← University
Hazard Identification and the Hierarchy of Controls
Faculty of Human ResourcesWorkplace Safety
0 of 6
123456

A regulatory inspection report sits on the desk of the operations manager at a mid-sized metal fabrication facility in southwestern Ontario, and its findings have prompted an urgent review of the company's entire approach to workplace safety. The facility employs approximately 85 workers across 2 shifts, operating cutting, welding, grinding, and finishing processes that expose workers to a range of physical, chemical, and ergonomic hazards. The inspector's report, issued following an unannounced visit 3 weeks earlier, identified multiple deficiencies: incomplete hazard assessments for several work stations, inconsistent application of control measures across similar operations, missing or outdated Safety Data Sheets for 4 chemical products in active use, and inspection records that showed gaps of up to 6 months between documented workplace inspections in certain production areas.

The facility has operated for 12 years under its current ownership, and until 18 months ago, its safety record was unremarkable. A lost-time injury rate that had held steady at roughly 2.3 incidents per 100 workers began climbing after the retirement of a long-serving health and safety coordinator whose institutional knowledge had never been formally captured in written procedures or documentation. The replacement coordinator, hired from outside the organization 14 months ago, inherited binders of paper records in varying states of completion, an electronic filing system with no consistent naming conventions, and a joint health and safety committee that had been meeting irregularly. Worker training records existed for initial WHMIS orientation but showed no evidence of refresher training or job-specific hazard communication for workers who had changed roles within the facility.

The most recent incident preceding the inspection involved a worker who sustained burns to both forearms while operating a plasma cutting station. The investigation revealed that the required heat-resistant sleeves had been available but not worn, that the hazard assessment for that station had last been reviewed 27 months earlier despite equipment upgrades in the interim, and that the worker had received no documented training on the specific hazards of the upgraded equipment. The employer now faces decisions about how to rebuild its hazard identification processes, what methodology to apply when assessing and prioritizing risks, how to structure control measures in accordance with legal expectations, what documentation practices will satisfy due diligence requirements going forward, how frequently and thoroughly to conduct workplace inspections, and how to communicate hazard information effectively to workers who speak 4 different first languages across the workforce.

Hazard Communication: WHMIS, Safety Data Sheets, and Worker Training

Effective hazard communication represents the critical bridge between hazard identification, risk assessment, and the practical protection of workers in Canadian workplaces. While the preceding lessons in this course have examined how to identify hazards and apply the hierarchy of controls, this final lesson addresses the equally essential matter of ensuring that workers and supervisors understand the hazards they may encounter and the protective measures in place. Without robust communication systems, even the most sophisticated hazard controls fail to achieve their protective purpose. The Workplace Hazardous Materials Information System, commonly known as WHMIS, stands as Canada's national hazard communication standard for hazardous products used in workplaces, but effective hazard communication extends well beyond chemical hazards to encompass all workplace dangers that workers need to understand to perform their duties safely.

The legal foundation for hazard communication in Canada rests on both federal and provincial legislation, creating a comprehensive framework that applies across all Canadian workplaces. At the federal level, the Hazardous Products Act establishes the supplier requirements for WHMIS, mandating that manufacturers, importers, and distributors of hazardous products provide appropriate labels and safety data sheets. The federal Hazardous Products Regulations, as of the date of authorship, align Canadian requirements with the Globally Harmonized System of Classification and Labelling of Chemicals, ensuring consistency with international standards and facilitating trade while protecting workers. For federally regulated employers in sectors such as banking, telecommunications, interprovincial transportation, and federal Crown corporations, the Canada Labour Code Part II and the Canada Occupational Health and Safety Regulations establish employer obligations regarding hazard communication, worker training, and the maintenance of safety data sheets. Provincial and territorial occupational health and safety legislation creates parallel obligations for employers under provincial jurisdiction, which encompasses the vast majority of Canadian workers. In British Columbia, the Workers Compensation Act and the Occupational Health and Safety Regulation administered by WorkSafeBC establish detailed requirements for hazard communication and WHMIS training. Alberta's Occupational Health and Safety Act and its associated code similarly mandate employer compliance with WHMIS requirements and broader hazard communication obligations. Saskatchewan's Saskatchewan Employment Act Part III and accompanying regulations govern workplace safety requirements including hazard communication in that province. Ontario's Occupational Health and Safety Act contains specific WHMIS provisions alongside general requirements for workplace hazard communication and worker instruction. Quebec's approach reflects its distinct civil law tradition, with the Act Respecting Occupational Health and Safety and the Regulation Respecting Information on Controlled Products establishing requirements that align with WHMIS principles while operating within Quebec's broader occupational health and safety framework administered by the Commission des normes, de l'équité, de la santé et de la sécurité du travail.

That’s the free preview

You’ve reached the end of what’s open to read. The rest of this lesson is part of a $149 course — purchasing unlocks it, or sign in if you already have access.

Unlock this course — $149
Join Binder UniversityTry Binder

More in this program

OHS Incident Reporting Obligations: What Must Be Reported Across Canada
Incident Investigation and Reporting Obligations
The Due Diligence Defence in Canadian OHS Law: What It Requires
OHS Due Diligence: Building and Documenting a Defence
The OHS Framework in Canada: Federal and Provincial Jurisdiction
OHS Framework and Employer Obligations Across Canada