# Policy - Hazardous Materials and WHMIS

> Fire Service Safety Management System, version 0.3.3 (2026-10-25). The Human Factor. Document FSSMS-POL-15.
>
> Canonical: https://thehumanfactor.ca/library/fire-service-safety/policy-hazardous-materials-and-whmis
>
> Licence: CC BY-NC-SA 4.0 with the Adopting Agency Grant (https://creativecommons.org/licenses/by-nc-sa/4.0/)
>
> General information only, not legal, medical or other professional advice. Verify every requirement against the current official text of the law, standards and manufacturer instructions that apply to you. Obtain your own legal review and consult your joint health and safety committee before adopting anything. You adopt, adapt, implement and rely on this material entirely at your own risk and on your own responsibility. Full terms: Terms of Use, thehumanfactor.ca.

> **Warning: Adoption without implementation increases legal exposure**
>
> Adopting this policy without the training, equipment, supervision, verification and resources to carry it out as written increases municipal and command liability in a regulatory investigation or a fatality inquiry. See [00a Copyright, Licence and Legal Notices](https://thehumanfactor.ca/library/fire-service-safety/copyright-licence-and-legal-notices).

> **Warning: Before adoption**
>
> This model policy requires review by the department’s legal counsel and against every applicable collective agreement before adoption. It is general information, not legal advice. Where it conflicts with a statute, a regulation or an agreement, the statute, regulation or agreement governs. Section and clause numbers are cited as of 2026-10-22; confirm each before adoption.

## How to use this model

**Format options.** Adopt as a chief-approved policy with the WHMIS procedure and the hazmat operating guidelines beneath it, or split into two: a hazmat and energy hazards policy for operations and a WHMIS policy aligned with the municipality’s corporate WHMIS procedure. Keep the numbering; the programs and the audit checklist refer to it.

**Drafting conventions.** **Shall** means mandatory. **Should** means expected unless there is a documented reason. **May** means permitted. Placeholders in double curly braces, such as `{{Department}}`, are completed by the department. Drafting notes in callouts are removed before adoption.

**Keep intact:** the service level commitment (5.1), the monitoring-before-entry and SCBA commitments (5.3), the decontamination and exposure record commitments (5.5, 5.6), the energy-hazard rules (5.8), the WHMIS elements (5.9), and the speak-up and learning firewall clauses (5.10, 5.11). **Adapt:** the service level, action levels, titles, the corporate WHMIS interface and the records system.

## Policy header

| Field | Entry |
|:---|:---|
| Policy title | Hazardous Materials and WHMIS |
| Number | {{Policy number}} |
| Approved by | {{Fire Chief}} (role) |
| Effective date | {{Effective date}} |
| Next review date | {{Review date}} (12 months after adoption, then every three years) |
| Policy owner | {{Deputy Chief}}, operations |
| Consulted | {{JOHSC}}; {{Union}}; {{Volunteer Association}}; medical adviser; municipal corporate safety unit; counsel |

## 1. Purpose

1.1 This policy states what {{Department}} commits to so that members are protected at incidents involving hazardous materials, deliberate chemical, biological, radiological and nuclear agents, illicit drugs, and the energy hazards of lithium-ion batteries, energy storage systems, solar photovoltaic systems and hydrogen; and so that hazardous products used in the department’s own workplaces are identified, communicated and handled under the Workplace Hazardous Materials Information System.

1.2 The detail is in [Hazardous Materials, CBRN and Energy Hazards Program](https://thehumanfactor.ca/library/fire-service-safety/hazardous-materials-cbrn-and-energy-hazards-program); its element 5.7 covers WHMIS in department workplaces.

## 2. Scope and application

2.1 Section 5.1 to 5.8 and 5.10 to 5.11 apply to every member at every incident where a hazardous material, an unknown substance, a drug, or an energy system is or may be involved, including mutual aid companies working within the department’s incident management system.

2.2 Section 5.9 applies to every member, civilian employee, volunteer and contractor in every department workplace: stations, shops, training grounds, apparatus and vehicles.

