A worker without valid working at heights training is not allowed to put on a harness and clip in. Not because someone decided that would be a good idea. Because Ontario made it the law.
Who Actually Needs This Training
If you work on a construction project in Ontario and your job requires you to use a travel restraint system, a fall restricting system, a fall arrest system, a safety net, a work belt, or a safety belt, you need an approved working at heights training program before you use any of it. That requirement comes from O. Reg. 213/91, the Construction Projects regulation, and it applies before the equipment goes on, not sometime after.
This is separate from, and in addition to, the equipment-specific training required under section 26.2 of O. Reg. 213/91. Working at heights training covers the general skills and knowledge for using fall protection safely. Section 26.2 training covers the specific gear your crew actually uses on your site. Employers need both, not one or the other.
What "Approved" Actually Means
Not every fall protection course counts. The training program itself has to be approved by the Ministry of Labour's Chief Prevention Officer, and it has to be delivered by a training provider who has also been approved by the Chief Prevention Officer.
Here's where a lot of companies get burned: the Ministry has repeatedly flagged fraudulent training providers who take a fee and hand over a card without ever delivering valid training. Basically, what this means is simple: checking that a course exists is not enough. Confirm the specific provider was approved by the Chief Prevention Officer at the time the worker actually took the course, not just that they show up on some list today.
The Three-Year Clock
Working at heights training is valid for three years from the date of successful completion. After that, the worker needs a refresher program, delivered by an approved provider, to keep it valid for another three years. To be eligible for the refresher, a worker has to have completed both modules of an approved program the first time, not a partial course.
If a worker's training has lapsed and they have not taken the refresher, they are not covered to use fall protection on your site. That is not a paperwork technicality. It is the same gap that shows up in fall protection court cases: a worker relying on equipment they were never properly, currently trained to use.
What Employers Are Responsible For
Working at heights training is not a box a worker checks off once and forgets. It is an ongoing employer responsibility.
You are responsible for confirming that every worker using fall protection has valid, current training from an approved provider, and for confirming they are separately trained on the specific fall protection equipment they use on your site. You also have to keep records for every worker, either their proof of completion document or a record showing their name, the approved provider's name, the training program name, and the completion date. A Ministry inspector can ask for that record at any time, and you have to be able to produce it.
Three Things to Check on Your Site This Week
- Pull your training records and check the dates, not just the names. A three-year-old card that has quietly expired is functionally the same as no training at all.
- Confirm the provider on every record was actually approved by the Chief Prevention Officer at the time of training. A card from a provider that has since lost approval, or was never approved, does not protect your worker or your company.
- Do not confuse working at heights training with equipment-specific training. A worker with a valid working at heights card who has never been shown the specific harness and anchor system on your site is still not properly trained to use it.
Before your next crew goes up, check the actual expiry date on every fall protection card on your site, not just whether one exists. That five-minute check is the difference between compliant and one incident away from a very expensive court bulletin.