2019 WHMIS / GHS Workplace-Specific Training Guidelines

An employer has a general duty to ensure a worker “exposed or likely to be exposed” to a hazardous product receives and participates in prescribed instruction and training (subsection 42(1), OHSA). The WHMIS Regulation requires a worker “who works with or who may be exposed in the course of his or her work to a hazardous product” to receive certain information (section 6, WHMIS Reg.). The following points are intended to guide workplace parties and inspectors when determining which workers should participate in instruction and training:

1. An “exposed worker” is any worker who uses, handles, stores or disposes
of a hazardous product, or who directly supervises another worker performing
these activities.

2. A worker “likely to be exposed” is any worker who could be at risk during:
• the use, handling, storage or disposal of a hazardous product;
• maintenance operations; or
• emergencies, such as an accidental leak or spill.

The worker education program must be developed and implemented for the employer’s workplace and be related to any other training, instruction and prevention programs at the workplace (subsection 7(2), WHMIS Reg.). In developing and implementing the program, the employer must consult the joint health and safety committee or health and safety representative (subsection 42(2), OHSA). There is no specific requirement to keep records of WHMIS training, but an employer may wish to do so to be able to demonstrate to an inspector that workers have received appropriate information and instruction.

The employer must ensure, so far as is reasonably practicable, that the WHMIS education program results in workers being able to use the information to protect their health and safety (subsection 7(3), WHMIS Reg.). The OHSA requires the employer to review the worker’s familiarity with the training and instruction provided at least annually, and in consultation with the joint health and safety committee or health and safety representative, if any (subsection 42(3), OHSA).

It is left to the individual employer to devise the means to determine that a worker has been properly trained and instructed. For example, the employer may ask workers to take some form of written or oral test, or to participate in a practical demonstration of their knowledge. Subsection 7(3) of the WHMIS Regulation includes the phrase “so far as is reasonably practicable” because it is recognized the employer may have difficulty at times determining with certainty what workers have learned, due either to language or literacy problems. In general, workers should be able to answer the following questions for every hazardous product they use.

1. What are the hazards of this product?
2. How do I protect myself?
3. What should I do in an emergency?
4. Where is the safety data sheet? Where can I get more information?

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