2.3 The technician sub-module applies only where the department declares a technician service level.

## 3. Definitions

- **Action level**: an instrument reading at which a defined action is taken, set by the department from the applicable exposure limits and medical direction.
- **CBRN**: chemical, biological, radiological and nuclear agents deliberately released (CSA Z1610-11).
- **Competency level**: awareness, operations, operations mission-specific, technician, incident commander, hazmat officer or hazmat safety officer as defined by the responder standard [(NFPA 470, 2022)](https://thehumanfactor.ca/library/fire-service-safety/policy-hazardous-materials-and-whmis#ref-nfpa-470).
- **Energy storage system (ESS)**: a stationary installation that stores electrical energy [(NFPA 855, 2026)](https://thehumanfactor.ca/library/fire-service-safety/policy-hazardous-materials-and-whmis#ref-nfpa-855).
- **Exposure**: contact with a hazardous material, gas, drug or radiation by inhalation, skin, eye, ingestion or injection, whether or not symptoms follow.
- **Hazardous product**: a product classified under the Hazardous Products Regulations for which WHMIS applies [(Hazardous Products Regulations \[CA\], 2026)](https://thehumanfactor.ca/library/fire-service-safety/policy-hazardous-materials-and-whmis#ref-hazardous-products-regulations-ca).
- **IDLH**: immediately dangerous to life or health.
- **Learning firewall**: the commitment that learning information is not used for discipline [(The Human Factor, 2026a)](https://thehumanfactor.ca/library/fire-service-safety/policy-hazardous-materials-and-whmis#ref-the-human-factor-2026a).
- **Psychological safety**: the shared belief that it is safe to speak up, ask, admit error and challenge a decision [(Edmondson, 1999)](https://thehumanfactor.ca/library/fire-service-safety/policy-hazardous-materials-and-whmis#ref-edmondson-1999).
- **Safety data sheet (SDS)**: the supplier’s document for a hazardous product under WHMIS [(Hazardous Products Regulations \[CA\], 2026)](https://thehumanfactor.ca/library/fire-service-safety/policy-hazardous-materials-and-whmis#ref-hazardous-products-regulations-ca).
- **Service level**: the written statement of which hazmat competency levels and tasks the department provides.
- **Thermal runaway**: the self-sustaining heat-producing reaction in a lithium-ion cell [(NTSB, 2020, SR-20/01)](https://thehumanfactor.ca/library/fire-service-safety/policy-hazardous-materials-and-whmis#ref-ntsb-2020).

## 4. Principles

1.  People are the solution we build around, not the problem to fix. The member who meters by habit and the officer who holds the crew outside are the system working; this policy protects what they do [(Hollnagel, 2014)](https://thehumanfactor.ca/library/fire-service-safety/policy-hazardous-materials-and-whmis#ref-hollnagel-2014).

2.  Procedures describe work as done, written with the people who do it [(Conklin, 2012)](https://thehumanfactor.ca/library/fire-service-safety/policy-hazardous-materials-and-whmis#ref-conklin-2012).

3.  Learning comes before blame, and learning information is never used for discipline. Conduct concerns go to a separate process run by different people ([Dekker, 2016](https://thehumanfactor.ca/library/fire-service-safety/policy-hazardous-materials-and-whmis#ref-dekker-2016); [The Human Factor, 2026a](https://thehumanfactor.ca/library/fire-service-safety/policy-hazardous-materials-and-whmis#ref-the-human-factor-2026a)).

4.  Psychological safety is a condition of safety, so speaking up is expected and protected [(Edmondson, 1999)](https://thehumanfactor.ca/library/fire-service-safety/policy-hazardous-materials-and-whmis#ref-edmondson-1999).

5.  The department does what it is trained and equipped to do and no more; beyond the declared service level, it isolates and calls for help.

6.  Nobody enters an unknown atmosphere unmonitored, and nobody treats a battery or a solar array as safe because it looks quiet.

