A regulatory inspector from the provincial occupational health and safety authority arrived at a mid-sized metal fabrication facility in central Alberta 3 days after a worker suffered a serious crush injury while operating a hydraulic press. The injured worker, a machine operator with 14 months of employment at the facility, sustained multiple fractures to his left hand and forearm when the press cycled unexpectedly during a clearing procedure. The injury required surgical intervention and would keep the worker off the job for an estimated 6 to 8 months. The inspector's arrival marked the beginning of what would become an extensive investigation into the employer's safety practices, documentation systems, and supervisory arrangements.

The facility employed approximately 85 workers across 2 production shifts and had operated under the same ownership for 11 years. The operations manager, who also held responsibility for health and safety matters, met with the inspector and began producing documents in response to formal requests. The inspector asked for the written safety program, hazard assessments for the hydraulic press operation, training records for the injured worker, competency verification documentation, supervision logs, and records of any previous incidents involving similar equipment. Over the following weeks, the inspector would interview supervisors, review maintenance records, examine the physical safeguards on the equipment, and assess whether the organization's documented safety systems reflected actual workplace practices.

The organization did have a written safety manual, last revised 4 years earlier, and maintained some training records in a combination of paper files and spreadsheet entries. Hazard assessments existed for several production processes but had not been updated following equipment modifications made 18 months prior. The supervisor on duty at the time of the incident had been promoted to the role 7 months earlier and had received informal orientation to supervisory responsibilities but no documented training on safety supervision obligations. The injured worker's training file contained a signed acknowledgment form from his initial orientation but no subsequent competency verification records despite the worker having transitioned to operating the hydraulic press 5 months into his employment.

As the investigation proceeded, the employer faced mounting questions about whether its safety program, training documentation, supervision practices, hazard assessments, and incident response procedures would meet the standard required to establish a due diligence defence. The HR manager and operations manager began working with external advisors to understand what regulators and courts look for when assessing whether an employer took all reasonable precautions, and to evaluate whether the organization's existing documentation could support such a defence or whether critical gaps would undermine its legal position.