# Policy - Occupational Health and Safety

> Fire Service Safety Management System, version 0.3.3 (2026-10-25). The Human Factor. Document FSSMS-POL-01.
>
> Canonical: https://thehumanfactor.ca/library/fire-service-safety/policy-occupational-health-and-safety
>
> 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: Review before adoption**
>
> This model policy needs review by the department’s counsel and against every applicable collective agreement and volunteer association agreement before adoption. It is general information, not legal advice. Where it conflicts with a statute, regulation or agreement, the statute, regulation or agreement governs. Section numbers are cited as of 2026-10-22; confirm each one before signing.

## How to use this model

**Format.** This note contains two documents. Part A is the one-page policy statement that the statute requires, signed by the fire chief and by the municipality through council or the chief administrative officer, and posted in every station. Part B is the policy proper, which gives the statement its working content. Adopt Part A as a signed policy; adopt Part B as a department policy, standard operating guideline or directive, whichever format the department uses, but keep the numbering because the other policies and the audit checklists refer to it.

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

**Keep intact.** The ten commitments in section 5, the accountability clauses in section 6, the four house principles in section 4, and the review cycle in section 12. **Adapt.** Role titles, the signature block, the posting locations and the reporting calendar.

| Field | Entry |
|:---|:---|
| Policy title | Occupational Health and Safety Policy |
| Policy number | FSSMS-POL-01 ({{Department}} number: {{Policy number}}) |
| Approved by | {{Fire Chief}}; {{Municipality}} through council resolution or the chief administrative officer |
| Effective date | {{Effective date}} |
| Next review date | {{Review date}} (12 months after adoption, then every three years, and annually for the Part A statement where the statute requires) |
| Policy owner | {{Division Chief, Safety}} |
| Consulted | {{JOHSC}}; {{Union}}; {{Volunteer Association}}; department physician or occupational health provider; municipal counsel |

------------------------------------------------------------------------

## Part A: Policy statement (signed, posted)

> **Note: Customize**
>
> This page is the document the regulator asks to see first and the one every member sees on the station wall. Keep it to one page. The signature block uses roles, never names, in this model; the department fills in the names when it signs. The signature form with the posting log is [Form - OHS Policy Statement (Signature Page)](https://thehumanfactor.ca/library/fire-service-safety/form-ohs-policy-statement-signature-page).

**{{Department}} Occupational Health and Safety Policy Statement**

The health and safety of every member of {{Department}}, career and volunteer, uniformed and civilian, is the first condition of everything we do. Firefighting, rescue, medical response and the work that supports them are hazardous. We accept that the hazards exist; we do not accept that injury, illness or death is part of the job.

{{Department}} and {{Municipality}} commit to:

1.  Comply with the applicable occupational health and safety statute and regulations and with the standards this department adopts, and go beyond them where the evidence says we should.
2.  Run the internal responsibility system: everyone in this department is responsible for health and safety to the extent of their authority and ability to act, and the chain of command is accountable for the safety of the work it directs.
3.  Identify hazards before they hurt someone, assess the risk, and control it by the hierarchy of controls: eliminate first, protect with equipment last.
4.  Consult the joint occupational health and safety committee on every policy, program and procedure that affects health and safety, respond to its recommendations in writing within the statutory time, and give it the time, training and information it needs.
5.  Train and supervise every member so they can do their work safely, and never assign a task to a member who is not trained and equipped for it.
6.  Report every injury, exposure, near miss and hazard; learn from each one; and never use what we learn from a report as the basis for discipline.
7.  Protect psychological health and safety on the same footing as physical health and safety, and make it safe to speak up, ask, admit a mistake and challenge a decision.
8.  Improve continuously: measure how the program performs, audit it, review it with the committee every year, and act on what we find.
9.  Resource the program: time, people, equipment and money, in the budget, every year.
10. Hold ourselves to account: the fire chief reports to the chief administrative officer and council on health and safety performance every year, and every officer answers for the safety of the people they lead.

No one in this department will be penalized for raising a safety concern, refusing unsafe work in good faith, stopping a task they believe is dangerous, or reporting an error.

| Signatory | Role | Signature | Date |
|:---|:---|:---|:---|
| Fire chief | {{Fire Chief}} |  |  |
| Municipality | {{Chief Administrative Officer}} or Mayor or Warden on council resolution {{Resolution number}} |  |  |
| Reviewed with | {{JOHSC}} worker co-chair and employer co-chair |  |  |

Posted at: every station, the training centre, headquarters, the maintenance facility and {{Records system}}. Reviewed annually.

------------------------------------------------------------------------

## Part B: The policy

## 1. Purpose

1.1 This policy states what {{Department}} commits to for the health and safety of its members and how that commitment is given effect through the Fire Service Safety Management System.