7.  Every exposure is written down, because the member’s health claim decades from now may depend on it.

## 5. Policy statements

### 5.1 Service level

5.1.1 The department shall declare in writing the hazmat and CBRN service level it provides, mapped to the competency levels of the responder standard [(NFPA 470, 2022)](https://thehumanfactor.ca/library/fire-service-safety/policy-hazardous-materials-and-whmis#ref-nfpa-470), shall train and equip every member to the level their assignment requires, and shall not assign members beyond it. *Accountable: fire chief.*

5.1.2 Where the declared level does not meet a hazard in the district, the department shall maintain written mutual aid or provincial team arrangements and shall record the call-out route on every apparatus. *Accountable: fire chief.*

### 5.2 Incident management

5.2.1 Every hazmat and energy-hazard incident shall be managed within the incident management system with hazard control zones, entry control, an entry team and a backup team of equal size, and a hazmat safety officer or the incident safety officer ([NFPA 470, 2022](https://thehumanfactor.ca/library/fire-service-safety/policy-hazardous-materials-and-whmis#ref-nfpa-470); [NFPA 1550, 2024, ch. 10](https://thehumanfactor.ca/library/fire-service-safety/policy-hazardous-materials-and-whmis#ref-nfpa-1550)). *Accountable: incident commander.*

### 5.3 Monitoring and respiratory protection

5.3.1 No member shall enter an atmosphere that may be hazardous without monitoring it first, and monitoring shall continue during entry (MLITSD, n.d., GN 6-51). *Accountable: company officer.*

5.3.2 The department shall set written action levels from the applicable exposure limits with the medical adviser, and SCBA shall be worn in any atmosphere that is IDLH, potentially IDLH, undefined or hazardous, including overhaul and any battery off-gas (MLITSD, n.d., GN 6-50; [NFPA 1550, 2024, cl. 9.11.7](https://thehumanfactor.ca/library/fire-service-safety/policy-hazardous-materials-and-whmis#ref-nfpa-1550)). *Accountable: deputy chief, operations, for the levels; company officer at the incident.*

### 5.4 Protective equipment

5.4.1 Chemical protective clothing shall be selected by a documented risk assessment, shall meet the hazmat and CBRN ensemble standard, and shall be inspected and tested on schedule; structural firefighting PPE shall not be used as chemical protection (CSA Z1610-11; [NFPA 1990, 2022](https://thehumanfactor.ca/library/fire-service-safety/policy-hazardous-materials-and-whmis#ref-nfpa-1990); [NFPA 1550, 2024, cl. 9.6](https://thehumanfactor.ca/library/fire-service-safety/policy-hazardous-materials-and-whmis#ref-nfpa-1550)). *Accountable: program manager, Hazardous Materials team.*

### 5.5 Decontamination

5.5.1 Emergency decontamination shall be set up before the first entry at every hazmat and energy-hazard incident; every member and item leaving a hot zone shall pass through technical decontamination; and post-call station decontamination shall follow [Decontamination and Contamination Control Program](https://thehumanfactor.ca/library/fire-service-safety/decontamination-and-contamination-control-program). *Accountable: incident commander.*

### 5.6 Exposure records and medical surveillance

5.6.1 Every exposure or suspected exposure shall be reported before the end of the shift and recorded in the exposure register, kept for the member’s career plus 30 years, and available to the member and the department physician. *Accountable: health and safety officer.*

5.6.2 Hazmat technicians shall be under a medical surveillance program with baseline, periodic, post-exposure and exit evaluations set by the department physician [(NFPA 1580, 2025)](https://thehumanfactor.ca/library/fire-service-safety/policy-hazardous-materials-and-whmis#ref-nfpa-1580). *Accountable: senior officer responsible for health and safety.*

### 5.7 Opioids, drugs and clandestine laboratories

5.7.1 Members shall follow the tiered precautions for opioid and drug exposure, shall carry and administer naloxone as trained, shall decontaminate skin with soap and water, and shall not enter a suspected clandestine laboratory except for a rescue, operating no switches and treating it as a police-led crime scene ([CCOHS, 2018](https://thehumanfactor.ca/library/fire-service-safety/policy-hazardous-materials-and-whmis#ref-ccohs-2018); MLITSD, n.d., GN 6-17). *Accountable: company officer.*

### 5.8 Energy hazards

5.8.1 At any lithium-ion battery, electric vehicle, energy storage system, solar photovoltaic or hydrogen incident, members shall identify the system, shut it down where trained, and watch it; shall wear full PPE and SCBA near a battery; shall treat every solar array as energized in any light; shall never enter a room or container that is or may be filled with battery gas; shall never overhaul a damaged battery system; and shall escort a damaged electric vehicle to the recovery location with a written warning of reignition risk ([IAFF et al., 2023](https://thehumanfactor.ca/library/fire-service-safety/policy-hazardous-materials-and-whmis#ref-iaff-2023); MLITSD, n.d., GN 6-34, 6-50 and 6-53; [NTSB, 2020, SR-20/01](https://thehumanfactor.ca/library/fire-service-safety/policy-hazardous-materials-and-whmis#ref-ntsb-2020)). *Accountable: incident commander.*

