WHMIS Training Requirements in Ontario for Employers

What are an Ontario employer's WHMIS training requirements?

Under R.R.O. 1990, Reg. 860, an Ontario employer must ensure every worker who works with, or may be exposed to, a hazardous product is instructed in how to read labels and safety data sheets, in safe use, storage, handling and disposal, and in emergency procedures. The employer must also keep supplier labels and safety data sheets in place and up to date, and the instruction must be developed for that workplace.

Who WHMIS applies to

Ontario's WHMIS legislation applies to all workplaces except farms, according to the Ontario government's WHMIS page. The detailed duties sit in Regulation 860 under the Occupational Health and Safety Act, and they apply to employers and workers in respect of hazardous products used, stored and handled at a workplace (s. 4(1)).

A hazardous product is one classified under the federal Hazardous Products Regulations in a hazard class listed in Schedule 2 to the Hazardous Products Act (s. 1(1)). Some items are carved out of parts of the regulation, including wood products, tobacco products, manufactured articles, and products being transported or handled under dangerous goods transportation law (s. 4(3)).

The employer duties at a glance

WHMIS employer duties in Ontario: the essentials

Governing regulation: R.R.O. 1990, Reg. 860, Workplace Hazardous Materials Information System (WHMIS), under the OHSA
Who must be instructed: Every worker who works with, or may be exposed in the course of work to, a hazardous product (s. 7(1))
Hazard information: Workers must be informed of all hazard information the employer receives from the supplier and all further hazard information the employer is or ought to be aware of (s. 6(1))
Program is workplace-specific: The education program must be developed and implemented for the employer's workplace and related to other training, instruction and prevention programs (s. 7(2))
Effectiveness standard: So far as reasonably practicable, the program must result in workers being able to use the information to protect their health and safety (s. 7(3))
Supplier labels: Hazardous products received from a supplier must carry a supplier label; the employer must not alter it while product remains in the container (s. 8(1), 8(2))
Safety data sheets: The employer must obtain a supplier safety data sheet and update it as soon as practicable after significant new data is provided or becomes available (s. 17(1), 17(2))
Refresher or expiry period: Regulation 860 sets no fixed expiry or refresher interval for WHMIS instruction

What worker instruction must cover

Section 7(1) requires the employer to ensure each exposed worker is instructed in:

The contents required on labels, and the purpose and significance of the information on them
The contents required on a safety data sheet, and the purpose and significance of that information
Procedures for the safe use, storage, handling and disposal of a hazardous product
The same procedures when a product is contained or transferred in a pipe, piping system, process vessel, reaction vessel, or a tank car, tank truck, ore car, conveyor belt or similar conveyance
Procedures to follow when fugitive emissions are present
Procedures to follow in an emergency involving a hazardous product

Labels in the workplace

If a supplier label becomes illegible or is removed, the employer must replace it with a supplier label or a workplace label (s. 8(3)). If a hazardous product is moved from its supplier container into another container, the other container must have a workplace label (s. 10(1)).

A workplace label must show a product identifier identical to the one on the safety data sheet, information for safe handling, and a statement that a safety data sheet is available (s. 1(1)). There is a limited exemption for a portable container filled directly from a labelled container where the product is used only by the worker who filled it, only during that shift, and the contents are clearly identified (s. 10(2)).

Does WHMIS training expire?

Regulation 860 does not set an expiry date or a fixed refresher interval for WHMIS instruction, and the Ontario government's WHMIS page says only that employers must ensure workers are trained on hazardous products before they use them, with the type and amount of training depending on whether a product is new to the workplace or newly classified as hazardous.

Training certificates issued by course providers may carry their own dates, but those are not set by the regulation. Because the employer must keep instruction effective and tied to the hazards actually in the workplace (s. 7(2), 7(3)) and must update information when significant new data arrives (s. 6(1), 17(2)), instruction usually needs revisiting when products, labels or procedures change. Whether a particular certificate is accepted is a question for the employer and, ultimately, a Ministry inspector.

Where the authority sits. Syon Safety is not a certifying or inspecting body. WHMIS duties in Ontario are set by Regulation 860 under the Occupational Health and Safety Act and enforced by Ministry of Labour, Immigration, Training and Skills Development inspectors. This guide is general information, not legal advice.

Frequently asked questions

Is WHMIS training mandatory for every employee in Ontario?

It is mandatory for every worker who works with, or may be exposed in the course of work to, a hazardous product (Reg. 860, s. 7(1)). It also forms part of basic health and safety awareness training under O. Reg. 297/13.

Does WHMIS apply to a small business?

Yes. Regulation 860 contains no exemption based on the number of employees. The Ontario government states that WHMIS legislation applies to all workplaces except farms.

How often does WHMIS training need to be repeated in Ontario?

Regulation 860 sets no fixed refresher interval. The employer must ensure instruction is effective and covers the hazardous products actually in the workplace, so retraining is usually needed when products or procedures change.

Can an employer use an online WHMIS course?

The regulation does not prescribe a delivery format. It requires that instruction cover the listed content and be developed and implemented for the employer's workplace (s. 7(2)), so generic training generally needs workplace-specific instruction added.

What is the difference between a supplier label and a workplace label?

A supplier label is provided by the supplier and carries the information required by the federal Hazardous Products Regulations. A workplace label is applied by the employer, for example when a product is decanted, and must show the product identifier, safe handling information and that a safety data sheet is available.

Sources

Every regulatory claim above is taken from the body that sets the requirement, listed here so you can check it yourself rather than take our word for it.

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WHMIS training requirements in Ontario: what employers must do