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Ontario Erectors Association

MOL February Report


MOL Report to LM 2018 February

Provincial Coordinator’s Comments

At our recent Safe at Work Ontario (SAWO) consultations, I had the opportunity to engage in some really interesting dialogue about risk, data and information management, workplace violence, MOL’s enforcement campaigns and falls. I was amazed at the participant’s innovative answers to the questions we were asking. I’d like to thank everyone who took the time to contribute positive, thoughtful and constructive comments, and for participating in the consultation sessions.

During the consultations, I heard many great ideas and also noticed some themes. One of these themes I heard from participants was the benefits of the working at heights (WAH) standard. One of the main benefits that the constructors and employers in attendance noted, was that they no longer have to worry about fall protection training when they hire a new worker (provided they have already received the training). While I agree that the development of the WAH standard was a step in the right direction, it does concern me that employers may be taking the training card at face value and thinking that is all that is required for workers to work at heights.

Not only should employers individually assess each worker’s knowledge in WAH, employers also need to provide their workers component and application specific training which is not covered in WAH. This level of training is in accordance with section 26.2(1) of the construction regulation.

Having a working at heights training card is similar to a driver’s license, it does not guarantee that you are a good driver or ensure that you truly understand all the rules of the road. A driver’s license does not teach you how to get out of a tricky situation or how to avoid an accident, it’s a card that shows that you have proven a minimum level of knowledge to be able to operate a vehicle on a public roadway. Similarly, WAH only proves that you have the basic understanding of fall protection principles.

As employers you have the responsibility to ensure that your workers have the appropriate level of training, knowledge and experience to be able to effectively use a fall protection system. Part of that responsibility is assessing each new worker to ensure they can properly apply WAH training to the fall protection situation at hand. In addition to verifying your workers application of WAH principles, section 26.2(1) of Ontario regulation 213/91 states that “an employer shall ensure that a worker who may use a fall protection system is adequately trained in its use and given adequate oral and written instructions by a competent person”. Section 26.2(1) is in addition to the WAH training requirements in Ontario regulation 297/13. WAH training is designed to give the basic fundamentals of fall protection principles whereas section 26.2(1) is designed to take that basic knowledge and strengthen it to a site specific application. Section 26.2(1) uses WAH as the base knowledge and builds site specific application and equipment into a complete training package to ensure the end user has the ability to successfully and safely perform the task at hand.

Our inspectors routinely find workers who have WAH training, which is positive, however, adequate training under section 26.2(1) is less common. As a result we often see the most basic of systems being used inappropriately which not only frustrates the worker, but also exposes them to unnecessary risk. Employers need to take the time to fully understand the fall protection systems that best suits the need of their workers on site and train the workers on the system’s appropriate application, limitations, use and installation.

As a system, we need to take a hard look at the training we are providing to our workers and determine whether or not it is providing a strong knowledge base that our workers can use and apply to protect themselves and others. Our inspectors will continue to ensure that both WAH training requirements, as well as adequate oral and written instruction under section 26.2(1) has been completed prior to performing work at heights.

Brian Barron

Provincial Coordinator

Construction Health and Safety Program

Ontario Ministry of Labour