OHS Code review - Miscellaneous Changes and Approach to Referencing Technical Standards survey

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Third-party technical standards (standards) are documents outlining requirements for training, work procedures, equipment, materials or personal protective equipment (PPE). They are developed and maintained by organizations outside the Government of Alberta. Examples of standard-setting organizations include the CSA Group (CSA), American National Standards Institute (ANSI), American Society of Mechanical Engineers (ASME), and the National Institute for Occupational Safety and Health (NIOSH). Standard-setting organizations work with subject matter experts, industry stakeholders, and government participants to develop and update their standards, following their own internal review processes, which are independent of the government regulatory review process.

All Canadian jurisdictions refer to standards in their OHS legislation, although there are a mix of approaches used, even within a jurisdiction. While the most common approach is to cite specific editions of standards in legislation, some refer to the “latest edition”, or refer to an “approved” standard. Saskatchewan and British Columbia maintain a list of “approved standards” outside their legislation.

Currently the OHS Code references about 196 standards in 367 locations across the OHS Code. Standards may be updated, replaced, or discontinued by their standard-setting organization, requiring updates to the OHS Code. To update an existing standard to a newer version requires an update to the OHS Code through the OHS Code review process.

The survey questions below propose amending the OHS Code to refer to “approved standards” in locations where standards are currently referenced and maintain a list of approved standards outside of the OHS Code along with processes for adopting and updating standards.

The survey wording will provide a summary of the proposed change with rationale but will not include proposed legal language. Final legal language will be drafted once consultation is complete.

Change A:
Currently, Alberta’s OHS Code references specific editions of 196 third-party technical standards in 367 locations in the OHS Code.

Standard setting organizations routinely update their standards, or the standards may be rescinded. As a result, standards referenced in the OHS Code become out of date between OHS Code reviews and no longer reflect best practices for health and safety.

To allow for more timely updates to referenced standards when appropriate, it is proposed to amend the OHS Code to refer to “approved standards” in locations where standards are currently referenced and maintain a list of approved standards outside of the OHS Code. This list would be established through a Director Order and published online.

Change B:
It is proposed to change the process for updating or adopting technical standards in the OHS Code.

• For existing standards, technical review will be conducted and the Director Order updated on an ongoing basis to reflect the most current version of the standard, unless changes to the standard are substantive. Stakeholders will be informed of changes through mechanisms such as eNews.
• For existing standards with substantive changes (for example, new requirements which could change work site procedures and work site party responsibilities), stakeholders will be engaged on changes through technical working groups or other consultation before the Director Order is updated.
• For adoption of new standards, the full OHS Code review process would be followed (review, engagement, consultation and government approval processes). Following this process, the Director Order will be updated accordingly.

The following section contains questions related to miscellaneous changes in the OHS Code, consisting of consequential changes that are the result of proposed changes to Parts 36 and 40, new requirements to improve health and safety and regulatory alignment with other jurisdictions in Canada, as well as correction of errors and editorial changes to improve clarity.

The survey wording will provide a summary of the proposed change with rationale but will not include proposed legal language. Final legal language will be drafted once consultation is complete.

Currently, section 533.1 in Part 36 requires when there is a requirement that specifications or procedures, or both, are certified by a professional engineer, an employer must ensure the specifications or procedures, or both, are implemented and followed.

To clarify existing requirements for all work sites that when procedures or specifications are certified by a professional engineer, they must be implemented and followed, it is proposed to move the requirement in section 533.1 to Part 3 of the OHS Code which will create a requirement that applies in all circumstances in the OHS Code where certification by a professional engineer is required. Section 533.1 would be repealed.

Currently, section 40 applies to “exposed workers.”

An “exposed worker” means a worker who may reasonably be expected to work in a restricted area at least 30 work days in a 12-month period.

A “restricted area” means an area of the work site where there is a reasonable chance that the airborne concentration of asbestos, silica, coal dust or lead exceeds or may exceed the occupational exposure limit for one or more of the substances.