1.2 It satisfies the requirement in the applicable occupational health and safety statute for a written occupational health and safety policy, and it is the top-tier document of the written occupational health and safety program that the statute requires at the department’s size ([J03 OHS Policy and Program](https://thehumanfactor.ca/library/fire-service-safety/j03-ohs-policy-and-program)). It is also the OH&S policy that a management-system standard requires of top management (ISO 45001:2018, cl. 5.2; CSA Z45001:19, cl. 5.2) and the written organizational statement and policy that the fire service standard expects [(NFPA 1550, 2024, ch. 6)](https://thehumanfactor.ca/library/fire-service-safety/policy-occupational-health-and-safety#ref-nfpa-1550).

1.3 Every other policy in this set is written under this one. Where another policy is silent, this policy applies.

## 2. Scope and application

2.1 This policy applies to every member of {{Department}}: career, volunteer, paid-on-call, probationary, auxiliary, student, civilian and seconded; to every officer; and to the fire chief. It applies to contractors, visitors and mutual aid partners while they are in a department workplace or operating under department command.

2.2 It applies to every workplace: stations, headquarters, training grounds, maintenance facilities, apparatus, vessels, and any incident scene, training site or other location where members work under department direction.

2.3 It applies to every module the department switches on in [01 Program Profile Worksheet](https://thehumanfactor.ca/library/fire-service-safety/program-profile-worksheet). Modules switched off are recorded there with the reason.

2.4 Nothing in this policy reduces a right or duty under the applicable statute, regulation or collective agreement.

## 3. Definitions

**Accountable.** The one role that answers for an outcome and cannot delegate that answerability.

**Hierarchy of controls.** The order in which controls are chosen: elimination, substitution, engineering controls, administrative controls, personal protective equipment.

**Internal responsibility system.** The principle that every person in the workplace is responsible for health and safety in proportion to their authority and ability to act, with the employer carrying the greatest responsibility because it has the most control [(Ham, 1976)](https://thehumanfactor.ca/library/fire-service-safety/policy-occupational-health-and-safety#ref-ham-1976); some statutes state it in their purpose clause ([J02 Duties of Employers, Supervisors, Workers and Contractors](https://thehumanfactor.ca/library/fire-service-safety/j02-duties-of-employers-supervisors-workers-and-contractors)).

**JOHSC.** The joint occupational health and safety committee required by the applicable statute, or the safety representative where the department is below the committee threshold.

**Learning information.** Anything said, written or produced in a debrief, after-action review, post-incident analysis, learning team, near-miss report or independent learning review for the purpose of learning.

**Member.** Any person who performs work for the department under its direction, whether paid, volunteer or paid-on-call.

**Program.** The written, auditable system for one hazard family or function, as set out in [01 Program Architecture](https://thehumanfactor.ca/library/fire-service-safety/program-architecture).

**Psychological health and safety.** The absence of harm to mental health from the workplace, and the presence of conditions that support it (CSA Z1003-13); some statutes now define health and safety to include it ([J28 Psychological Health and Safety](https://thehumanfactor.ca/library/fire-service-safety/j28-psychological-health-and-safety)).

**Psychological safety.** The shared belief among a crew or a team that it is safe to speak up, ask, admit error and challenge, without fear of embarrassment or reprisal [(Edmondson, 1999)](https://thehumanfactor.ca/library/fire-service-safety/policy-occupational-health-and-safety#ref-edmondson-1999).

**Safety management system.** The Fire Service Safety Management System adopted by the department: this policy set, the programs, the safe work procedures, the audit program and the records.

## 4. Principles

1.  **People are the solution we build around, not the problem to fix.** The members who do the work are the department’s best source of knowledge about where it is hard and where it goes wrong, and the program is designed with them.

2.  **Procedures describe work as done, written with the people who do it.** A procedure that does not match how the task is really done is a hazard, and the department corrects the procedure or the conditions, not the person.

3.  **Learning comes before blame, and learning information is never used for discipline.** The department separates learning from accountability for conduct, and runs the two through different people and different processes.

4.  **Psychological safety is a condition of safety, so speaking up is expected and protected.** Every member is expected to say so when something is unsafe, and every officer is expected to welcome it.

5.  **The line owns safety.** The fire chief and the chain of command are accountable for the safety of the work they direct. The safety division coordinates and verifies; the JOHSC participates and challenges; neither replaces the line.

6.  **Prevention over response.** The department spends its effort on the controls that stop people dying and getting sick: respiratory protection, contamination control, incident command and accountability, safe driving, medical fitness, psychological health. These answer the recurring causes in the line-of-duty death evidence: sudden cardiac events, occupational cancer, vehicle collisions, and the five structural-fire factors of risk assessment, command, accountability, communications and procedures that the fire service has distilled from the NIOSH investigations (Fire Engineering, 2023; NIOSH, n.d.-b; USFA, 2024b; see [05 Design Principles and Lessons Learned](https://thehumanfactor.ca/library/fire-service-safety/design-principles-and-lessons-learned)).

7.  **Evidence and measurement.** The department measures what it does and what happens, publishes the results to its members, and changes course when the numbers say so.

8.  **Volunteers are members.** Every commitment in this policy applies to volunteer and paid-on-call members in full, whatever the statute says about their status.