5.8.2 The department shall collect the emergency response plans that energy storage sites must prepare into pre-incident plans and dispatch flags, and shall check its energy-hazard procedures against new guidance at least annually [(NFPA 855, 2026)](https://thehumanfactor.ca/library/fire-service-safety/policy-hazardous-materials-and-whmis#ref-nfpa-855). *Accountable: program manager, Hazardous Materials team.*

### 5.9 WHMIS in department workplaces

5.9.1 **Inventory.** Every department workplace shall maintain a current inventory of hazardous products on the department’s template, reviewed at least annually and whenever a product is added or removed ([Hazardous Products Act \[CA\], 1985](https://thehumanfactor.ca/library/fire-service-safety/policy-hazardous-materials-and-whmis#ref-hazardous-products-act-ca); [Hazardous Products Regulations \[CA\], 2026](https://thehumanfactor.ca/library/fire-service-safety/policy-hazardous-materials-and-whmis#ref-hazardous-products-regulations-ca)). *Accountable: station or shop officer; verified by the HSO.*

5.9.2 **Safety data sheets.** A current safety data sheet, matched to the inventory, shall be available to every member on every shift at every workplace, in paper or by a system that works when the network does not; the department shall obtain updated sheets as suppliers issue them (suppliers must update SDS within 90 days and labels within 180 days of significant new data) ([Hazardous Products Act \[CA\], 1985](https://thehumanfactor.ca/library/fire-service-safety/policy-hazardous-materials-and-whmis#ref-hazardous-products-act-ca); [Hazardous Products Regulations \[CA\], 2026](https://thehumanfactor.ca/library/fire-service-safety/policy-hazardous-materials-and-whmis#ref-hazardous-products-regulations-ca)). *Accountable: station or shop officer.*

5.9.3 **Labels.** Every hazardous product shall carry a supplier label; any product decanted into another container shall carry a workplace label; no unlabelled product shall be used; piping systems carrying hazardous products shall be identified. *Accountable: every member; enforced by the officer.*

5.9.4 **Education and training.** Every member, civilian employee and volunteer shall receive general WHMIS education and workplace-specific training on the products they may be exposed to before working with them, and the training shall be reviewed at least annually in consultation with the JOHSC, or sooner when conditions change; the workplace WHMIS regulation that applies sets the education and review duties ([J21 WHMIS, Hazardous Materials and Asbestos](https://thehumanfactor.ca/library/fire-service-safety/j21-whmis-hazardous-materials-and-asbestos)). Fire service operational training may be used to meet the workplace-specific requirement where it covers the products. *Accountable: deputy chief, administration; training officer.*

5.9.5 **Procurement and contractors.** Hazardous products shall be purchased only with an SDS, and contractors bringing hazardous products into a department workplace shall provide the SDS and follow this policy. *Accountable: procurement; contractor coordinator.*

5.9.6 **Storage and handling.** Products shall be stored, handled and disposed of as the SDS and the applicable regulation require, with the PPE the SDS specifies available and used. *Accountable: station or shop officer.*

### 5.10 Speaking up and stopping work

5.10.1 Every member has the authority and the duty to stop a hazmat or energy-hazard task they believe presents an imminent danger, by naming the hazard and the action; the officer shall acknowledge, act or explain, and review the call afterwards for learning. No stop-work call, challenge, exposure report or near-miss report made in good faith shall be the subject of reprisal. This is in addition to the statutory right to refuse in [Policy - Right to Refuse Unsafe Work and Stop-Work Authority](https://thehumanfactor.ca/library/fire-service-safety/policy-right-to-refuse-unsafe-work-and-stop-work-authority). *Accountable: fire chief.*

5.10.2 A member’s concern under this policy shall be logged within two working days and answered within 15 days with the decision and the reason. *Accountable: program manager, Hazardous Materials team.*

### 5.11 Learning

5.11.1 Every hazmat entry and every energy-hazard incident shall be debriefed and triaged under [Incident Investigation and Learning Program](https://thehumanfactor.ca/library/fire-service-safety/incident-investigation-and-learning-program); exposures with symptoms, entries without a backup team, battery reignitions after handover and deflagrations shall receive a post-incident analysis; and learning information shall not be used for discipline [(The Human Factor, 2026a)](https://thehumanfactor.ca/library/fire-service-safety/policy-hazardous-materials-and-whmis#ref-the-human-factor-2026a). *Accountable: senior officer responsible for health and safety.*

## 6. Roles and responsibilities

Only the differences from [01 Roles and Responsibilities](https://thehumanfactor.ca/library/fire-service-safety/roles-and-responsibilities) are stated.

