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OHS Annual Reports You Must Submit to the Government – Know the Laws of Your Province

BC has the strictest annual reporting requirements, followed by Manitoba, Quebec, Ontario and the Federal jurisdiction.

In addition to fatalities, injuries and serious safety events that employers must report to the government on an ongoing basis as they occur, many jurisdictions require employers to submit annual reports related to different aspects of safety and the OHS program in the preceding the year. While requirements vary by jurisdiction, regular annual reports generally include updates on:

  • The number and nature of injuries that happened at the workplace during the year: FED, NT, NU, SK:
  • JHSC activities during the year: BC, QC;
  • Occurrences of workplace violence and harassment: FED, BC, MB; and
  • Reports on specific types of hazards or operations, such as lead smelting, coal mines, hearing protection and asbestos work.

Several jurisdictions, including FED, BC, MB, ON and QC,  require multiple annual reports; by contrast, the OHS regulations of 4 jurisdictions include no annual reporting requirements at all—NB, NL, PEI, YK.

Annual reporting requirements also differ with regard to:

  • Who must prepare the annual report;
  • To whom the report must be submitted and by when; and
  • Which information the report must include.

Here’s a summary of the annual OHS reporting requirements of all jurisdictions so you can ensure compliance no matter where in Canada you operate.

OHS Annual Reporting Requirements

1. Annual Hazardous Occurrence Report Form

Who Must Prepare Report: All employers

Deadline: March 1

Recipient: Fed government—Head of Compliance and Enforcement

Contents of Report: Annual Hazardous Occurrence Report Form listing the number of accidents, occupational diseases and other hazardous occurrences the employer is aware of affecting any employee in the course of employment during the 12-month period ending on December 31 of the preceding year (COHS Regs, Sec. 15.10)

2. Workplace Violence & Harassment Annual Report

Who Must Prepare Report: All employers

Deadline: March 1

Recipient: Fed government—Head of Compliance and Enforcement

Contents of Report: Annual workplace violence and harassment report listing: (a) employer’s name or business name; (b) employer’s Income Tax Act business number; (c) contact person; and (d) the following information about the occurrences for which notice was provided in the Annual Hazardous Occurrence Report in the preceding calendar year: (i) total number of occurrences, (ii) number of occurrences that were related, respectively, to sexual harassment and violence and non-sexual harassment and violence, (iii) number of occurrences that resulted in an employee’s death, (iv) if known, number of occurrences that fell under each prohibited ground of discrimination set out in subsection 3(1) of the Canadian Human Rights Act, e.g., race, religion, sex, etc. (v) locations the occurrences took place, and total number of occurrences in each location, (vi) types of professional relationships that between the principal and responding parties, specifying the total number for each type, (vii) the means by which resolution processes were completed and, for each of those means, the number of occurrences involved, and (viii) the average number of months it took to complete the resolution process for an occurrence (COHS Regs, Sec. 36)

Annual Mine Plan

Who Must Prepare Report: Employers who are required to establish a mine certified by a professional engineer under Section 533 of the OHS Code

Deadline: September 30

Recipient: OHS Director

Contents of Report: (a) Proposed underground operations working plan for the next year of operation, (b) Ventilation plan for the next year of operation, and (c) Locations of all firefighting pipelines, water control valves, fire stations and fire cabinets (OHS Code, Sec. 681)

1. Annual JHSC Evaluation Report

Who Must Prepare Report: Employer or JHSC co-chairs or member(s) designated by the co-chairs

Deadline: Not specified

Recipient: (a) If evaluation prepared by employer, must be submitted to JHSC co-chairs or member(s) designated by the co-chairs, or (b) If evaluation prepared by JHSC co-chairs or member(s) designated by the co-chairs, must be submitted to the employer