## 5. Policy statements

### 5.1 Compliance

5.1.1 {{Department}} shall comply with the applicable occupational health and safety statute and regulations, with the workers’ compensation statute, and with every standard the department adopts through [02 Standards and Law Master Map](https://thehumanfactor.ca/library/fire-service-safety/standards-and-law-master-map). Accountable: {{Fire Chief}}.

5.1.2 The department shall maintain a register of its legal and other requirements, review it annually, and evaluate compliance against it as an input to the management review (ISO 45001:2018, cl. 6.1.3 and 9.1.2). Accountable: {{Division Chief, Safety}}.

5.1.3 Where a standard sets a higher bar than the regulation, the department shall meet the standard unless it records a documented reason not to. Accountable: {{Fire Chief}}.

### 5.2 Internal responsibility system

5.2.1 Every member shall take every reasonable precaution for their own health and safety and that of others, cooperate with the department and with the JOHSC, use the equipment and protective equipment provided, report hazards, and not take part in horseplay or unsafe conduct. Accountable: each member.

5.2.2 Every officer who directs work shall know the hazards of that work, ensure the members assigned are trained, competent and fit for it, ensure procedures are followed and protective equipment is used, and respond to concerns, reports and refusals as the policies require. Accountable: each officer.

5.2.3 The duties in [01 Roles and Responsibilities](https://thehumanfactor.ca/library/fire-service-safety/roles-and-responsibilities) and [Policy - Internal Responsibility and Accountability](https://thehumanfactor.ca/library/fire-service-safety/policy-internal-responsibility-and-accountability) form part of this policy. Accountable: {{Fire Chief}}.

### 5.3 Hazard identification and control

5.3.1 The department shall maintain a hazard profile and risk register covering routine, non-routine and emergency work, assessed by the method in [03 Hazard Profile and Risk Register Method](https://thehumanfactor.ca/library/fire-service-safety/hazard-profile-and-risk-register-method) and governed by [Policy - Risk Management and Hazard Assessment](https://thehumanfactor.ca/library/fire-service-safety/policy-risk-management-and-hazard-assessment). Accountable: {{Division Chief, Safety}}.

5.3.2 Controls shall be selected in hierarchy order (ISO 45001:2018, cl. 8.1.2; CSA Z1002:12). Personal protective equipment is the last control, never the first, and never the only control where a higher control is practicable. Accountable: program managers.

5.3.3 Workplaces shall be inspected on the schedule in [Annual Inspection and Review Schedule](https://thehumanfactor.ca/library/fire-service-safety/annual-inspection-and-review-schedule), and every deficiency logged in the [Corrective Action Register](https://thehumanfactor.ca/library/fire-service-safety/corrective-action-register) with an owner and a due date. Accountable: {{Health and Safety Officer}}.

### 5.4 Consultation through the JOHSC

5.4.1 The department shall establish and maintain the JOHSC as the statute requires ([J05 Joint Committee and Health and Safety Representative](https://thehumanfactor.ca/library/fire-service-safety/j05-joint-committee-and-health-and-safety-representative)) and as set out in [02 JOHSC Integration](https://thehumanfactor.ca/library/fire-service-safety/johsc-integration): composition, co-chairs, monthly meetings, paid time, training, posted minutes (ISO 45001:2018, cl. 5.4). Accountable: {{Fire Chief}}.

5.4.2 The department shall consult the JOHSC before adopting or changing any policy, program, procedure, protective equipment or safety-sensitive training, and shall file the consultation record with the document; some jurisdictions require committee consultation on written procedures by regulation ([J06 Written Procedures and Committee Consultation](https://thehumanfactor.ca/library/fire-service-safety/j06-written-procedures-and-committee-consultation)). Accountable: policy owner for each document.

5.4.3 The fire chief shall respond in writing to every written JOHSC recommendation within the time the applicable statute sets ([J05 Joint Committee and Health and Safety Representative](https://thehumanfactor.ca/library/fire-service-safety/j05-joint-committee-and-health-and-safety-representative)), and within 21 days wherever the statute allows longer, stating what the department will do, by when, and if it declines, why. Accountable: {{Fire Chief}}.

5.4.4 Volunteer members shall be represented on the JOHSC in proportion to their share of the department. Accountable: {{Fire Chief}}.

### 5.5 Training and supervision

5.5.1 No member shall be assigned a task for which they have not been trained and found competent, and no service shall be declared for which the department has not trained and equipped its members. Accountable: each officer; {{Deputy Chief}} for declared services.

5.5.2 Every member shall receive orientation to this policy and the safety management system on joining and whenever a program changes materially, with the training ladder in [03 Communication, Training and Rollout Plan](https://thehumanfactor.ca/library/fire-service-safety/communication-training-and-rollout-plan). Accountable: training division.

5.5.3 Every officer shall complete the supervisor safety competency in [01 Roles and Responsibilities](https://thehumanfactor.ca/library/fire-service-safety/roles-and-responsibilities) section 7 within six months of appointment. Accountable: {{Deputy Chief}}.

