Working at heights training in Ontario: who needs it and what counts

This is a construction-project requirement, not a general workplace rule

Working at heights training in Ontario applies to workers on construction projects — workplaces covered by O. Reg. 213/91. That boundary is often misunderstood: the requirement does not apply to all Ontario workplaces, only to those that fall under the Construction Projects regulation.

Workers at non-construction workplaces — offices, warehouses, maintenance operations — may have separate obligations to work safely at height under the OHSA and sector-specific regulations, but the mandatory CPO-approved working at heights program is a construction-sector requirement.

On a construction project, the obligation is triggered when a worker is required to use one of six specific fall protection methods. The training must be completed before the worker uses that equipment — not enrolled in, but completed.

The fall protection equipment that triggers the requirement

Under O. Reg. 213/91, an employer must ensure that a worker on a construction project completes working at heights training before the worker uses any of the following fall protection methods:

• Travel restraint system
• Fall restricting system
• Fall arrest system
• Safety net
• Work belt
• Safety belt

What the training must be — and the fraud warning

The training program must be approved by the Chief Prevention Officer of the Ministry of Labour, Immigration, Training and Skills Development, and it must be delivered by a provider who held CPO approval at the time the worker completed it. A course that was not CPO-approved at the time of delivery does not meet the requirement, regardless of its content.

The ministry issues a specific fraud warning about this: providers have accepted fees and issued training cards without delivering valid approved training. When enrolling workers, verify the provider appears on the MLITSD list of currently approved providers before booking.

Completing working at heights training does not replace the site-specific equipment training required by section 26.2 of O. Reg. 213/91. Workers need both: the general approved program and hands-on instruction on the specific systems in use at the site.

What employers are required to do

Ensuring valid training before a worker uses fall protection is an employer obligation. The employer must also verify that the provider was CPO-approved at the time the worker trained — not just that the worker holds a card.

Workers do not need to repeat approved training when they change employers, provided the training is still within its three-year validity period. The new employer is responsible for verifying that the existing training is valid.

• Confirm each worker has completed valid training from a CPO-approved provider before assigning fall-protection work on a construction project.
• Keep a training record for each worker: either a copy of the proof of completion document, or a written record noting the worker's name, the provider's name, the program name, and the date of completion.
• Make training records available to a Ministry of Labour, Immigration, Training and Skills Development inspector on request.
• Track expiry dates — training is valid for three years from the worker's date of completion, not from the date they joined your organisation.