The Canadian Occupational Health and Safety Regulations (COHSR) have been amended effective 10 July, 2019.  The key changes that have been made are to part XII of the labor code, which prescribes the planning and implementation of fall protection systems and equipment, personal safety equipment, personal safety devices, and clothing.

These amendments also bring the technical requirements in line with the latest standards that have been set by standard development agencies such as the Canadian Standards Association (CSA) and UL Standards Canada, in addition to making the federal regulations more consistent with those set by other Canadian jurisdictions.  The complete details of the regulation changes can be found in their entirety in Volume 153 of the Canada Gazette, 10 July, 2019

Large construction site

What are the main changes to the COHSR?

The most significant changes can be found below.  We will discuss each in further detail throughout this article:

  • Fall protection plan
  • New minimum height requirements for fall protection equipment
  • A reduction in the size of fall hazard zones
  • Reference to the all of the latest CSA standards related to fall protection equipment
  • Other amendments

Fall Protection Plan:

Possibly some of the most impactful changes and additions to section XII of the Canadian labour code are those made in regards to the creation of a fall protection plan.  The regulation states that for any work that requires fall protection equipment under the COHSR, a fall protection plan must also be created and implemented in consultation with a workplace safety committee or health and safety official.

The complete details on the new requirements can be found in section 12.06 of the Canadian Labour Code, but the main point of the new code states that:

Fall protection plan
  • A fall protection plan must be developed with a workplace safety official/committee, or by the health and safety department of an organization
  • Everyone who works at heights must be trained on the fall protection plan
  • The fall protection plan must be kept readily available at the workplace for consultation
  • The fall protection plan must be reviewed and updated to accommodate changes to the workplace

The creation of the plan will certainly result in some additional costs to employers in the short term.  However, a study done by the labour department has provided sufficient evidence to show that when employers create a fall protection plan, and employees are educated on that plan, a notable drop in workplace injury and death can be expected.   This is in addition to the reduction in financial cost to Canadian businesses.

In the fall protection plan, each worker must be educated about all of the hazards associated with the work site, as well as how to reduce those hazards.  They must also be trained on how each piece of fall protection equipment is used, and have a rescue plan on hand.

    New minimum height requirements for fall protection equipment:

    Possibly the most unexpected change to section XII of the Canadian labor code is an increase in the minimum height in which it`s required for worker wear fall protection equipment.  A change from 2.4 to 3 meters was designed to more closely align with those requirements set out by other Canadian jurisdictions, such as the provinces.  While there may be a minor change to the total number of falls in a given year, the other changes are expected to offset that potential risk.

    A reduction in the size fall hazard zones:

    A fall hazard zone is a work area near an unguarded edge, where workers become obligated to use personal fall protection equipment as a result of the risk to that edge.  The reason for the zone is that sometimes workers may need to work relatively near to a fall hazard, but not so close as to present a clear risk of falling.

    Fall hazard zone

    The fall hazard zone therefore creates a buffer where one can safely work without protection equipment, and the latest changes to the Canadian OSH regulations have reduced the zone from 3 meters down to 2 meters.  This should have a positive impact on the burden that employers had in creating a fall hazard zone where very little space is available, or where the fall hazard zone is seldom occupied.

    Reference to the latest CSA standards for all components of fall protection system:

    The previous version of the Canadian Occupational Health and Safety Regulations stated that the components of a fall protection system should meet the following CSA Standards:

    • Z259.1-1976: fall-arresting safety belts and lanyards for the construction and mining industries
    • Z259.2-M1979: fall-arresting devices, personnel lowering devices and lifelines
    • Z259.3-M1978: lineman’s body belt and safety strap


    Fall protection equipment


    Since the late 1970`s, there have been significant changes, additions and improvements to CSA standards rendering the reference to the above standards quite outdated.  A complete list of the CSA standards that are included in the latest regulations can be found under section 12.09 of the latest edition of the labour code.

    The reference to the latest CSA standards means that it`s more important than ever that employers take appropriate measures to ensure that all of their fall protection systems and components are up to date and in line with the relevant standards.

    Other Amendments:

    Some additional amendments made by Canadian Occupational Health and Safety speak to other hazards associated with:

    1.  Respiratory protection: Requires that respiratory protection be provided that meets CSA standard Z94.4, and added protections for radiological contaminants.
    2.  Protection against moving vehicles: ANY exposure to risks associated with moving vehicles mandates employers take steps to reduce that risk.

    Cost-Benefit Analysis:

    It`s well understood that the new regulations will generate additional costs for Canadian employers in the short-term (costs associated with creating and implementing the fall protection plan).  However, a cost-benefit analysis conducted by Canada Labour found that the changes should have a net positive financial impact.

    While the expected total cost of the regulation changes is estimated at $21.7 million over the next 20 years, the benefits from reduced injuries and fatalities in the workplace are expected to save Canadian businesses $37.1 million resulting in a net benefit of $15.4 million in savings for Canadian businesses.

    Working at heights training


    In conclusion, while there have been some significant changes to the Canadian Occupational Health and Safety Regulations, they have been developed to both reduce the likelihood of injury or death in the workplace while reducing costs to Canadian businesses at the same time.

    It`s now more important than ever that Canadian businesses understand the risks to their workers, and that they take the appropriate steps to ensure that they develop a fall protection plan that everyone can clearly understand and implement.   And while may seem like a lot to manage for those without significant safety expertise, choosing the right partner can make the whole process significantly easier for you and your entire organization.