What Is Worker Health and Safety Awareness in 4 Steps?

Under Ontario's Occupational Health and Safety Act (OHSA), employers must ensure that covered workers and supervisors complete basic occupational health and safety awareness training, unless an exemption applies. O. Reg. 297/13 sets separate minimum requirements for workers and for supervisors, and employers may choose any training program that meets them. This guide explains what the ministry's Worker Health and Safety Awareness in 4 Steps program is, what its four steps cover, the legal requirements and training deadlines, who needs the training, whether you must use the ministry's own materials, how the training is delivered, and how long the certificate is valid. 1,3

What is Worker Health and Safety Awareness in 4 Steps?

Worker Health and Safety Awareness in 4 Steps is the basic occupational health and safety awareness training program for workers published by Ontario's Ministry of Labour, Immigration, Training and Skills Development (MLITSD). It is often called "the 4 Steps", the "MOL 4 Steps" (for Ministry of Labour) or "4 Steps to Safety". It exists because Ontario law, O. Reg. 297/13 under the Occupational Health and Safety Act, requires every covered worker to complete basic OHS awareness training unless an exemption applies. The ministry's program presents that training in four steps. The steps are built around a worker's three fundamental rights: the right to know, the right to participate, and the right to refuse unsafe work under the conditions set out in the law. Supervisors have separate, additional training requirements, which the ministry covers in its Supervisor Health and Safety Awareness in 5 Steps program. Employers may also use another training program, as long as it covers all of the regulation's applicable requirements. 1,2,12

Awareness training does not replace instruction on the hazards, equipment and procedures of a particular job. 3

What are the four steps?

The ministry's program takes its name from its four learning steps:

• Step 1: Get on board. Where you fit in workplace health and safety: your role, your supervisor's and employer's roles, and the internal responsibility system that connects them.
• Step 2: Get in the know (the right to know). Workplace hazards, WHMIS and occupational disease, and how to find out how to work safely.
• Step 3: Get involved (the right to participate). The ways workers take part in health and safety, from raising concerns to joint health and safety committees.
• Step 4: Get more help (the right to refuse unsafe work and where to go for help). When and how you can refuse unsafe work, the protection from reprisals for exercising your rights, and where to turn for help.

Together, the steps explain how workers can recognize a concern, raise it and obtain help. 2

What does Ontario law require? (O. Reg. 297/13)

Ontario Regulation 297/13, Occupational Health and Safety Awareness and Training, makes basic OHS awareness training mandatory across every workplace the Occupational Health and Safety Act covers, regardless of sector, subject to the regulation’s exemptions. The duties are specific: 1

• Workers must complete a basic awareness program "as soon as practicable" after starting work (s. 1(1)).
• Supervisors must complete a supervisor awareness program "within one week of performing work as a supervisor" (s. 2(1)). The content of supervisor training is set out separately in s. 2(3).
• Previously completed training may be recognized by a new employer. Workers and supervisors who have already completed a compliant awareness program may not need to repeat it, provided they supply proof of completion and their employer verifies that the previous training meets the applicable requirements (ss. 1(2) and 2(2)). This exemption does not replace any additional workplace-specific or hazard-specific training required under occupational health and safety legislation.
• Employers must maintain training records for workers and supervisors who complete the training, as well as the exemption records required by section 4. On request, employers must provide written proof of completion, or of an exemption where the regulation requires it. This also applies when a former worker or supervisor makes the request within six months of ceasing to work for that employer. Records may be kept on paper or electronically. They must be available for an inspector to review and for proof to be provided on request.

The worker 4 Steps program alone does not fulfil the supervisor content requirements, which include recognizing, assessing and controlling hazards and evaluating those controls. Supervisors generally need training covering both sets of content; limited exemptions for qualifying supervisor training completed before July 1, 2014 are explained in the ministry’s guide. 1,5,11

Is the 4 Steps program required outside Ontario?

Ontario's 4 Steps program is specific to that province. However, employers across Canada are subject to occupational health and safety training obligations under the legislation of their own jurisdiction. 7,13

For federally regulated workplaces covered by Part II of the Canada Labour Code, section 125(1)(q) requires employers to provide the information, instruction, training and supervision needed to protect employees at work. Where the Canada Occupational Health and Safety Regulations apply, section 19.6 requires employers to review and, if necessary, revise their employee training program at least every three years, when conditions change with respect to hazards, or when new hazard information becomes available. This is a review of the training program; it does not mean every employee must retake the training every three years. 8,9,10

Each province and territory sets its own training duties in its OHS law, and the rights the 4 Steps program teaches, to know, to participate and to refuse unsafe work, exist in every Canadian jurisdiction, though their details and procedures vary. Employers outside Ontario should check the training requirements of their own jurisdiction rather than assume that Ontario's 4 Steps program alone meets all of their obligations. 7,13

Do you have to use the ministry's own program?