An employer must ensure exposed workers receive a health assessment with prescribed elements. The employer must also set out the requirements for how health assessments are conducted and how the results are documented.

To clarify the responsibility of medical service providers who provide health, it is proposed to include a new requirement for medical services providers who provide health assessment to report a notifiable disease to the Director of Medical Services.

Currently, section 43 of the OHS Code requires an employer to ensure blood lead level testing is available to a worker if the worker at a work site could reasonably be expected to have elevated lead levels.

To clarify the responsibility of medical service providers who provide blood lead testing, it is proposed to include a new requirement for medical services providers who provide blood lead testing to report a notifiable disease to the Director of Medical Services.

Currently, section 81 requires a material hoist to meet the requirements of CSA Standard CAN/CSA Z256‑M87 (R2006), Safety Code for Material Hoists.

To clarify employer responsibilities, it is proposed to specify the employer is responsible for ensuring the hoist meets the requirements of the referenced standard.

Currently, section 88 requires a mobile crane to meet the requirements of CAN/CSA Z150‑98 (R2004), Safety Code on Mobile Cranes with the exception of clauses 1.6 and 1.7.

To clarify employer responsibilities, it is proposed to specify the employer is responsible for ensuring the mobile crane meets the requirements of the referenced standard.

Currently, section 93 requires a bridge, jib, monorail, gantry or overhead travelling crane to meet the design requirements for electrical components and functions of:

• CSA Standard C22.1‑06, Canadian Electrical Code, Part 1, Section 40; and
• CSA Standard C22.2 No. 33‑M1984 (R2004), Construction and Test of Electric Cranes and Hoists.

To clarify employer responsibilities, it is proposed to specify the employer is responsible for ensuring the crane meets the requirements of the referenced standard.

Currently, section 94 requires a bridge, jib, monorail, gantry or overhead travelling crane to meet the safety requirements of CSA Standard CAN/CSA B167‑96 (R2007), Safety Standard for Maintenance and Inspection of Overhead Cranes, Gantry Cranes, Monorails, Hoists and Trolleys.

To clarify employer responsibilities, it is proposed to specify the employer is responsible for ensuring the crane meets the requirements of the referenced standard.

Currently, section 96 requires a personnel hoist, except for a personnel hoist used in a mine, to meet the requirements of CSA Standard CAN/CSA Z185-M87 (R2006), Safety Code for Personnel Hoists.

To clarify employer responsibilities, it is proposed to specify the employer is responsible for ensuring the hoist meets the requirements of the referenced standard.

Currently, section 100 requires a tower crane manufactured on or after July 1, 2009 to meet the requirements of CSA Standard Z248‑04, Code for Tower Cranes.

To clarify employer responsibilities, it is proposed to specify the employer is responsible for ensuring the tower crane meets the requirements of the referenced standard.

Currently, section 191 provides the detailed requirements for signallers at work sites. In this section, employers must ensure that designated signallers wear high‑visibility safety apparel that identifies them as a designated signaller but does not prescribe a standard for the apparel.

To harmonize with other jurisdictions in Canada, it is proposed to introduce a new standard for high visibility apparel, CSA Standard Z96:22, High-visibility safety apparel.

Currently, section 194, requires employers to ensure workers designated to control traffic wear high‑visibility safety apparel that identifies them as a designated signaller but does not prescribe a standard for the apparel.

To harmonize with other jurisdictions in Canada, it is proposed to introduce a new standard for high visibility apparel, CSA Standard Z96:22, High-visibility safety apparel. To remove duplication with the standard, it is also proposed to remove the requirement for the apparel to be retroreflective if the worker is controlling traffic in the dark or visibility is poor.

Currently, section 223 of the OHS Code requires an employer to ensure audiometric testing is conducted for workers exposed to “excess noise.” The section sets out the circumstances when testing must be done, standards for the testing and the responsibilities of physicians, audiologists and audiometric technicians.

“Excess noise” is defined as noise that exceeds the limits specified in section 218.

To clarify the responsibility of medical service providers who provide audiometric testing, it is proposed to include a new requirement for medical services providers who provide audiometric testing to report a notifiable disease to the Director of Medical Services.