6.1 **Fire chief:** signs the service level statement; approves this policy; ensures the mutual aid and provincial team arrangements exist.

6.2 **Deputy chief, operations:** owns the hazmat program; approves the action levels with the medical adviser.

6.3 **Deputy chief, administration (or equivalent):** owns WHMIS in department workplaces and the interface with the municipality’s corporate WHMIS procedure.

6.4 **Program manager, Hazardous Materials team:** maintains the program, procedures, pre-plans and the annual guidance check; logs and answers concerns.

6.5 **Health and safety officer:** keeps the exposure register; verifies WHMIS inventories and SDS access on inspection.

6.6 **Department physician:** runs technician medical surveillance; advises on action levels.

6.7 **Station and shop officers:** the WHMIS duties in 5.9.

6.8 **Members:** monitor, wear PPE, decontaminate, report exposures, read labels and SDS, apply workplace labels when decanting, ask when unsure.

6.9 **Procurement and contractors:** 5.9.5.

6.10 **JOHSC:** consulted on this policy, the action levels, the PPE matrix and the annual WHMIS training review; reviews exposure register trends annually.

## 7. Program and procedures this policy requires

- [Hazardous Materials, CBRN and Energy Hazards Program](https://thehumanfactor.ca/library/fire-service-safety/hazardous-materials-cbrn-and-energy-hazards-program), including element 5.7, WHMIS in department workplaces
- [SWP - Hazmat Entry and Decontamination](https://thehumanfactor.ca/library/fire-service-safety/swp-hazmat-entry-and-decontamination)
- [SWP - EV and Lithium Battery Fire](https://thehumanfactor.ca/library/fire-service-safety/swp-ev-and-lithium-battery-fire)
- [SWP - Solar PV and Energy Storage Systems](https://thehumanfactor.ca/library/fire-service-safety/swp-solar-pv-and-energy-storage-systems)
- [SWP - Downed Power Lines and Utility Emergencies](https://thehumanfactor.ca/library/fire-service-safety/swp-downed-power-lines-and-utility-emergencies)
- [SWP - Exposure Reporting](https://thehumanfactor.ca/library/fire-service-safety/swp-exposure-reporting)
- [SWP - On-Scene Preliminary Exposure Reduction](https://thehumanfactor.ca/library/fire-service-safety/swp-on-scene-preliminary-exposure-reduction) and [SWP - Post-Call Station Decontamination](https://thehumanfactor.ca/library/fire-service-safety/swp-post-call-station-decontamination)

## 8. Records, confidentiality and disclosure

8.1 Records: the service level statement; training and competency records; instrument logs; entry logs and monitoring records; decon checklists; exposure reports and the exposure register; technician surveillance dates (medical content stays with the physician); WHMIS inventories, SDS and training records; pre-plans; handover records; the concern log; learning review reports.

8.2 Exposure records are personal information: kept for the career plus 30 years, accessible to the member, released to others only with consent or as the law requires. Medical records are held by the physician and never merged with the exposure register. Records are written expecting freedom-of-information disclosure and identify people by role wherever the purpose allows.

## 9. Reporting

9.1 To the fire chief: every exposure with symptoms the same day; every battery reignition after handover; the quarterly indicator worksheet.

9.2 To the JOHSC: the quarterly indicator worksheet; the annual exposure register trend review; the annual WHMIS training review; every learning review summary.

9.3 To the regulator: exposures and incidents reportable under the applicable statute within the statutory time ([J08 Incident Reporting and Investigation](https://thehumanfactor.ca/library/fire-service-safety/j08-incident-reporting-and-investigation)).