### 5.6 Reporting and learning

5.6.1 Every injury, illness, exposure, near miss, good catch, equipment failure and hazard shall be reported through the department’s reporting system before the end of the shift or, for volunteers, within 24 hours. Accountable: each member; each officer for the supervisor’s section.

5.6.2 The department shall report to the regulator and the workers’ compensation board within the statutory times ([J08 Incident Reporting and Investigation](https://thehumanfactor.ca/library/fire-service-safety/j08-incident-reporting-and-investigation)) and notify the JOHSC. Accountable: {{Division Chief, Safety}}.

5.6.3 Events shall be triaged and reviewed through the three-tier learning system in [Incident Investigation and Learning Program](https://thehumanfactor.ca/library/fire-service-safety/incident-investigation-and-learning-program): hot debrief and after-action review, post-incident analysis, independent learning review. Accountable: {{Division Chief, Safety}}.

5.6.4 Learning information shall never be used as the basis for discipline. Conduct concerns go to a separate process run by different people. Accountable: {{Fire Chief}}.

### 5.7 Psychological health and safety

5.7.1 The department shall identify and control psychosocial hazards with the same method it uses for physical hazards (CSA Z1003-13), and run the program in [Psychological Health and Safety and Peer Support Program](https://thehumanfactor.ca/library/fire-service-safety/psychological-health-and-safety-and-peer-support-program). Accountable: {{Deputy Chief}} through the program manager.

5.7.2 Every officer shall act so that members can speak up, challenge and stop work without fear: acknowledge the concern, act on it, and review it later for learning. In fire service safety-climate data, higher supervisor support for safety and higher management commitment to safety are associated with lower injury odds, and supervisor support is the one an officer controls directly [(Geczik et al., 2024)](https://thehumanfactor.ca/library/fire-service-safety/policy-occupational-health-and-safety#ref-geczik-2024). The department shall measure psychological safety in every program’s indicators. Accountable: each officer; {{Division Chief, Safety}} for the measure.

5.7.3 Harassment and violence shall be prevented and responded to under the department’s policies and the applicable law ([J26 Workplace Violence](https://thehumanfactor.ca/library/fire-service-safety/j26-workplace-violence); [J27 Workplace Harassment](https://thehumanfactor.ca/library/fire-service-safety/j27-workplace-harassment)). Accountable: {{Fire Chief}}.

### 5.8 Continuous improvement

5.8.1 The department shall run the annual cycle in [04 Annual Program Cycle and Calendar](https://thehumanfactor.ca/library/fire-service-safety/annual-program-cycle-and-calendar): quarterly program updates, annual program appraisals, an annual internal audit, an annual management review chaired by the fire chief, and an external review every three years (ISO 45001:2018, cl. 9.2 and 9.3; [NFPA 1550, 2024, ch. 6](https://thehumanfactor.ca/library/fire-service-safety/policy-occupational-health-and-safety#ref-nfpa-1550)), which also meets any statutory duty to monitor the OHS program’s effectiveness ([J03 OHS Policy and Program](https://thehumanfactor.ca/library/fire-service-safety/j03-ohs-policy-and-program)), as governed by [Policy - Program Review and Continuous Improvement](https://thehumanfactor.ca/library/fire-service-safety/policy-program-review-and-continuous-improvement). Accountable: {{Fire Chief}}.

5.8.2 Every program shall be owned by a line program manager through a Program Improvement Team or a named officer, as set out in [06 Program Improvement Teams](https://thehumanfactor.ca/library/fire-service-safety/program-improvement-teams). Accountable: {{Deputy Chief}}.

### 5.9 Resources

5.9.1 The fire chief shall ensure the safety management system is resourced in the annual budget, using the program team budget worksheets, and shall escalate in writing to the chief administrative officer and council any safety-critical gap that cannot be resourced. Accountable: {{Fire Chief}}.

5.9.2 The senior officer responsible for health and safety and the health and safety officer shall be given the authority, time and access to do their work and shall report directly enough to the fire chief to be heard. Accountable: {{Fire Chief}}.

### 5.10 Measurement and review

5.10.1 The department shall maintain the leading and lagging indicators in [04 Baseline Metrics and Indicator Set](https://thehumanfactor.ca/library/fire-service-safety/baseline-metrics-and-indicator-set), publish them to members quarterly, report them to the JOHSC monthly and to council annually. Accountable: {{Health and Safety Officer}}.

5.10.2 This policy and the Part A statement shall be reviewed as section 12 requires. Accountable: {{Division Chief, 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 here.

6.1 **Council or governing board.** Adopts the Part A statement by resolution, receives the annual health and safety report, and approves the budget that funds the commitments in section 5.9.

6.2 **Chief administrative officer.** Co-signs the Part A statement for the municipality as employer of record; ensures corporate services support the fire service’s program with written service levels.

6.3 **Fire chief.** Signs the Part A statement; is accountable for every commitment in section 5; chairs the management review; responds to JOHSC recommendations.

6.4 **Policy owner ({{Division Chief, Safety}}).** Maintains this policy, runs the consultation at each review, keeps the legal requirements register, and reports compliance.

