Does Generic WHMIS Meet OHS Requirements?
When prequalifying Contracting Employers and Employers there is often a glaring deficiency in training that many are not aware of. That is the requirement for WHMIS training which is legislated as a responsibility in the Alberta OHS Act and the Code.
With the advent of the online training in the construction industry many associations or external safety companies are providing “Generic” WHMIS courses. While these programs do provide a general entry level overview of the WHMIS training required, they do not provide adequate training that addresses the differences of controlled products used by employers. What most employers think is that their “Generic” training program they have received, meets the legislated responsibilities of the company. The shortcomings of generic WHMIS training courses provided by commercial providers was highlighted in a recent OHS Bulletin dated July 2022, Government of Alberta, High-pressure WHMIS training sales tactics. In the Bulletin they specifically state that WHMIS training must include site-specific information about WHMIS products and the health and safety procedures used at the work site.
What the companies need to know is that they must review Safety Data Sheets (SDS) specific to their operations and ensure that all employees are aware of the information related to the various products that are used in the workplace. One of the lapses that is significant in the “Generic” WHMIS training is the review of the different sections of the SDS to ensure that the workers are competent to assess what the hazards are of the controlled products and how best to protect themselves from these hazards.
In the Alberta OHS Code Part 29 WHMIS: Training - Section 397 there are specific requirements related to what the employer must provide for training. While several of the items are addressed in the “Generic” programs that I have reviewed, there are many areas that require further training with your workers to ensure they have all the information required to work safely with the controlled products in the workplace.
What does this mean to the average employer? If you are relying on WHMIS training that is “Generic” you may be leaving your workers inadequately trained to properly protect themselves from the hazards associated with their work activities for your company. Therefore you are not meeting your obligations under the legislation and ensuring that your workers are “competent”. This leaves you in a liability position if something were to occur because of the lack of training received by your workers, not to mention the moral and ethical responsibilities as an employer.
How do you protect your workers? As an employer you should complete an internal training program that deals specifically with the controlled products that you are using. This training would involve the review and explanation of the various sections of all the Safety Data Sheets of the controlled products used in the workplace. Completing a review of all the sections of the Safety Data Sheets would ensure that your employees are aware of the necessary methods for the handling and use of the controlled products.
To assist you in determining what you need to provide the Government of Alberta has developed an online resource for you. This document is available online and is free to download for your review. This resource can be found at the link below:
OHS Resource Portal. WHMIS 2015: Information for Employers (alberta.ca)
If you wish to have a WHMIS training program that you can deliver to your workers, contact us at frank@numberssafety.com for more information on the various options we have for your training needs. This program will be developed and tailored to your specific operations and hazards associated with your company’s work activities.