9.4 To council: the hazmat and energy-hazard indicators in the annual health and safety report.

## 10. Training requirements

| Role | Minimum training | Refresh |
|:---|:---|:---|
| Every member | Hazmat awareness; opioid and drug exposure; WHMIS general and workplace-specific | Annually |
| Every suppression member | Hazmat operations with practical evolution; energy hazards; instrument sign-off | Annually |
| Selected companies | Mission-specific competencies as declared | Annually |
| Technician team | Technician level and declared specialties; CBRN PPE | Annual refresher; recertification per standard |
| Chief officers | Hazmat incident commander | Every three years |
| Hazmat officer and safety officer | Officer chapters of the responder standard | Every three years |
| Station and shop officers | WHMIS administration (inventory, SDS, labels) | Annually |

## 11. Legal and standards basis

11.1 The applicable occupational health and safety statute and regulations: the workplace WHMIS regulation, spill reporting and the storage of hazardous products ([J21 WHMIS, Hazardous Materials and Asbestos](https://thehumanfactor.ca/library/fire-service-safety/j21-whmis-hazardous-materials-and-asbestos)); SCBA, respiratory protection and fit testing ([J13 Firefighter PPE and Protective Equipment](https://thehumanfactor.ca/library/fire-service-safety/j13-firefighter-ppe-and-protective-equipment); [J14 Respiratory Protection, Fit Testing and Breathing Air](https://thehumanfactor.ca/library/fire-service-safety/j14-respiratory-protection-fit-testing-and-breathing-air)); confined space entry ([J17 Confined Space](https://thehumanfactor.ca/library/fire-service-safety/j17-confined-space)); limits of approach to energized conductors ([J19 Lockout, Machine Guarding and Electrical Safety](https://thehumanfactor.ca/library/fire-service-safety/j19-lockout-machine-guarding-and-electrical-safety)); exposure record retention ([J09 Records Retention](https://thehumanfactor.ca/library/fire-service-safety/j09-records-retention)); and reporting to the regulator ([J08 Incident Reporting and Investigation](https://thehumanfactor.ca/library/fire-service-safety/j08-incident-reporting-and-investigation)).

11.2 WHMIS 2015 classification, labels and safety data sheets ([Hazardous Products Act \[CA\], 1985](https://thehumanfactor.ca/library/fire-service-safety/policy-hazardous-materials-and-whmis#ref-hazardous-products-act-ca); [Hazardous Products Regulations \[CA\], 2026](https://thehumanfactor.ca/library/fire-service-safety/policy-hazardous-materials-and-whmis#ref-hazardous-products-regulations-ca)); the transport of dangerous goods ([Transportation of Dangerous Goods Act, 1992 \[CA\], 1992](https://thehumanfactor.ca/library/fire-service-safety/policy-hazardous-materials-and-whmis#ref-transportation-of-dangerous-goods-act-1992-ca); [Transportation of Dangerous Goods Regulations \[CA\], 2026](https://thehumanfactor.ca/library/fire-service-safety/policy-hazardous-materials-and-whmis#ref-transportation-of-dangerous-goods-regulations-ca)); the Emergency Response Guidebook [(Transport Canada, 2024)](https://thehumanfactor.ca/library/fire-service-safety/policy-hazardous-materials-and-whmis#ref-transport-canada-2024); and the duty of everyone who directs work to take reasonable steps to prevent bodily harm [(Criminal Code \[CA\], 1985, s. 217.1)](https://thehumanfactor.ca/library/fire-service-safety/policy-hazardous-materials-and-whmis#ref-criminal-code-ca).

11.3 [NFPA 470 (2022)](https://thehumanfactor.ca/library/fire-service-safety/policy-hazardous-materials-and-whmis#ref-nfpa-470); [NFPA 1990 (2022)](https://thehumanfactor.ca/library/fire-service-safety/policy-hazardous-materials-and-whmis#ref-nfpa-1990); [NFPA 1550 (2024)](https://thehumanfactor.ca/library/fire-service-safety/policy-hazardous-materials-and-whmis#ref-nfpa-1550); [NFPA 1580 (2025)](https://thehumanfactor.ca/library/fire-service-safety/policy-hazardous-materials-and-whmis#ref-nfpa-1580); [NFPA 855 (2026)](https://thehumanfactor.ca/library/fire-service-safety/policy-hazardous-materials-and-whmis#ref-nfpa-855); [NFPA 2 (2023)](https://thehumanfactor.ca/library/fire-service-safety/policy-hazardous-materials-and-whmis#ref-nfpa-2); CSA Z1610-11; CSA Z94.4-18; CSA Z462:24.