6.5 **Officers.** Carry the employer’s duties for the work they direct; model the behaviour; respond to concerns.

6.6 **Members.** Carry the duties in 5.2.1; take part in programs, training, medical evaluations and learning reviews.

6.7 **JOHSC.** Consulted on this policy at every review; receives the posted statement; audits compliance with the policy as part of its statutory functions.

## 7. Program and procedures this policy requires

Every program in [01 Program Architecture](https://thehumanfactor.ca/library/fire-service-safety/program-architecture) and every policy in the 04 Policies set. In particular: [Policy - Internal Responsibility and Accountability](https://thehumanfactor.ca/library/fire-service-safety/policy-internal-responsibility-and-accountability), [Policy - Risk Management and Hazard Assessment](https://thehumanfactor.ca/library/fire-service-safety/policy-risk-management-and-hazard-assessment), [Policy - Program Review and Continuous Improvement](https://thehumanfactor.ca/library/fire-service-safety/policy-program-review-and-continuous-improvement), [Policy - Records, Privacy and Health Information](https://thehumanfactor.ca/library/fire-service-safety/policy-records-privacy-and-health-information), [Respiratory Protection Program](https://thehumanfactor.ca/library/fire-service-safety/respiratory-protection-program), [Protective Clothing and Equipment Program](https://thehumanfactor.ca/library/fire-service-safety/protective-clothing-and-equipment-program), [Decontamination and Contamination Control Program](https://thehumanfactor.ca/library/fire-service-safety/decontamination-and-contamination-control-program), [Emergency Operations Safety Program](https://thehumanfactor.ca/library/fire-service-safety/emergency-operations-safety-program), [Incident Investigation and Learning Program](https://thehumanfactor.ca/library/fire-service-safety/incident-investigation-and-learning-program), [Medical, Fitness and Wellness Program](https://thehumanfactor.ca/library/fire-service-safety/medical-fitness-and-wellness-program), [Psychological Health and Safety and Peer Support Program](https://thehumanfactor.ca/library/fire-service-safety/psychological-health-and-safety-and-peer-support-program).

## 8. Records, confidentiality and disclosure

8.1 Records created under this policy: the signed Part A statement with posting log; the consultation record; the legal requirements register and compliance evaluation; management review minutes; the annual health and safety report to council.

8.2 All are written for disclosure under municipal freedom-of-information law, identify people by role, and contain no personal health information. Governed by [Policy - Records, Privacy and Health Information](https://thehumanfactor.ca/library/fire-service-safety/policy-records-privacy-and-health-information) and [05 Document Control and Records](https://thehumanfactor.ca/library/fire-service-safety/document-control-and-records).

8.3 The Part A statement is a public document. The policy proper is available to every member and to the JOHSC, and to any member on request.

## 9. Reporting

| Report | From | To | When |
|:---|:---|:---|:---|
| Safety performance indicators | {{Health and Safety Officer}} | JOHSC; operations meeting | Monthly |
| Program quarterly updates | Program managers | Senior team; JOHSC for information | Quarterly |
| Compliance evaluation and audit results | {{Division Chief, Safety}} | Fire chief; JOHSC | Annually, before the management review |
| Management review outputs | {{Fire Chief}} | All members; JOHSC; CAO | Annually |
| Annual health and safety report | {{Fire Chief}} | Council | Annually |
| Safety-critical resource gaps | {{Fire Chief}} | CAO and council | As they arise, in writing |

## 10. Training requirements

| Role | Minimum training | Refresh |
|:---|:---|:---|
| Every member | Orientation to this policy and the safety management system (two hours); member duties; how to report; how to refuse and stop work | Annually, 30 minutes, and on material change |
| Every officer | Supervisor safety competency ([01 Roles and Responsibilities](https://thehumanfactor.ca/library/fire-service-safety/roles-and-responsibilities) section 7), 16 hours | Every three years and on change in law or program |
| Fire chief, deputy chiefs | Due diligence for senior officers, including Criminal Code s. 217.1, four hours | Every three years |
| JOHSC members | JOHSC member course as the statute and [02 JOHSC Integration](https://thehumanfactor.ca/library/fire-service-safety/johsc-integration) require | As the statute requires |
| Policy owner | Management-system fundamentals (ISO 45001 structure), one day | Every three years |

