Instruction and training of employees in the location, use and operation of fire protection equipment - 937-1-IPG-038

Effective Date: December 20, 2002

1. Subject

Application of paragraph 17.6(1)(b) of the Canada Occupational Health and Safety Regulations (COHS) Regulations concerning the instruction and training of employees in the location, use and operation of fire protection equipment (FPE).

2. Issue

In order to assist Health and Safety Officers in advising employers and employees concerning the nature and scope of this requirement, the following program position has been developed to ensure a consistent and uniform application of the regulation.

3. Questions

  1. Who is to be trained?
  2. On what type(s) of FPE?
  3. How extensive should the training be?
  4. What role should the Health and Safety Committee/Representative (HSC or HSR) play?
  5. Who is to provide the training?
  6. How much time should Human Resources Development Canada (HRDC)-Labour Program allow an employer to comply?

4. Conclusions

a. Who is to be trained?

All persons employed by an employer at a work place as defined in section 122 of the Canada Labour Code - Part II.

b. On what type(s) of FPE?

All fire protection and emergency equipment to which employees have access to in their work place.

c. How extensive should the training be?

  1. Compliance can be achieved through the provision of an on-going program of instruction and training sessions whereby the employer informs employees of the FPE located in their work place, their appropriate use and operating features.
  2. These instructional sessions should include, but are not limited to, lectures, films, hands-on demonstrations, information brochures and pamphlets or any combination of these methods.
  3. The extent and depth of the training required is dependent on the hazards particular to the work place operations. For example, it may suffice to explain the appropriate use and operating features of portable fire extinguishers to employees working in office occupancies. Employers should, however, be encouraged to provide their employees with hands-on practical training whenever possible.
  4. For higher hazard occupancies such as laboratories, workshops, warehouses, repair garages, and printing plants, etc., it would be necessary to provide employees with hands-on practical training in the use and operation of portable fire extinguishers, in combination with a lecture and/or a film.
  5. It should be considered essential to provide hands-on practical training in the use and operation of the standpipe and hose system and portable fire extinguishers to those employees located in remote work sites, where firefighting capabilities, such as those provided by paid or volunteer public fire departments are either non-existent or delayed due to required travel distances.
  6. With respect to fire protection systems, such as automatic sprinklers and fire alarm systems, a lecture, film and/or information session, would normally be considered sufficient training for employees.

d. What role should the HSC or HSR play?

  1. The employer shall request the policy and/or work place HSC or HSR as applicable, to participate in determining the nature and scope of the instruction and training needed in the work place in accordance with paragraphs 134.1(4)(c), 135.(7)(b), and 136(5)(d) of the Canada Labour Code, Part II.
  2. In addition, the committee shall have full access to the program in order to regularly monitor its implementation.

e. Who is to provide the training?

  1. The onus is on the employer to appoint, or where necessary, to hire "qualified personnel" to provide the necessary instruction and training.
  2. The employer shall consult with the HSC or the HSR prior to appointing someone to perform these duties.

f. How much time should HRDC-Labour Program allow an employer to comply?

(a) Before a time frame is established or requested from an employer, the following factors are to be considered:

  1. the status of the employer's program (if any) at the time of HRDC-Labour Program's intervention;
  2. the complexity of the instruction and training required in the work place;
  3. any previous instruction or training that employees, such as emergency wardens may have had;
  4. the recommendations of the HSC or HSR after reviewing the program;
  5. the number of employees to be trained; and
  6. the resources available to the employer in order to implement the program.

(b) Because of the many variables involved, it is HRDC-Labour Program's position that the minimum time frame in which any employer can be reasonably expected to complete such a program of instruction and training should not be less than six (6) months to one (1) year.

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