Worker awareness training and AODA training only have to happen "as soon as practicable." Supervisor awareness training is different. It has a hard deadline of one week, and it starts the moment someone begins performing work as a supervisor — not the moment you get around to the paperwork.
The one-week clock
Section 2 of O. Reg. 297/13 requires every employer to ensure a supervisor completes a basic occupational health and safety awareness program within one week of performing work as a supervisor. There is no grace period for small employers and no exemption for someone who is "only supervising part-time."
The exception: if the supervisor already completed a supervisor awareness program, gives you proof, and you verify it covered what the regulation requires, you don't have to train them again (s. 2(2)). Keep the proof and your verification on file.
An example
You promote a warehouse associate to shift lead, and they start assigning work to the rest of the shift on Monday, October 5, 2026. Their supervisor awareness training is due by Monday, October 12. A completion dated October 20 shows a gap of eight days, even though they did the training.
"Supervisor" is a function, not a job title
This is where small employers most often get caught. The Occupational Health and Safety Act defines a supervisor as a person who has charge of a workplace or authority over a worker. Nothing in that definition mentions a title, a pay grade, or a formal promotion.
In practice that can include:
- a lead hand or shift lead who directs other workers,
- a working owner who assigns tasks to their own staff,
- a site or store manager, and
- anyone left "in charge" while the usual manager is away, even temporarily.
If a person directs how and when others work, treat them as a supervisor and start the clock.
What else changes the week you add a supervisor
- They still need the worker program too. Supervisor awareness training does not replace the worker awareness requirement — a supervisor who never completed the worker program still needs one that covers it.
- They take on personal duties. Section 27 of the OHSA places specific duties on supervisors, including ensuring workers work in the manner and with the protective devices, measures and procedures the law requires, and taking every precaution reasonable in the circumstances to protect them.
- Headcount thresholds may follow. Regularly employing more than five workers, and again reaching twenty, changes your health and safety representative and joint health and safety committee obligations under sections 8 and 9 of the OHSA.
What you have to be able to show
Training that happened but was never recorded is, from an inspector's point of view, training that cannot be proven. O. Reg. 297/13 requires the employer to keep a record of the awareness training, and to provide written proof of completion to a worker on request for up to six months after they leave your employment.
For a supervisor, the date on that record matters more than usual: it is trivially comparable against the date they started supervising. A completion dated three months after a promotion is a visible gap.
Your first-week checklist
- Write down the date the person started performing supervisory work. This is the date the clock runs from.
- Assign the supervisor awareness program with a due date inside seven days.
- Confirm they have also completed the worker awareness program, or assign it.
- Walk them through your workplace violence and harassment policies and your reporting process.
- File the completion record: the person, the program, the date they completed it and a copy of their Proof of Completion certificate, somewhere you can find it without searching email.
How Ethica handles it
Ethica's Ontario health and safety awareness course assigns the Ministry of Labour's official supervisor e-learning module with a seven-day due date already set, counted from the day you assign it, so assign it the day they start supervising. Assign it to the person, and they get an email link — no account, no password. They upload the Ministry's Proof of Completion certificate when they finish, the completion is recorded against them with a timestamp, reminders chase them before the deadline, and the record exports to CSV, with each person's certificate, whenever you need to produce it.