## 11. Legal and standards basis

- The applicable occupational health and safety statute and regulations: the written policy and written program requirements ([J03 OHS Policy and Program](https://thehumanfactor.ca/library/fire-service-safety/j03-ohs-policy-and-program)); employer, supervisor and worker duties ([J02 Duties of Employers, Supervisors, Workers and Contractors](https://thehumanfactor.ca/library/fire-service-safety/j02-duties-of-employers-supervisors-workers-and-contractors)); JOHSC provisions ([J05 Joint Committee and Health and Safety Representative](https://thehumanfactor.ca/library/fire-service-safety/j05-joint-committee-and-health-and-safety-representative)); written procedures and committee consultation on them ([J06 Written Procedures and Committee Consultation](https://thehumanfactor.ca/library/fire-service-safety/j06-written-procedures-and-committee-consultation)); the right to refuse and reprisal protection ([J07 Right to Refuse and Reprisal Protection](https://thehumanfactor.ca/library/fire-service-safety/j07-right-to-refuse-and-reprisal-protection)); reporting to the regulator ([J08 Incident Reporting and Investigation](https://thehumanfactor.ca/library/fire-service-safety/j08-incident-reporting-and-investigation)); record retention ([J09 Records Retention](https://thehumanfactor.ca/library/fire-service-safety/j09-records-retention)); the status of volunteers ([J11 Volunteer Firefighters](https://thehumanfactor.ca/library/fire-service-safety/j11-volunteer-firefighters)); protective equipment ([J13 Firefighter PPE and Protective Equipment](https://thehumanfactor.ca/library/fire-service-safety/j13-firefighter-ppe-and-protective-equipment)); workplace violence and harassment ([J26 Workplace Violence](https://thehumanfactor.ca/library/fire-service-safety/j26-workplace-violence); [J27 Workplace Harassment](https://thehumanfactor.ca/library/fire-service-safety/j27-workplace-harassment)); and psychological health and safety where the statute includes it ([J28 Psychological Health and Safety](https://thehumanfactor.ca/library/fire-service-safety/j28-psychological-health-and-safety)).
- The duty of persons directing work to take reasonable steps to prevent bodily harm [(Criminal Code \[CA\], 1985, s. 217.1)](https://thehumanfactor.ca/library/fire-service-safety/policy-occupational-health-and-safety#ref-criminal-code-ca).
- Leadership and commitment, the OH&S policy, roles, consultation and participation, legal requirements, compliance evaluation and management review (ISO 45001:2018, cl. 5.1 to 5.4, 6.1.3, 9.1.2, 9.3; CSA Z45001:19).
- The organizational statement, policy and risk management plan of the fire service health and safety standard [(NFPA 1550, 2024, ch. 6)](https://thehumanfactor.ca/library/fire-service-safety/policy-occupational-health-and-safety#ref-nfpa-1550).
- Psychological health and safety in the workplace (CSA Z1003-13); hazard identification and risk assessment (CSA Z1002:12).
- The CPSE/CFAI accreditation path. This policy and the system under it are written so that the department’s own records answer the accreditation criteria without a second set of documents: responsibility for the occupational health, safety and risk management programs assigned to named roles [(CPSE, 2019, criterion 11A.1)](https://thehumanfactor.ca/library/fire-service-safety/policy-occupational-health-and-safety#ref-cpse-2019); policies and procedures for reporting, evaluating, addressing and communicating hazards and unsafe conditions [(CPSE, 2019, criterion 11A.2)](https://thehumanfactor.ca/library/fire-service-safety/policy-occupational-health-and-safety#ref-cpse-2019); documented steps taken to reduce risk and address identified hazards [(CPSE, 2019, criterion 11A.3)](https://thehumanfactor.ca/library/fire-service-safety/policy-occupational-health-and-safety#ref-cpse-2019); a formal, documented appraisal at least annually of the wellness and fitness program’s effectiveness [(CPSE, 2019, criterion 11B.6)](https://thehumanfactor.ca/library/fire-service-safety/policy-occupational-health-and-safety#ref-cpse-2019); the community risk assessment and standards of cover that make staffing a safety control [(CPSE, 2019, Category 2)](https://thehumanfactor.ca/library/fire-service-safety/policy-occupational-health-and-safety#ref-cpse-2019); and the human resources criteria on orientation, recognition, corrective action, succession and the harassment policy [(CPSE, 2019, Category 7)](https://thehumanfactor.ca/library/fire-service-safety/policy-occupational-health-and-safety#ref-cpse-2019). The 11th edition applies to agencies appearing from 2027 and keeps the 11-category structure with more weight on mental health, wellness and labour-management interaction [(CPSE, 2025)](https://thehumanfactor.ca/library/fire-service-safety/policy-occupational-health-and-safety#ref-cpse-2025).

## 12. Review and approval

12.1 The Part A statement is reviewed annually in consultation with the JOHSC, using the consultation loop in section 14, and re-signed if changed.

12.2 This policy is reviewed 12 months after adoption, then every three years; after any Tier 3 learning review, death or critical injury; after any change in the applicable statute or regulation; and whenever the JOHSC requests it in writing.

