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FLHA questions answered

Is an FLHA mandatory in Canada?

No province requires a form with the name "FLHA", but provincial law does require employers to assess and control hazards, and an FLHA is a common way to record that on site. Alberta is the most explicit: the employer must assess the work site and identify existing and potential hazards before work begins, write up the results with the control methods, and record the date. The assessment must be repeated when work or conditions change.

Source: Alberta OHS Code, Part 2: Hazard Assessment, Elimination and Control

What is the difference between an FLHA and a JHA?

A JHA plans a job ahead of time step by step, while an FLHA is done at the work site just before the work starts to check the hazards of that day and place. CCOHS describes a job hazard analysis (also called a job safety analysis) as breaking a job into basic steps, identifying the hazards of each step and setting the safest way to do it. Energy Safety Canada's COR audit protocol also treats a formal, task-based hazard assessment as separate from a field level or site-specific hazard assessment.

Source: CCOHS OSH Answers: Job Safety Analysis

How often must hazard assessments be done in Alberta?

In Alberta a hazard assessment must be done before work begins at a work site, and then repeated whenever the work or the site changes. Under OHS Code s.7(4) it must be redone at reasonably practicable intervals to prevent unsafe conditions developing, when a new work process is introduced, when a work process or operation changes, and before significant additions or alterations to a work site. The date it was prepared or revised must be recorded on it.

Source: Alberta OHS Code, Part 2: Hazard Assessment, Elimination and Control

Do FLHAs need to be in French in Quebec?

Yes, an FLHA given to a crew in Quebec should be in French. The Quebec government states that, under the Charter of the French Language, employers must use French in written communications addressed to staff and must draw up training documents produced for staff in French.

Source: Quebec.ca: Obligations in matters of the French language

What should an FLHA include?

An FLHA should record the work site, the date, the tasks, the existing and potential hazards, and the controls for each hazard. Alberta's OHS Code requires a written report of the hazard assessment and the methods used to eliminate or control the hazards, with the date it was prepared or revised. Controls must follow the hierarchy: eliminate the hazard if reasonably practicable, then engineering controls, then administrative controls, then PPE. Because affected workers must be involved, the FLHA should also show who took part.

Source: Alberta OHS Code, Part 2: Hazard Assessment, Elimination and Control

Who fills out an FLHA?

The employer is legally responsible for the hazard assessment, but the workers doing the job must take part in it. Alberta's OHS Code s.7 puts the duty to assess the work site on the employer, and s.8 requires the employer to involve affected workers in the assessment and in eliminating or controlling the hazards found.

Source: Alberta OHS Code, Part 2: Hazard Assessment, Elimination and Control

Do workers have to be involved in the hazard assessment?

Yes, in Alberta the employer must involve affected workers in the hazard assessment and in eliminating or controlling the hazards it identifies. This is OHS Code s.8(1), so an FLHA should show that the crew took part, not only that they read it.

Source: Alberta OHS Code, Part 2: Hazard Assessment, Elimination and Control

How long do you have to keep FLHAs?

Alberta's hazard assessment rules do not set a retention period, but keeping completed FLHAs for at least three years is a safe benchmark. Energy Safety Canada's COR audit protocol asks whether safety records are kept for at least one full audit cycle, which is three years. COR auditors also look at site-specific hazard assessments done over the previous 12 months.

Source: Energy Safety Canada COR Audit Protocol 2023

What is a prime contractor and when is one needed?

A prime contractor is the person or company that coordinates health and safety on a work site where more than one employer is working. In Alberta, every construction or oil and gas work site with 2 or more employers must have a prime contractor, designated in writing by the person in control of the site, and if no one is designated that person is the prime contractor. The prime contractor must post its name at the site and set up a system to ensure compliance with the OHS Act, regulations and Code.

Source: Alberta OHS Act, Part 1: General Obligations

Who is the prime contractor in British Columbia?

In BC, the prime contractor of a multiple-employer workplace is the directing contractor or other person who has a written agreement with the owner to be the prime contractor, or the owner if there is no such agreement. A multiple-employer workplace is one where workers of 2 or more employers are working at the same time. Under the Workers Compensation Act s.24, the prime contractor must coordinate health and safety activities, and each employer must give it the name of the person supervising its workers.

Source: WorkSafeBC: Workers Compensation Act, Part 2 (Occupational Health and Safety)

Who is the constructor in Ontario?

The constructor is the person who undertakes a construction project for an owner, and it includes an owner who does all or part of a project themselves or through more than one employer. Under OHSA s.23, the constructor must ensure that the Act and regulations are followed on the project, that every employer and worker complies, and that workers' health and safety is protected.

Source: Ontario Occupational Health and Safety Act, R.S.O. 1990, c. O.1

What is COR in construction?

COR (Certificate of Recognition) is a voluntary certification for employers whose occupational health and safety management system meets an audited standard. It is a nationally trademarked program endorsed by the Canadian Federation of Construction Safety Associations, and many contractors need it to prequalify for public and private sector projects. In Ontario, IHSA is the body that grants COR.

Source: IHSA: Certificate of Recognition (COR) in Ontario

How do you get COR in Alberta construction?

You get COR by passing an external audit of your health and safety management system with at least 80 percent overall and at least 50 percent on each element, reviewed by your certifying partner such as ACSA. A COR is typically valid for three years, as long as the annual internal maintenance audit requirements are met. In Alberta, COR is a voluntary program run by the Government of Alberta.