Contents of Report: Written evaluation of each JHSC at the workplace that lists: (A) Whether, during the evaluation period (citations to section numbers refer to the Workers Compensation Act): (i) the JHSC met the membership requirements of section 33, (ii) worker representatives on the JHSC were selected in accordance with section 34,  (iii) employer representatives on the JHSC were selected in accordance with section 35, (iv) the JHSC fulfilled each of its duties and functions under section 36, (v) the JHSC met regularly as required by section 37(2), (vi) the employer met section 39 requirements regarding the written recommendations sent by the JHSC with a written request for a response from the employer, if any, (vii) each member of the JHSC received the time off from work entitled under section 40, (viii) each member of the JHSC attended the OHS training courses the member was entitled to attend under section 41, (ix) the employer provided the JHSC the equipment, premises, clerical personnel and information under section 42, (x) the JHSC prepared reports of its meetings and provided copies to the employer as required under section 43(1), (xi) the employer met the requirements of posting and keeping posted committee information in section 44, and (xii) each member of the JHSC received the instruction and training the employer was required to ensure was provided under section 3.27 of the OHS Regulation; (B) An assessment of the effectiveness of the joint committee’s rules of procedures as established under section 37(1); and (C) An assessment of the overall effectiveness of the JHSC (OHS Regs., Sec. 3.26)

2. Written Audit Security Annual Report

Who Must Prepare Report: Independent qualified security expert hired by the employer of workers that work alone or in isolation at a late-night retail site who are required to implement a violence prevention program under Section 4.22.1(2) of the OHS Regulations

Deadline: By the end of the first year of implementing that program and by the end of every second year after that

Recipient: The hiring employer, which must then post the report in the workplace and leave it posted for the entire year and then replacing it with the new annual report from the preceding year

Contents of Report: Written security audit report confirming that: (a) there’ s a time lock safe on the premises that can’t be opened during late night hours; (b) cash and lottery tickets not reasonably required to operate during late night hours are stored in the time lock safe; (c) there’s good visibility both into and out of the premises; (d) there’s limited access to the inside of the premises; (e) the premises is monitored by video surveillance; (f) there are signs on the premises, visible to the public, indicating that (i) the safe on the premises is a time lock safe that can’t be opened during late night hours, (ii) there’s a limited amount of accessible cash and lottery tickets on the premises, and (iii) the premises is monitored by video surveillance; (g) a worker assigned to work alone or in isolation in late night retail premises who’s at risk of harm from a violent act, (i) is at least 19 years of age, and (ii) is provided with a personal emergency transmitter that is monitored by (A) the employer, or (B) a security company or other person designated by the employer (OHS Regs, Sec. 4.22.1)

3. Primary Lead Smelters Annual Report to Board

Who Must Prepare Report: Employer engaged in primary lead smelting that’s exempt from the requirement to maintain airborne lead concentrations at or below the exposure limit in lead processing areas

Deadline: Not specified

Recipient: The Board, i.e., WorkSafeBC

Contents of Report: Annual written review of health protection plan to ensure that workers’ blood lead levels are minimized (OHS Regs., Sec. 6.69)

1. Annual Report on Violent Incidents

Who Must Prepare Report: Employers required to implement a workplace violence prevention program

Deadline: Not specified

Recipient: The JHSC or health and safety representative or, if there is no JHSC or health and safety representative at the workplace, the workers directly

Contents of Report: Written report that compiles: (a) the records of incidents of violence to a worker in the workplace, if any; (b) the results of any investigation into an incident of violence, including a copy of

(i) any recommendations for control measures or changes to the violence prevention policy, and (ii) any report prepared under section 2.9 in respect of such an incident; and (c) the control measures, if any, implemented as a result of an investigation into an incident (WSH Regs., Sec. 7.2)

2. Bi-Annual Report on Noise Control Measures

Who Must Prepare Report: Employers required to provide audiometric testing

Deadline: Once every 2 years at unspecified date

Recipient: Within 30 days of preparing it, employer must provide a copy of the report to: (a) the physician or audiologist engaged by the employer under subsection 12.4(3) of the Reg.; (b) the workplace JHSC or health and safety representative; and(c) the Manitoba OHS director

