What Does an Alberta OHS Program Have to Include?

You have reached 20 workers, or a general contractor has asked for your health and safety program before you can bid. Either way, you need to know what has to be in it, and how much of it you have to write from scratch.

Does Alberta require your company to have one?

20 or more regularly employed workers: you must establish a health and safety program. The requirement sits in section 16 of the Alberta OHS Act.

The count is company-wide. Workers at all of your work sites add up toward the 20. Full-time and part-time each count as one worker, workers hired through temporary staffing agencies count, and volunteers are included. The number is based on the average number of workers at your work sites on a daily basis over the previous 12 months, or since operations began if that is shorter.

Fewer than 20: no program requirement, but you still need documentation that meets the legal requirements that apply to you, including hazard assessment and control and an emergency response plan. Affected workers must be involved, and consulting your health and safety representative is recommended.

What the legislation mandates, and what it leaves to you

Alberta's OHS legislation does not lay out a mandatory list of program elements. The Act defines a health and safety program as a coordinated system of procedures, processes and other measures designed to promote continuous improvement in occupational health and safety, and leaves the shape of it to the employer. That freedom is where owners get stuck, because nobody hands them the list.

What is not optional is the legal requirements underneath. Hazard assessment, emergency response planning, health and safety committees and worker training should all be part of your program, and you must comply with them whether or not they appear in the document. Building those into one coherent system for a construction operation is what OHS program development is for.

The program must also be developed in conjunction with your joint work site health and safety committee or health and safety representative, if you have one.

The elements a working program is built from

Alberta publishes foundational elements that help build a well-rounded program. For a construction or trades employer, they tend to look like this:

1. Policy and roles. A health and safety policy and defined responsibilities for management, supervisors and workers.
2. Hazard assessment and control. A documented process for identifying hazards on each job and deciding how to control them. Most other elements draw from this one.
3. Safe work procedures. Written procedures for the tasks your people actually do.
4. Training and orientation. New worker orientation, site-specific training and supervisor training.
5. Inspections. Scheduled inspections, with records and a way to track corrections to completion.
6. Incident reporting and investigation. Including near misses, with findings fed back into procedures and training.
7. Emergency response. A plan for each site, first aid arrangements and drills.
8. Committee or representative. Meeting records and a way to raise concerns without reprisal.
9. Annual review. A look at what is working and what needs updating.

How it flexes for construction work

• Multiple work sites. One program can cover all of them, but hazard assessments, emergency response plans, inspections and training often need to be site-specific.
• Multiple employers on one site. You need procedures to protect health and safety when another employer or self-employed person is working alongside you. Where there is a prime contractor, the prime contractor coordinates the programs; where there is not, the employers coordinate with each other.
• COR. Alberta's Certificate of Recognition is voluntary and is awarded to employers whose health and safety management systems meet established standards, verified by an audit through a certifying partner. A program built to the legislated minimum is a starting point, not a COR-ready system.

Build it in this order

1. Confirm your worker count and which legal requirements apply to your type of work.
2. Write the policy and assign responsibilities by role.
3. Do the hazard assessments first. Procedures, training and inspections all depend on them.
4. Turn assessments into written procedures and a training plan.
5. Set the recurring cycle: inspections, committee meetings, incident reviews, annual program review.
6. Build it with your committee or representative involved, not informed afterwards.
7. Keep records. A program you cannot show is a program you cannot prove.

If you would rather not start from a blank page, Salient builds OHS programs for Alberta construction and trades employers — policy, hazard assessments, procedures, training and the record-keeping that holds it all together. OHS program development is the full build, and our service plans keep the program maintained as your sites and headcount change. Book a free discovery call and we will tell you what your operation actually needs.

Frequently asked questions

Do I need an OHS program if I have fewer than 20 workers?

No. Employers with fewer than 20 regularly employed workers are not required to have a health and safety program, but they still must have documentation in place that meets the legal requirements applying to their work, including assessment and control of workplace hazards and an emergency response plan. Affected workers must be involved, and consulting a health and safety representative is recommended where there is one.

Does Alberta specify exactly what an OHS program must contain?

No. Alberta's OHS legislation does not set out a mandatory list of program elements, so employers can shape the program to fit their workplace. What is not optional is the legal requirements underneath it, such as hazard assessment, emergency response planning, health and safety committees and worker training, which must be complied with whether or not they are written into the program.

Can one OHS program cover multiple work sites?

Yes. One program can cover all of an employer's work sites, and the workers at all of those sites count toward the 20-worker threshold. Some parts, including hazard assessments, emergency response plans, inspections and training, may need to be adjusted to suit each site.

Is having an OHS program the same as being COR certified?

No. Alberta's Certificate of Recognition is voluntary and is awarded to employers whose health and safety management systems meet established standards, verified by an audit through a certifying partner. A program built to the legislated minimum is the starting point; certification is a separate step.