Source: Alberta Construction Safety Association: COR Process

At what height is fall protection required in Canada?

Fall protection is generally required from 3 metres in Canada, and at lower heights where a fall could land a worker on or in a hazard. Alberta requires it at 3 metres or more, below 3 metres where there is an unusual possibility of injury, into or onto a hazardous substance or object or through an opening, and above 1.2 metres at a permanent work area. Ontario applies its rules to falls of more than 3 metres, more than 1.2 metres on a wheelbarrow path, and falls into operating machinery, water or a hazardous substance.

Source: Alberta OHS Code, Part 9: Fall Protection

When does a trench need shoring?

A trench needs shoring, sloping or another protective system from 1.2 metres deep in Ontario and BC, and from 1.5 metres deep in Alberta and Manitoba. Alberta's OHS Code s.450 requires workers to be protected from cave-ins by cutting back the walls, using temporary protective structures, or both, before they work in an excavation more than 1.5 metres deep and closer to the wall than the depth of the excavation. Each province has its own exceptions, such as excavations cut in sound and stable rock.

Source: Alberta OHS Code, Part 32: Excavating and Tunnelling

Do I need a written fall protection plan?

In Alberta you need a written fall protection plan when a worker may fall 3 metres or more and is not protected by guardrails, and in BC when workers are not protected by permanent guardrails and a fall of 7.5 metres or more may occur. Alberta's plan must list the fall hazards, the fall protection system, the anchors, the clearance below, how the system is assembled, maintained, inspected, used and taken down, and the rescue procedure. It must be available at the work site and reviewed with workers before the work begins.

Source: Alberta OHS Code, Part 9: Fall Protection

Do I need a written rescue plan for fall arrest in Ontario?

Yes, before any worker on an Ontario project uses a fall arrest system or a safety net, the employer must develop written procedures for rescuing the worker after a fall is arrested. This is O. Reg. 213/91 s.26.1(4). Workers who may use a fall protection system must also be adequately trained and given oral and written instructions by a competent person.

Source: Ontario O. Reg. 213/91: Construction Projects

What are the working alone rules in Alberta?

In Alberta, working alone is a hazard that must be covered in the hazard assessment whenever help would not be readily available in an emergency or if the worker is injured or ill. The employer must provide an effective communication system, such as radio, landline or cell phone, with regular contact at intervals that suit the hazard. If electronic contact is not practicable, the employer or a designate must visit the worker, or the worker must check in, at suitable intervals.

Source: Alberta OHS Code, Part 28: Working Alone

Does BC require a written working alone procedure?

Yes, BC employers must have a written procedure for checking the well-being of anyone assigned to work alone or in isolation. It must set the time between checks and what to do if the worker cannot be contacted, including emergency rescue, and a designated person must make the checks and record the results. A check at the end of the work shift is also required.

Source: WorkSafeBC OHS Regulation, Part 4: General Conditions

What is WHMIS and did it change in 2025?

WHMIS is Canada's system for giving workers hazard information on hazardous products through labels, safety data sheets and training, and its updated rules became fully mandatory for suppliers in December 2025. Amendments to the Hazardous Products Regulations came into force on December 15, 2022, with a 3 year transition, to December 15, 2025, for suppliers to update product classifications, safety data sheets and labels. Provincial, territorial and federal workplace WHMIS rules may also need updating.

Source: CCOHS OSH Answers: WHMIS, General

Is Working at Heights training mandatory in Ontario?

Yes, an Ontario construction worker who may use travel restraint, a fall restricting system, fall arrest, a safety net, a work belt or a safety belt must have completed Working at Heights training. Both the training program and the training provider must be approved by the Chief Prevention Officer. The training is valid for three years from the date it was successfully completed.

Source: Ontario O. Reg. 297/13: Occupational Health and Safety Awareness and Training

How long is a locate valid in Ontario?

A locate in Ontario is valid for 60 days, unless another period is prescribed by the Minister or the locator specifies a longer period. This is set by s.8 of the Underground Infrastructure Notification System Act, 2012.

Source: Ontario Underground Infrastructure Notification System Act, 2012

What is the right to refuse unsafe work?

Workers can refuse work they have reason to believe is likely to endanger themselves or another worker. In Ontario, this covers dangerous equipment, the physical condition of the workplace, workplace violence, and contraventions of the law that are likely to cause harm (OHSA s.43). The worker must promptly report the refusal to the employer or supervisor, who must investigate right away, and the worker stays in a safe place nearby until the investigation is complete.

Source: Ontario Occupational Health and Safety Act, R.S.O. 1990, c. O.1

When is a joint health and safety committee required in Ontario?

In Ontario, a joint health and safety committee is required at a workplace where 20 or more workers are regularly employed. The committee rule does not apply to a constructor at a project where work is expected to last less than three months. Where no committee is required and the number of workers regularly exceeds five, the workers must select at least one health and safety representative.

Source: Ontario Occupational Health and Safety Act, R.S.O. 1990, c. O.1

Do I need locates before digging in Alberta?

Yes, before the ground is disturbed in Alberta, the employer must contact the owners of buried facilities, tell them about the planned work, ask them to identify and mark their facilities, and wait until the locations are marked. Workers must be made aware of the locate marks, and marks moved or destroyed by the work must be re-established. Owners include the owner of any pipeline within 30 metres of the work site.

Source: Alberta OHS Code, Part 32: Excavating and Tunnelling

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