11.4 [CCOHS (2018)](https://thehumanfactor.ca/library/fire-service-safety/policy-hazardous-materials-and-whmis#ref-ccohs-2018); NTSB (2020, SR-20/01); IAFF et al. (2023).

11.5 Accreditation: hazmat program deployment, regulatory compliance and appraisal; exposure reduction and contamination control; exposure records [(CPSE, 2019, criteria 5H.1 to 5H.3, 11A.4, 11A.9, 11A.10)](https://thehumanfactor.ca/library/fire-service-safety/policy-hazardous-materials-and-whmis#ref-cpse-2019).

## 12. Review and approval

12.1 Reviewed 12 months after adoption, then every three years; and after any exposure with lasting harm, any battery deflagration or reignition injury, any legislative or standards change, or on the request of the JOHSC. The energy-hazard procedures beneath this policy are checked against new guidance at least annually regardless.

12.2 Approved by the fire chief after consultation with the JOHSC, the bargaining agents, the volunteer association and the municipality’s corporate safety unit, with the consultation recorded.

## 13. Adoption checklist

| Step | Lead | Done |
|:---|:---|:---|
| Counsel and collective agreement review | Fire chief |  |
| JOHSC consultation recorded | Senior officer, H&S |  |
| Bargaining agent and volunteer association consultation recorded | Fire chief |  |
| Interface with the corporate WHMIS procedure agreed | Deputy chief, administration |  |
| Service level statement signed | Fire chief |  |
| Action levels set with the medical adviser | Deputy chief, operations |  |
| PPE selection matrix adopted | Program manager |  |
| Exposure register and retention period confirmed | HSO |  |
| Technician surveillance program confirmed with the physician | Senior officer, H&S |  |
| WHMIS inventories and SDS access verified at every workplace | HSO |  |
| Energy-hazard SOGs and dispatch card issued | Program manager |  |
| Concern route announced | Program manager |  |
| Policy signed and posted | Fire chief |  |
| Review date entered in the annual calendar | Senior officer, H&S |  |

## 14. Consulting the JOHSC and bargaining agents

| They will ask | Honest answer |
|:---|:---|
| Will members be sent to incidents beyond what they are trained for? | No. The service level statement is the limit; beyond it the department isolates and calls for help, and the policy says so. |
| Who sets the action levels, and can members see them? | The department with the medical adviser and the JOHSC; they are printed on the instrument cases and in the SOG. |
| Will an exposure report be held against a member? | Never. The firewall applies and the register exists for the member’s benefit. |
| What about volunteers who rarely see these incidents? | They get the same annual sessions, at times they can attend, with the time credited. |
| Is WHMIS a fire department program or a municipal one? | Both: the municipality’s procedure applies, and this policy sets the fire service’s duties under it. |

Put the agreement in writing. Where there is disagreement, record it, adopt what can be agreed, and review at 12 months.

## 15. Customization and sector variants

> **Note: Customize**
>
> Complete the header table, the role titles, the service level, the action levels, the retention period and the corporate WHMIS interface.

> **Tip: Volunteer and composite departments**
>
> The energy-hazards session and the opioid procedure come first; they are the incidents a volunteer station will actually see. Technician capability stays with the regional team, in writing.

**Closing disclaimer.** This model policy is general information prepared by The Human Factor. It is not legal advice. Adapt it to the department, confirm every citation, and review it with counsel and the bargaining agents before adoption.