Contents of Report: Written report that sets out a detailed account of the steps taken by the employer to comply with the requirements of Part 12 of the Reg. (Hearing Conservation & Noise Control), including: (a) the sound control measures taken at the workplace; and (b) statistics for the number of workers: (i) who received required audiometric testing, (ii) who experienced an abnormal audiogram or an abnormal shift, and (iii) whose abnormal audiogram and abnormal shift was, in the opinion of the physician or audiologist who reviewed the test results, a result of exposure to noise at the workplace (WSH Regs., Sec. 12.6)

No annual reports specifically required by OHS Regulations

No annual reports specifically required by OHS Regulations

Annual Report on Coal Mining Job Training Program

Who Must Prepare Report: Employers at a coal mine

Deadline: Not specified

Recipient: Nova Scotia OHS Director

Contents of Report: Annual summary of training carried out as part of the job training program, including, for each course delivered in the year: (a) the dates the course was delivered; (b) the course instructor(s); (c) the course’s subject matter; (d) the location where the course was delivered; (e) the name of each student enrolled in the course; and (f) the mark each student received on every exam or assignment in the course (Underground Mining Regs., Sec. 518)

1. MOL Asbestos Work Report

Who Must Prepare Report: Employer of a worker in a Type 2 or Type 3 asbestos operation on a construction project or building a repair operation

Deadline: At least once a year and immediately upon termination of the worker

Recipient: Provincial Physician, Ministry of Labour (MOL) and the worker

Contents of Report: A copy of the MOL Asbestos work report form for each worker (Designated Substance—Asbestos on Construction Projects and in Buildings and Repair Operations Regs., Sec. 21)

2. Annual Survey of Potentially Hazardous Elements on Mining Plant Feed Streams & Concentrates

Who Must Prepare Report: Employers of workers at a mine or mining plant

Deadline: Not specified

Recipient: Workplace JHSC or health and safety representative

Contents of Report: A copy of annual survey of potentially hazardous minor elements on all feed streams to and concentrates coming from a mining plant, along with an assessment of the potential hazard from the elements detected in the survey due to the processes used in the mining plant (Mines & Mining Plant Regs., Sec. 267)

No annual reports specifically required by OHS Regulations

1. Annual JHSC Activities Report

Who Must Prepare Report: The workplace JHSC at an establishment employing more than 20 workers and belonging to a category identified for that purpose by the regulation

Deadline: March 31

Recipient: CNESST

Contents of Report: Annual report of activities from 1 January to 31 December and listing the following information: (a) identification of the certified associations represented on the JHSC; (b) the number of workers in the establishment; (c) the list of committee members and their function in the establishment; (d) the frequency of meetings and the average annual rate of attendance at the meetings; (e) the name of the physician in charge of health services in the establishment; (f) any amendments made to the prevention program that ensue from recommendations of the committee; (g) the number and nature of complaints received; and (h) the number of incident investigation queries carried out under section 78(9) of the OHS Act, specifying the incidents that caused a work accident or an occupational disease (Reg. respecting Health and Safety Committees, Sec. 34)

2. Annual Updating of Prevention Program

Who Must Prepare Report: Employers required to implement a prevention program at the workplace

Deadline: The anniversary of the date the employer initially submitted the prevention program to CNESST

Recipient: CNESST

Contents of Report: Annual updating of the prevention program (Reg. respecting Prevention Programs, Sec. 8)

Annual Workplace Injury Report

Who Must Prepare Report: Employers if the government requests the report

Deadline: Not specified

Recipient: The OHS Ministry or agency designated by the Minister that requests the report

Contents of Report: Report setting out details of all hours worked and all work-related injuries during the preceding year (OHS Regs., Sec. 2-5)

Annual Workplace Injury Report

Who Must Prepare Report: Employers if the government requests the report

Deadline: Not specified

Recipient: The Chief Safety Officer or person or organization designated by the Chief Safety Officer that requests the report

Contents of Report: Report setting out out details of person hours worked and work-related injuries during the preceding year that occurred in the Northwest Territories or Nunavut (OHS Regs., Sec. 11)

No annual reports specifically required by WSC Regulations