12.3 Each review records who was consulted, what changed, and why.

## 13. Adoption checklist

| Step | Lead | Done |
|:---|:---|:---|
| Complete [01 Program Profile Worksheet](https://thehumanfactor.ca/library/fire-service-safety/program-profile-worksheet) so scope and modules are known | {{Division Chief, Safety}} |  |
| Confirm your jurisdiction’s requirements on the topic pages listed under Jurisdiction requirements, and confirm every citation | Policy owner with counsel |  |
| Map role titles to [01 Roles and Responsibilities](https://thehumanfactor.ca/library/fire-service-safety/roles-and-responsibilities) section 6 | Policy owner |  |
| Circulate the draft to the JOHSC with the consultation booklet; set a four-week return date | JOHSC employer co-chair |  |
| Circulate to {{Union}} and {{Volunteer Association}} | {{Fire Chief}} |  |
| Counsel review | Municipal counsel |  |
| Fire chief signs Part A | {{Fire Chief}} |  |
| Council resolution or CAO signature | CAO |  |
| Post at every workplace; log the posting with date and location | Station officers |  |
| Orientation delivered to every member within 90 days | Training division |  |
| Policy entered in [05 Document Control and Records](https://thehumanfactor.ca/library/fire-service-safety/document-control-and-records) with review date | Policy owner |  |
| Review date in [04 Annual Program Cycle and Calendar](https://thehumanfactor.ca/library/fire-service-safety/annual-program-cycle-and-calendar) | Policy owner |  |

## 14. Consulting the JOHSC and bargaining agents

Consult early, in writing, with a deadline a month out. Circulate the draft with a short booklet: what the policy is, what changed, what the committee is being asked, and a feedback form. Discuss it at the next meeting; collect the responses through the employer co-chair; record what was accepted, what was not and why.

| They will ask | Honest answer |
|:---|:---|
| Is this just a poster? | Part A is the poster. Part B is enforceable policy with named accountable roles, a reporting table and a review cycle the audit scores. |
| Does “learning information is never used for discipline” mean nobody is ever held to account? | No. Conduct concerns (intentional harm, impairment, reckless disregard, criminal acts) go to a separate process run by different people. What is said in a debrief or a learning team is not that process’s evidence. |
| Will volunteers be treated the same? | Yes, for every purpose of the safety management system. [Policy - Volunteer Members](https://thehumanfactor.ca/library/fire-service-safety/policy-volunteer-members) says so, and [J11 Volunteer Firefighters](https://thehumanfactor.ca/library/fire-service-safety/j11-volunteer-firefighters) shows where each statute treats volunteers differently. |
| Who pays for committee time and training? | The department, as paid time or credited time for volunteers, as the statute requires. |
| What happens when the committee recommends something and the chief says no? | The chief answers in writing within the statutory time with reasons. The recommendation, the answer and any disagreement are recorded, and the item stays on the committee’s agenda. |
| Does the policy change the collective agreement? | No. Where they conflict, the agreement governs, and the department records the conflict for the next bargaining round. |

Put the consultation in writing. Where the department and the committee or bargaining agent still disagree after consultation, record the disagreement, adopt what can be adopted, and revisit at the 12-month review.

## 15. Customization and sector variants

> **Note: Customize**
>
> Decide: which role co-signs for the municipality (CAO, mayor or warden on resolution); the posting locations; whether the department adopts Part B as policy, SOG or directive; the department’s own policy number. Fill in every placeholder in double curly braces. Replace the generic role titles with the mapping in [01 Roles and Responsibilities](https://thehumanfactor.ca/library/fire-service-safety/roles-and-responsibilities) section 6.

> **Tip: Volunteer and composite departments**
>
> A volunteer department below the statutory program threshold still adopts both parts. Part A is cheap and it is the signal that matters. Where the department is a registered society rather than a municipal division, the society’s board signs where council would, and the municipality’s CAO signs as the registering authority if the registration agreement makes the municipality the employer; confirm with counsel.

> **Information: Delivery note**
>
> Read Part A aloud at the first all-members session. The ten commitments are the department’s promise, and the members will hold the chief to them. That is the point.

