Every worker on an HCMI construction site is required to complete basic health and safety awareness training before beginning work. This is not optional — it is a legal requirement under Ontario law. This guide covers everything you need to know about your rights, your responsibilities, and how to stay safe on the job.
In This Guide
1. Legal Basis & Who Needs This Training
Under the Occupational Health and Safety Act (OHSA), section 25.2(2), every employer in Ontario must ensure that workers complete a basic occupational health and safety awareness training program. The specific content requirements are set out in Ontario Regulation 297/13, which came into force on July 1, 2014.
This training is mandatory for:
- All new HCMI employees, including full-time, part-time, and seasonal workers
- All subcontractor workers on HCMI project sites (subcontractors must provide proof of training)
- Co-op students and apprentices
- Temporary agency workers assigned to an HCMI site
Regulatory Note: O. Reg. 297/13, s.1 specifies that worker awareness training must be completed as soon as practicable, and the employer must keep records of the training. Workers cannot begin work on an HCMI site without documented proof of completion.
2. Your Three Fundamental Worker Rights
The OHSA grants every worker in Ontario three fundamental rights. These rights cannot be taken away, reduced, or penalized by any employer.
The Right to Know
You have the right to know about hazards in your workplace. This includes the right to receive information and instruction about hazardous materials, equipment, and processes. On a construction site, this means you must be informed about fall hazards, chemical exposures, electrical dangers, heavy equipment operation zones, and any other condition that could affect your health or safety.
Your employer must provide safety data sheets (SDS) for all hazardous products, proper labels on all containers, training on equipment before you use it, and information about workplace hazards specific to each project site.
The Right to Participate
You have the right to participate in the health and safety process at your workplace. This includes the right to be a member of or have representation on the Joint Health and Safety Committee (JHSC), to identify and report hazards, to provide input on health and safety policies and procedures, and to accompany a Ministry of Labour, Immigration, Training and Skills Development (MLITSD) inspector during a workplace inspection.
The Right to Refuse Unsafe Work
Under OHSA section 43, you have the right to refuse work that you believe is likely to endanger yourself or another worker. This is one of the most important protections in Ontario law. You cannot be disciplined, terminated, or penalized in any way for exercising this right in good faith.
The work refusal process under OHSA follows these steps:
- Report the unsafe condition to your supervisor immediately
- The supervisor must investigate the concern in the presence of the worker and a JHSC worker member or health and safety representative
- If the issue is resolved to your satisfaction, you return to work
- If you have reasonable grounds to believe the work is still unsafe, you may continue the refusal
- The MLITSD is called in to investigate and issue a decision
- During investigation, you remain in a safe place near your workstation and may be assigned reasonable alternative work
Important: OHSA section 50 prohibits any reprisal against a worker for exercising their rights under the Act. If you believe you have been penalized for a work refusal, you may file a complaint with the Ontario Labour Relations Board within 30 days.
3. Employer and Constructor Duties
Under OHSA section 25, employers have a general duty to take every precaution reasonable in the circumstances for the protection of a worker. Specific duties include:
- Providing information, instruction, and supervision to protect worker health and safety
- Acquainting workers with any hazard in the workplace
- Providing and maintaining protective equipment, devices, and clothing
- Ensuring compliance with the OHSA, its regulations, and any applicable orders
- Posting the OHSA in the workplace (or providing copies to workers)
- Preparing and reviewing at least annually a written health and safety policy and implementing a program to carry it out
On construction projects, the constructor (typically HCMI on our projects) has additional duties under OHSA section 23, including ensuring that all employers and workers on the project comply with the Act and regulations, ensuring that the health and safety of all workers on the project is protected, and appointing a supervisor for every project.
4. Three Types of Workplace Hazards
O. Reg. 297/13 requires that worker awareness training cover the occupational health and safety hazards workers may encounter. On HCMI construction sites, hazards fall into three broad categories:
Health Hazards
Health hazards are conditions or substances that can cause illness, disease, or deterioration of health over time. On construction sites, common health hazards include:
- Chemical hazards: dust (silica, concrete, wood), solvents, adhesives, paints, fuels, welding fumes
- Biological hazards: mould during renovation work, bird or rodent droppings in older structures, contaminated soil
- Physical hazards: noise (power tools, heavy equipment), vibration (jackhammers, compactors), UV exposure
- Ergonomic hazards: repetitive motions, awkward postures, heavy lifting
Safety Hazards
Safety hazards are conditions that can cause immediate injury or death. On construction sites, these include:
- Falls: from scaffolds, ladders, roofs, open holes, and elevated work platforms
- Struck-by hazards: falling objects, swinging loads, moving vehicles and equipment
- Electrical hazards: contact with overhead power lines, exposed wiring, faulty tools
- Caught-in/between hazards: trench collapse, unguarded machinery, pinch points
- Fire and explosion: from fuels, propane, welding near combustibles
Psychosocial Hazards
Psychosocial hazards affect mental health and well-being. These include workplace harassment, bullying, violence, excessive workload pressure, and lack of support. Under OHSA section 32.0.1, every employer must have a workplace harassment and violence policy and program.