## Jurisdiction requirements

This chapter relies on the following legal requirements, which differ by province and territory. Check your jurisdiction’s section on each topic page before adopting it.

| Topic | What to check in your jurisdiction | Page |
|:---|:---|:---|
| Incident Reporting and Investigation | Which exposures and hazardous materials incidents must be reported to the regulator, and how quickly | [J08 Incident Reporting and Investigation](https://thehumanfactor.ca/library/fire-service-safety/j08-incident-reporting-and-investigation) |
| Records Retention | How long exposure records must be kept, and who may see them | [J09 Records Retention](https://thehumanfactor.ca/library/fire-service-safety/j09-records-retention) |
| Firefighter PPE and Protective Equipment | Whether a regulation requires SCBA and hoods for firefighters who may be exposed to harmful contaminants | [J13 Firefighter PPE and Protective Equipment](https://thehumanfactor.ca/library/fire-service-safety/j13-firefighter-ppe-and-protective-equipment) |
| Respiratory Protection, Fit Testing and Breathing Air | The respirator program standard, the fit-test frequency and method, and the breathing air standard | [J14 Respiratory Protection, Fit Testing and Breathing Air](https://thehumanfactor.ca/library/fire-service-safety/j14-respiratory-protection-fit-testing-and-breathing-air) |
| Confined Space | The confined space rules that apply when a hazardous materials entry is also a confined space entry | [J17 Confined Space](https://thehumanfactor.ca/library/fire-service-safety/j17-confined-space) |
| Lockout, Machine Guarding and Electrical Safety | The minimum approach distances to energized conductors, and any relief for trained emergency workers | [J19 Lockout, Machine Guarding and Electrical Safety](https://thehumanfactor.ca/library/fire-service-safety/j19-lockout-machine-guarding-and-electrical-safety) |
| WHMIS, Hazardous Materials and Asbestos | The workplace WHMIS regulation and its education and review duties, spill and release reporting to the environmental authority, and fuel and flammable storage | [J21 WHMIS, Hazardous Materials and Asbestos](https://thehumanfactor.ca/library/fire-service-safety/j21-whmis-hazardous-materials-and-asbestos) |

## References

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Hollnagel, E. (2014). *Safety-I and Safety-II: The past and future of safety management*. Ashgate.

International Association of Fire Fighters \[IAFF\], UL Solutions, & Fire Safety Research Institute \[FSRI\]. (2023). *Considerations for fire service response to residential battery energy storage system incidents*. <https://www.iaff.org/wp-content/uploads/IAFF_DOE_ResidentialESSConsiderations_Final.pdf>

National Fire Protection Association. (2022). *NFPA 1990, Standard for protective ensembles for hazardous materials and CBRN operations* (consolidates NFPA 1991, 1992 and 1994). <https://www.nfpa.org/codes-and-standards/nfpa-1990-standard-development/1990>

National Fire Protection Association. (2022). *NFPA 470, Hazardous materials/weapons of mass destruction (WMD) standard for responders* (consolidates NFPA 472, 473 and 1072). <https://www.nfpa.org/codes-and-standards/nfpa-470-standard-development/470>

National Fire Protection Association. (2023). *NFPA 2, Hydrogen technologies code*. <https://www.nfpa.org/codes-and-standards/nfpa-2-standard-development/2>

National Fire Protection Association. (2024). *NFPA 1550, Standard for emergency responder health and safety* (consolidates NFPA 1500, 1521 and 1561). <https://www.nfpa.org/codes-and-standards/nfpa-1550-standard-development/1550>

National Fire Protection Association. (2025). *NFPA 1580, Standard for emergency responder occupational health and wellness* (consolidates NFPA 1581, 1582, 1583 and 1584). <https://www.nfpa.org/codes-and-standards/nfpa-1580-standard-development/1580>

National Fire Protection Association. (2026). *NFPA 855, Standard for the installation of stationary energy storage systems*. <https://www.nfpa.org/codes-and-standards/nfpa-855-standard-development/855>

National Transportation Safety Board \[NTSB\]. (2020). *Safety risks to emergency responders from lithium-ion battery fires in electric vehicles* (Safety Report NTSB/SR-20/01). <https://www.ntsb.gov/safety/safety-studies/Documents/SR2001.pdf>

Ontario Ministry of Labour, Immigration, Training and Skills Development \[MLITSD\]. (n.d.). *Firefighter guidance notes* (Section 21 Advisory Committee; individual notes revised to 2026). <https://www.ontario.ca/document/firefighter-guidance-notes>

The Human Factor. (2026a). *After the Call, Manual 02: The three tiers and event triage* \[Unpublished manuscript\].

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Transportation of Dangerous Goods Regulations, SOR/2001-286 (Canada; consolidation consulted in 2026, date not recorded). <https://laws-lois.justice.gc.ca/eng/regulations/SOR-2001-286/>