No. Employers may use the ministry's free awareness training materials, provided as workbooks or through an eLearning option, or another training program that covers all applicable requirements under O. Reg. 297/13. In either case, employers remain responsible for verifying that the training content meets the regulation's requirements. Using the ministry's materials also does not remove the employer's other responsibilities: maintaining training records for every worker and supervisor, and providing written proof of completion on request. 1,3,11

Check the ministry’s program page for the current availability of its eLearning modules. 2

Who is responsible for ensuring the 4 Steps program is completed?

The employer is responsible for ensuring that awareness training is completed and for being able to prove it, along with the record-keeping duties that come with it. Workers and supervisors must complete the applicable training within the prescribed timeframes, and it is worth keeping your proof of completion, since a new employer may be able to accept it. 1,4

For context on the committee-based safety roles the training explains: in Ontario, a joint health and safety committee (JHSC) is generally required at workplaces where 20 or more workers are regularly employed. Additional requirements and exceptions apply, including those related to construction projects, designated substances and certain ministry orders. 6

Who must complete the 4 Steps program in Ontario?

In Ontario, workers covered by the Occupational Health and Safety Act must complete basic health and safety awareness training unless a regulatory exemption applies. This includes full-time and part-time workers, whether they are new or have been in the job for years. 1,3,4

Supervisors must also meet the worker awareness training requirements and complete supervisor-specific awareness training under O. Reg. 297/13, unless an exemption applies. Ontario provides a separate Supervisor Health and Safety Awareness in 5 Steps program for this purpose. Previously completed training may qualify for an exemption if the worker or supervisor provides proof and the employer verifies that it meets the relevant requirements. 1,5,12

A job title alone does not settle the question: someone who supervises temporarily can still fall under the supervisor requirement. Self-employed people are not subject to the basic-awareness requirement in O. Reg. 297/13, according to the ministry’s guide. 3,5

Does O. Reg. 297/13 allow the 4 Steps program to be taken online?

Yes, fully online. The regulation sets the content an awareness program must cover, not the delivery format. Our Workplace 4 Steps Awareness course runs four modules matching the four steps, with one test, and takes about 1 hour 15 minutes in total. Employers can track course completion through the eSafetyFirst platform. 1,3

Completing the awareness course does not replace the workplace-specific instruction an employer must provide before a worker faces particular hazards. 4

What must a worker awareness program cover under O. Reg. 297/13?

O. Reg. 297/13 s. 1(3) spells out exactly what a compliant worker awareness program must cover:

• The duties and rights of workers under the Act
• The duties of employers and supervisors under the Act
• The roles of health and safety representatives and joint health and safety committees
• The roles of the Ministry, the Workplace Safety and Insurance Board and designated entities
• Common workplace hazards
• Basic awareness of the Workplace Hazardous Materials Information System (WHMIS), including the applicable information and instruction requirements. This general awareness does not replace the workplace-specific WHMIS education and training required for workers who work with or may be exposed to hazardous products.
• Occupational illness, including latency — the delay that can occur between exposure and illness.

These seven areas are the minimum worker awareness content required by the regulation. 1,4

Does the law require the 4 Steps program to be repeated?

Ontario's O. Reg. 297/13 does not set a fixed expiry date or require annual renewal of basic occupational health and safety awareness training. Proof of completion remains usable when you change employers, provided the new employer verifies that the training meets the requirements. 1,4

The ministry’s guide also explains that an employer may choose to have someone repeat awareness training. 4

Our Workplace 4 Steps Awareness certificate expires one year after completion. This is the term of our program’s certificate, not a legislated expiry date.

Employers remain responsible for providing any additional training required when workplace hazards, job duties or legal requirements change. 4

Key takeaways

The 4 Steps program presents the basic awareness training Ontario requires in four learning steps covering workers' rights and responsibilities. O. Reg. 297/13 makes awareness training mandatory for every covered worker and supervisor unless an exemption applies, with separate requirements for each group and the employer holding the records. Whether you use the ministry's materials or an alternative program that meets the applicable regulatory requirements, the goal is the same: every worker starts the job knowing their rights.