**Closing disclaimer.** This model policy is general information prepared by The Human Factor for licensed use by {{Department}}. It is not legal advice. Confirm every statutory reference with counsel 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 |
|:---|:---|:---|
| Duties of Employers, Supervisors, Workers and Contractors | Employer, supervisor and worker duties, and whether the statute states the internal responsibility system | [J02 Duties of Employers, Supervisors, Workers and Contractors](https://thehumanfactor.ca/library/fire-service-safety/j02-duties-of-employers-supervisors-workers-and-contractors) |
| OHS Policy and Program | The employee counts at which a written OHS policy and a written OHS program are required; how the policy is prepared, posted and reviewed; the elements the program must contain | [J03 OHS Policy and Program](https://thehumanfactor.ca/library/fire-service-safety/j03-ohs-policy-and-program) |
| Joint Committee and Health and Safety Representative | The committee threshold and composition, meeting frequency, paid time and training, and the time the employer has to answer a written recommendation | [J05 Joint Committee and Health and Safety Representative](https://thehumanfactor.ca/library/fire-service-safety/j05-joint-committee-and-health-and-safety-representative) |
| Written Procedures and Committee Consultation | When written procedures are required, and whether the committee must be consulted when they are made or changed | [J06 Written Procedures and Committee Consultation](https://thehumanfactor.ca/library/fire-service-safety/j06-written-procedures-and-committee-consultation) |
| Right to Refuse and Reprisal Protection | The right to refuse unsafe work, and the reprisal protection and complaint route | [J07 Right to Refuse and Reprisal Protection](https://thehumanfactor.ca/library/fire-service-safety/j07-right-to-refuse-and-reprisal-protection) |
| Incident Reporting and Investigation | Which deaths, serious injuries and dangerous occurrences must be reported to the regulator, how quickly, and who else must be told | [J08 Incident Reporting and Investigation](https://thehumanfactor.ca/library/fire-service-safety/j08-incident-reporting-and-investigation) |
| Records Retention | The default retention period for records the OHS law requires | [J09 Records Retention](https://thehumanfactor.ca/library/fire-service-safety/j09-records-retention) |
| Volunteer Firefighters | Whether volunteers are workers under the OHS statute and whether they count toward its thresholds | [J11 Volunteer Firefighters](https://thehumanfactor.ca/library/fire-service-safety/j11-volunteer-firefighters) |
| Firefighter PPE and Protective Equipment | Any regulation on the selection and use of protective equipment | [J13 Firefighter PPE and Protective Equipment](https://thehumanfactor.ca/library/fire-service-safety/j13-firefighter-ppe-and-protective-equipment) |
| Workplace Violence | Whether the workplace violence regulation applies to fire departments, and the program elements it requires | [J26 Workplace Violence](https://thehumanfactor.ca/library/fire-service-safety/j26-workplace-violence) |
| Workplace Harassment | Whether a written harassment policy is required, its required elements, and the training and review it needs | [J27 Workplace Harassment](https://thehumanfactor.ca/library/fire-service-safety/j27-workplace-harassment) |
| Psychological Health and Safety | Whether the statute defines health and safety to include psychological health and safety | [J28 Psychological Health and Safety](https://thehumanfactor.ca/library/fire-service-safety/j28-psychological-health-and-safety) |

## References

Center for Public Safety Excellence \[CPSE\]. (2019). *Fire and emergency service self-assessment manual* (10th ed.). Commission on Fire Accreditation International. <https://cpse.org/wp-content/uploads/2019/08/10th-Edition-FESSAM-Strikethrough-Underline-v.4.pdf>

Center for Public Safety Excellence \[CPSE\]. (2025). *Board approval of Fire and Emergency Service Accreditation Model updates (11th edition)* \[Web page\]. <https://www.cpse.org/accreditation/cfai10/>

Criminal Code, R.S.C. 1985, c. C-46 (Canada; consolidated to 2026-09-30; ss. 22.1, 22.2 and 217.1). <https://laws-lois.justice.gc.ca/eng/acts/c-46/>

CSA Group. (2012). *CSA Z1002:12 (R2022), Occupational health and safety: Hazard identification and elimination and risk assessment and control*. <https://www.csagroup.org/store/product/CAN-CSA-Z1002-12/>

CSA Group. (2013). *CAN/CSA-Z1003-13/BNQ 9700-803/2013 (R2022), Psychological health and safety in the workplace: Prevention, promotion, and guidance to staged implementation* (free to read from CSA Group and the Mental Health Commission of Canada). <https://www.csagroup.org/store/product/CAN-CSA-Z1003-13-BNQ%209700-803-2013/>

CSA Group. (2019). *CSA Z45001:19 (R2023), Occupational health and safety management systems: Requirements with guidance for use* (adopts ISO 45001:2018 with Canadian deviations). <https://www.csagroup.org/store/product/CSA%20Z45001:19/>

Edmondson, A. C. (1999). Psychological safety and learning behavior in work teams. *Administrative Science Quarterly, 44*(2), 350–383. https://doi.org/10.2307/2666999

Fire Engineering. (2023). *The NIOSH 5: Beyond firefighter LODDs*. <https://www.fireengineering.com/?p=571739>

Geczik, A. M., et al. (2024). An updated analysis of safety climate in the US fire and rescue service. *Injury Epidemiology, 11*, Article 19. <https://researchdiscovery.drexel.edu/esploro/outputs/journalArticle/An-updated-analysis-of-safety-climate/991021879760304721>

Ham, J. M. (1976). *Report of the Royal Commission on the Health and Safety of Workers in Mines*. Government of Ontario.

International Organization for Standardization. (2018). *ISO 45001:2018, Occupational health and safety management systems: Requirements with guidance for use*. <https://www.iso.org/standard/63787.html>

National Fire Protection Association. (2024). *NFPA 1550, Standard for emergency responder health and safety* (consolidates NFPA 1500, 1521 and 1561). <https://www.fire-police-ems.com/NFPA1550-2024.shtml>

National Institute for Occupational Safety and Health \[NIOSH\]. (n.d.-b). *Fire Fighter Fatality Investigation and Prevention Program* \[Program website and investigation reports\]. Centers for Disease Control and Prevention. <https://www.cdc.gov/niosh/firefighters/fffipp/index.html>

United States Fire Administration \[USFA\]. (2024b). *Firefighter fatalities in the United States in 2023*. Federal Emergency Management Agency. <https://www.usfa.fema.gov/downloads/pdf/publications/firefighter-fatalities-2023.pdf>