Currently, section 227 states that section 225 does not apply to utility workers working in accordance with the requirements of CAN/ULC-S801-14, Standard on Electric Utility Workplace Electrical Safety for Generation, Transmission, and Distribution.

To enhance alignment with current health and safety requirements, it is proposed to update the referenced technical standard to the most current version CAN/ULC-S801-25, Standard on Electric Utility Workplace Electrical Safety for Generation, Transmission, and Distribution. This same change will be made in section 800 in Part 40 Utility Workers – Electrical.

Currently, sections 460 in Part 32 and 542 in Part 36 require the employer to ensure that if powered mobile equipment may go over a bank or enter a dump opening while it is discharging its load, the equipment is effectively stopped or controlled by an anchored block, a ridge of material acting as a backstop, or a designated signaller with a stop signal.

To improve health and safety and remove duplication, it is proposed to create a new section in Part 19 for dumping blocks applicable to all powered mobile equipment when there is a danger of going over an edge when dumping a load. Duplicate requirements in section 460 in Part 32 Excavation and Tunnelling and section 542 in Part 36 Mining will be repealed.

Currently, section 390 requires the employer to develop and implement a violence and harassment prevention plan that includes provisions to protect the confidentiality of all parties involved in a complaint or incident, except where disclosure is necessary to investigate the complaint or incident, take corrective action, inform the parties involved or the results of the investigation, inform workers of a particular threat of violence or potential violence, or as required by law to inform workers of a specific or general threat of violence or potential violence.

To improve health and safety, it is proposed to add a new requirement to for employers to report threats of harassment or potential threats of harassment, in addition to threats or potential threats of violence, to affected workers after a complaint or incident has occurred at a work site.

Currently, section 391.1 specifies that incidents of violence and harassment are subject to incident investigation and reporting under section 33 (6), (7) and (8) of the OHS Act.

Section 33(6) and (7) of the OHS Act set out the requirements for a prime contractor and employer to investigate, prepare a report, provide the report to government, and retain the report if a reportable incident occurs as set out in section 33.

Section 33(8) of the OHS Act clarifies that reports prepared under this section are not admissible as evidence in a trial except in a prosecution for perjury or giving contradictory evidence.

Section 36 of the OHS Act outlines an OHS officer’s powers and work site parties’ responsibilities for investigations into incidents, injuries, or illnesses at a work site.

Change A:
To clarify prime contractor and employer responsibilities as to when violence and harassment incidents must be investigated, it is proposed to clarify that the provision to investigate applies apply where there is reason to believe that an incident of violence or harassment both has or may have occurred.

Change B:
To clarify prime contractor and employer responsibilities for reporting, it is proposed to add a new requirement for the prime contractor, or if there is no prime contractor, the employer, to provide a copy of the violence and harassment investigation report to a statutory director once the investigation is complete.

Currently, section 470.1 requires the employer to ensure that an explosive magazine meets the requirements of National Standard of Canada CAN/BNQ 2910-500/2015 (R 2022), Explosives - Magazines for Industrial Explosives.

To ensure the correct standard is referenced to reflect best practices for health and safety as the current standard for magazines has been withdrawn, it is proposed to adopt the 2026 NRCan standard Storage of Explosives, G06-08.

Currently, section 527 does not allow any person to recap waste needles. There is currently an acceptance issued that allows the recapping of dental needles and dental sharps as long as it is done in compliance with a standard of practice issued by College of Dental Surgeons of Alberta, Alberta College of Dental Hygienists, or College of Alberta Dental Assistants.

To reduce burden on employers, it is proposed to adopt a new requirement to allow recapping of waste needles if this is done compliance with a standard of practice issued by College of Dental Surgeons of Alberta, Alberta College of Dental Hygienists, or College of Alberta Dental Assistants.

The following questions are regarding proposed changes to definitions in the OHS Code

Advanced First Aider
Currently, the definition of “advanced first aider” means an emergency medical responder, primary care paramedic or a person who holds a certificate in advanced first aid from an approved training agency.

