Most Ontario training duties are measured in "as soon as practicable." Supervisor awareness training is not. 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 one exception: a supervisor who can verify they already completed an equivalent awareness program is exempt. Keep that verification on file — an unverifiable claim is not a record.
"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, if that authority is real and ongoing.
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 equipment required.
- Headcount thresholds may follow. Growing past five workers, and again past 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 — dated, per person, retrievable without a search through email.
How Ethica handles it
Ethica's Ontario health and safety awareness course ships the Ministry of Labour's official supervisor workbook with a seven-day due date already set, because the regulation sets it. Assign it to the person, and they get an email link — no account, no password. The completion is recorded against them with a timestamp, reminders chase them before the deadline, and the record exports to CSV or a per-person certificate whenever you need to produce it.