How to Build an EHS Program from Scratch (or Fix One That's Drifted)

A practical guide for Ontario property managers and operators on building a health and safety program: legal obligations, six core elements and common gaps.

EHS

9/16/20262 min read

Maybe you've been running without a formal EHS program. Maybe you have one that was written five years ago and hasn't been touched since. Either way, the gap is usually smaller than it looks.

Start with your obligations, not a template

Generic templates include things that don't apply to you and miss things that do. Work out what you're legally required to do first.

In Ontario, the starting point is the Occupational Health and Safety Act (OHSA). Regulations that often apply to commercial and industrial operations include:

O. Reg. 851: Industrial establishments
O. Reg. 213/91: Construction projects, including renovation and demolition
O. Reg. 278/05: Asbestos on construction projects and in buildings
O. Reg. 490/09: Designated substances such as lead and silica
O. Reg. 632/05: Confined spaces

Every other province has its own version, but the basics are the same everywhere: identify hazards, assess risk, put controls in place, train workers and document everything.

The six core elements

1. Accountability. Someone has to own EHS in practice, not just on paper. Your employer duties under OHSA stay with you even if someone else runs the program day to day.

2. Hazard identification and risk assessment. This drives everything else. Find the physical, chemical, biological and ergonomic hazards, then use the hierarchy of controls: elimination, substitution, engineering, administrative, PPE.

3. Written policies and procedures. You need written procedures for high-risk tasks, WHMIS, workplace violence and harassment, and emergency response. Verbal instructions don't count.

4. Training, with records. WHMIS is mandatory. JHSC certification is required for most workplaces with 20 or more workers. If you can't show who was trained, on what and when, it didn't happen.

5. Inspections and audits. Inspections check conditions, and JHSC workplaces generally need one every month. Audits check whether the program itself is working. You need both.

6. Incident investigation. Investigate incidents and near-misses to find the root cause, then track corrective actions until they're closed. Critical injuries must be reported to the Ministry of Labour, Immigration, Training and Skills Development (MLITSD) right away, with a written report within 48 hours.

Where new programs usually fall short

A binder on a shelf. The program exists, but workers have never seen it.
Training with no records. "I know they've been trained" won't satisfy an inspector or a plaintiff's lawyer.
Inspections with no follow-through. Finding a hazard and not fixing it is worse than not inspecting at all, because it proves you knew.
No JHSC or health and safety rep. Workplaces with 6–19 workers need a rep, and 20 or more need a JHSC. Many mid-size operators don't realize this applies to them.

Keep it running

Spreadsheets and email reminders work for one building. They fall apart across a portfolio. RiskCheck Connect, our EHS compliance platform, tracks your obligations, inspections, corrective actions and training records in one place, so you always know where every site stands.

Get it built right

A good EHS consultant doesn't take on your accountability for you. They make sure your program matches your real obligations and is simple enough that people actually use it.

Meeting us at BOMEX in Ottawa, September 22–24? Stop by and talk to our team. Or book a EHS program gap review at riskcheckinc.com.