To reduce burden and improve labour mobility, it is proposed to change the definition of “advanced first aider” to recognize a valid certificate in advanced first aid from a training agency taken in another Canadian jurisdiction. There is currently an allowance that allows for recognition of out of province training. The definition is proposed to be changed to:
“advanced first aider” means
a) a person who holds a certificate in advanced first aid from an approved training agency; or
b) a person who holds a valid certificate in advanced first aid recognized by another Canadian jurisdiction where the issuance of that certificate requires the person to have successfully completed an advanced first aid course that complies with the requirements in CSA Standard Z1210-17, First aid training for the workplace - Curriculum and quality management for training agencies or CSA Standard Z1210:24, First aid training for the workplace - Curriculum and quality management for training agencies.

Asbestos Waste
Currently, the definition of “asbestos waste” means a material that is discarded because there is a reasonable chance that asbestos might be released from it and become airborne, including protective clothing that is contaminated with asbestos”

To improve health and safety and clarity, it is proposed to revise the definition to:
“asbestos waste” means material that is:
a) removed or abated that contains or may contain asbestos, or
b) is contaminated or may be contaminated with asbestos.

Basic First Aider
Currently, the definition of “basic first aider” means a person who holds a certificate in basic first aid from an approved training agency.

To reduce burden and improve labour mobility, it is proposed to change the definition of “basic first aider” to recognize a valid certificate in basic first aid from a training agency taken in another Canadian jurisdiction. There is currently an allowance that allows for recognition of out of province training. The definition is proposed to be changed to:
“basic first aider” means
a) a person who holds a certificate in basic first aid from an approved training agency; or
b) a person who holds a valid certificate in basic first aid recognized by another Canadian jurisdiction where the issuance of that certificate requires the person to have successfully completed a basic first aid course that complies with the requirements in CSA Standard Z1210-17, First aid training for the workplace - Curriculum and quality management for training agencies or CSA Standard Z1210:24, First aid training for the workplace - Curriculum and quality management for training agencies.

Hazardous Location
Currently, the definition of “hazardous location,” in Part 10, means a place where fire or explosion hazards may exist due to flammable gases or vapours, flammable or combustible liquids, combustible dust or ignitable fibres or flyings, as described in the Canadian Electrical Code.”

To correct an error as this term is used in Part 36 as well as Part 10, it is proposed to change the definition of “hazardous location” to:
“a place where fire or explosion hazards may exist due to flammable gases or vapours, flammable or combustible liquids, combustible dust or ignitable fibres or flyings, as described in the Canadian Electrical Code”.

High Visibility Safety Apparel
Currently, the definition of “high visibility safety apparel” means personal protective equipment that is occupational apparel capable of signalling the user’s presence visually and intended to provide the user with conspicuity in hazardous situations under any light conditions and under illumination by vehicle headlights.

To harmonize with other jurisdictions in Canada and align with the proposed standard for high visibility apparel, it is proposed to change the definition of “high visibility safety apparel” to mean “personal protective equipment that is safety clothing intended to provide conspicuity during daytime, nighttime and other low-light condition usage”.

Intermediate First Aider
Currently, the definition of “intermediate first aider” means a person who holds a certificate in intermediate first aid from an approved training agency.

To reduce burden and improve labour mobility, it is proposed to change the definition of “intermediate first aider” to recognize a valid certificate in intermediate first aid from a training agency taken in another Canadian jurisdiction. There is currently an allowance that allows for recognition of out of province training. The definition of “intermediate first aider” is proposed to be changed to mean:
a) a person who holds a certificate in intermediate first aid from an approved training agency; or
b) a person who holds a valid certificate in intermediate first aid recognized by another Canadian jurisdiction where the issuance of that certificate requires the person to have successfully completed an intermediate first aid course that complies with the requirements in CSA Standard Z1210-17, First aid training for the workplace - Curriculum and quality management for training agencies or CSA Standard Z1210:24, First aid training for the workplace - Curriculum and quality management for training agencies.