5. The Internal Responsibility System (IRS)
The Internal Responsibility System is the foundation of occupational health and safety in Ontario. It means that everyone in the workplace — from the newest labourer to the company president — shares responsibility for health and safety.
Under the IRS:
- Workers are responsible for following safe work procedures, using required protective equipment, reporting hazards, and not operating equipment they are not trained or authorized to use
- Supervisors are responsible for ensuring workers comply with the Act and regulations, advising workers of hazards, and taking every precaution reasonable for worker protection
- Employers are responsible for providing a safe workplace, proper training, and equipment, and for maintaining the health and safety program
- The Joint Health and Safety Committee serves as the forum where workers and management collaborate on health and safety issues
The IRS works because it recognizes that the people closest to the work are often the first to identify hazards. When everyone takes ownership, issues are identified and resolved quickly — before someone gets hurt.
6. Reporting Hazards and Incidents
If you identify a hazard or are involved in or witness a workplace incident, you must report it immediately. Here is the HCMI reporting procedure:
- Immediate hazard: Remove yourself and others from danger. Report to your supervisor immediately. If the hazard is imminent and the supervisor is unavailable, contact the site superintendent or HCMI head office at 519-509-6363.
- Near miss: Report to your supervisor as soon as practicable. Complete an HCMI Near-Miss Report form (available in the site trailer).
- Injury or illness: Seek first aid immediately. Report to your supervisor. The supervisor must complete a Workplace Incident Report within 24 hours. If the injury requires medical attention, the worker must also complete a WSIB Form 6.
- Critical injury or fatality: Call 911 immediately. Do not disturb the scene. The supervisor must notify HCMI management and the MLITSD immediately (as required under OHSA s.51).
Regulatory Note: Under OHSA section 51, a critical injury (as defined in O. Reg. 834) must be reported to the MLITSD immediately by telephone. A written report must follow within 48 hours. Failure to report is an offence under the Act.
7. HCMI-Specific Policies
In addition to the legal requirements described above, HCMI maintains the following company-specific health and safety policies:
- Mandatory orientation: Every worker new to an HCMI project must complete a site-specific orientation before starting work, regardless of previous experience or training
- PPE requirements: Hard hat, CSA-approved safety boots, high-visibility vest, and safety glasses are mandatory at all times on HCMI construction sites. Additional PPE (hearing protection, respirators, fall protection, gloves) as required by the task
- Fit for duty: HCMI maintains a zero-tolerance policy for impairment on site. Workers must not be under the influence of alcohol, cannabis, or any substance that impairs their ability to work safely
- Tool and equipment inspection: Workers must inspect tools and equipment before each use and tag out any defective items immediately
- Emergency procedures: Workers must be familiar with the site-specific emergency plan, including muster points, first aid station locations, and emergency contact numbers posted in the site trailer
- Housekeeping: All workers are responsible for maintaining a clean and organized work area. Materials must be properly stored, debris cleared, and access routes kept free of obstructions
8. Worker Awareness Checklist
Before beginning work on any HCMI project site, confirm the following:
- I have completed worker health and safety awareness training (this training) and my record is on file
- I understand my three rights: the right to know, the right to participate, and the right to refuse unsafe work
- I know who my supervisor is and how to contact them
- I have completed the site-specific orientation for this project
- I know the location of the first aid station, emergency muster point, and posted emergency procedures
- I have the required PPE and it is in good condition
- I know how to report a hazard, near miss, or injury
- I have reviewed the safety data sheets for any hazardous materials I will be working with
- I understand that I must never operate equipment I am not trained and authorized to use
- I know who the JHSC worker representative or health and safety representative is for this site
HCMI Policy: Completion of this training must be documented and the record retained by HCMI for the duration of your employment plus one year. If you have questions about any content in this guide, speak with your supervisor or contact the HCMI Safety Department at office@churchbuilder.ca.