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Ontario 2026 OHSA Compliance Checklist

January 1, 2026 OHSA Changes — Employer Self-Assessment
Ontario's latest Occupational Health and Safety Act changes took effect January 1, 2026. Check each item your organization has fully implemented and documented. Sections 3, 4 and 6 apply to construction projects; confirm which obligations apply to your workplace.
1 Administrative Monetary Penalties O. Reg. 365/25
  • Aware that Ministry inspectors can now issue penalties without going to court
  • Inspector orders are corrected promptly and the corrective action is documented
  • Due-diligence records (policies, training, inspections) are maintained as a defence
  • Aware penalty recipients may be named publicly — compliance is a reputational issue
2 Procurement & OHS-System Equivalency O. Reg. 364/25
  • Your COR 2020 or ISO 45001 certification is current and audit-ready
  • You know public-sector buyers must treat all accredited OHS systems as equivalent
  • You are not paying for duplicate certifications to satisfy a single tender
  • Certificates and audit reports are ready to submit with bids
3 On-Site AED — Construction O. Reg. 157/25
  • Assessed whether the project runs 3+ months with 20+ workers (AED required)
  • Compliant AED plus kit on site: scissors, gloves, absorbent towels, razor, spare pads
  • A CPR/AED-trained worker is present whenever work is in progress
  • AED location and procedures are in the site emergency response plan and signed
4 WSIB AED Reimbursement O. Reg. 360/25
  • AED was purchased between July 1, 2025 and June 30, 2027
  • Purchase receipts and proof the project met the AED thresholds are retained
  • Reimbursement claim (up to $2,500/AED) submitted before July 31, 2027
  • Aware reimbursement is limited to one defibrillator per qualifying project
5 Naloxone Kits — At-Risk Workplaces In force 2023
  • Assessed whether your own workers are at risk of an opioid overdose at work
  • If at risk: at least one naloxone kit is provided on site
  • Assigned worker(s) trained to recognize overdose and administer naloxone
  • The risk assessment is documented even where a kit is not required
6 Washroom Cleaning Records — Construction O. Reg. 480/24
  • A cleaning record is maintained for each washroom facility
  • The date and time of the two most recent cleanings are recorded
  • Records are kept accessible for inspection on site
  • Cleaning responsibility is assigned and understood
7 Respirators & PPE — Coming 2026–2027 From Jul 1, 2026
  • Aware CSA-compliant respirators are accepted alongside NIOSH from July 1, 2026
  • Respirator fit-testing is current (before first use, then at least every 2 years)
  • Watching for new CSA head-protection and elevated-work-platform (MEWP) training rules
  • PPE purchasing specifications are reviewed as standards change
8 General Due-Diligence Foundations OHSA
  • OH&S policy is current, signed, and posted (6+ workers)
  • Workplace harassment and violence programs are in place and reviewed
  • A JHSC or health & safety representative is established and meeting
  • Training records and incident / near-miss reporting are up to date
Your Compliance Score
Applicable checks completed: ___ / 32
✔ 28–32   On Track
⚑ 20–27   Minor Gaps
✖ < 20    Action Needed
Score only the items that apply to your workplace (some sections are construction-only).
Not sure which 2026 changes apply to you? Let's map it out.
Our CRSP-certified consultants will identify your obligations under Ontario's 2026 OHSA changes, close the gaps, and get you audit- and inspection-ready across Canada. First conversation is free.