This question comes up quite frequently and I’ve heard many answers over the years. I’ve heard you only have to do it once; you have to do it annually, or every three years. I’ve even heard that it doesn’t matter. So what is correct?
Part IV of the Act deals with Toxic Substances and outlines requirements for the identification and assessment of hazardous materials in the workplace and the instruction and training required if there is a likelihood of exposure. s.42.(3) Review, states that an employer must review, in consultation with the JHSC (20+ employees) or the health and safety rep. (6-19 employees) the training and instruction provided to a worker and how familiar the worker is with that training at least annually.
So what is the employer’s obligation? Do we need to conduct full-blown training or can we do a basic review? This depends on your environment, the hazardous material present, the training that has already been provided and how the handling, use, storage, transport and disposal of hazardous materials are managed.
If you are auditing these elements on an annual basis and find that workers are not familiar with the nature of the chemicals they are exposed or likely to be exposed to, they cannot recall training, Safety Data Sheets are not readily available, material labels are illegible or missing, materials are stored incorrectly, or there have been incidents, then a basic annual review is not sufficient and more extensive training is required.
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