An Ontario health and safety inspector does not need an appointment, and does not need a warrant. Section 54 of the Occupational Health and Safety Act lets an inspector enter a workplace, inspect it, and require you to produce documents and records, including materials on the content, frequency and manner of any training program (s. 54(1)(c) and (p)).
Which means the practical question is never "do we do training?" It is "can we put the record on the table today?"
What tends to get asked for
Every visit is different, and what an inspector focuses on depends on why they came — a complaint, a critical injury, a proactive blitz in your sector. But many requests trace back to a small number of duties that apply to nearly every provincially regulated employer:
Awareness training records
Proof that every worker completed a basic occupational health and safety awareness program, and every supervisor completed the supervisor program within one week.
O. Reg. 297/13, ss. 1, 2 and 4
Workplace violence and harassment policies
The written policies themselves, reviewed at least annually, and posted in the workplace or electronically where six or more workers are regularly employed.
OHSA s. 32.0.1
Programs behind those policies
The violence risk assessment and the harassment complaint and investigation procedures, not just the policy statements.
OHSA ss. 32.0.2, 32.0.3, 32.0.6
Evidence workers were informed
That every worker received information and instruction on the policies and programs — including people hired after the policy was written.
OHSA ss. 32.0.5, 32.0.8
Health and safety representative or JHSC
Who they are and how they were selected, once you regularly employ more than five workers, and a committee once you regularly employ twenty or more.
OHSA ss. 8, 9
Hazard-specific training
WHMIS instruction for every worker who works with or may be exposed to a hazardous product, plus anything your sector requires — working at heights on a construction project, for example.
Reg. 860 (WHMIS); O. Reg. 213/91, s. 26.2; O. Reg. 297/13, s. 7
Where employers actually get caught
The failure is rarely that training never happened. It is that the record cannot be produced in a usable form:
- The record is a spreadsheet nobody has updated since the last hire. Every person added after the last update is an unexplained gap.
- The proof lives in a mailbox. "Bob emailed me that he finished it" is not a record you want to be searching for while an inspector waits.
- Nobody can say which version of the policy people saw. If the policy was revised, an acknowledgment that does not identify the version does not prove much.
- Departed workers are unaccounted for. You still owe a former worker written proof of their awareness training on request for up to six months after they leave.
What to do when an inspector arrives
- Take notes. Record who attended, what was asked for, and any deadline the inspector set for producing documents.
- Produce what you have, accurately. Do not guess at dates or reconstruct records after the fact. A gap you acknowledge is a much better position than a record that turns out to be wrong.
- Involve your health and safety representative or committee where they have a right to be involved.
- Close the gaps you find, and date them honestly. Assigning missing training the same week is a credible corrective step; backdating it is not.
- Follow up on orders in writing and keep the compliance evidence with your training records.
Getting to a one-minute answer
The test worth applying before an inspector ever shows up: can someone in your office, today, produce a list of who has completed each mandatory program, and when — including the people who joined last month?
That is precisely what Ethica keeps. Training goes out as an email link with no employee logins, completions are recorded against the person with a timestamp and the policy version they acknowledged, training set to go to everyone is assigned to new hires automatically so nobody is missed, and the whole record exports to CSV, or to a zip of certificates and signed acknowledgments, on demand.
Each mandatory program has its own page: health and safety awareness training, workplace violence and harassment policies and AODA accessibility training. For what to pull together beforehand, see how to prepare for a compliance training audit.