Company Faces Significant Fine for Non-Compliance with OHSA

All Ontario employers have certain obligations with respect to drafting and implementing a policy and accompanying program on violence and harassment in the workplace, as set out in the Occupational Health and Safety Act.  An employer’s legal obligations were further expanded when the OHSA was amended in the Fall of 2016 via Bill 132; this legislation codified that an employee is entitled to be free from not just workplace harassment and violence but also specifically workplace sexual harassment (a concept that had previously only been articulated in the Ontario Human Rights Code. Bill 132 also mandated that workplace harassment and violence programs be implemented in concert with Health and Safety Committees, clearly set out an employer’s obligation to investigate complaints when they are notified of same, and clarified the obligations of the employer to report findings to involved parties to an investigation, amongst other amendments or additions to the existing structure in the OHSA.

A February 2017 decision of Justice of the Peace Gerald Ryan illustrates that the Ministry of Labour is actively seeking to enforce the obligations set out in the OHSA, and to use fairly significant fines as an enforcement measure where appropriate.  In this instance, an Oshawa-based security company had been inspected by the Ministry of Labour after an injury suffered by one of its employees.  As a result of that inspection, 10 orders were issued to the company, including orders to assess the risk of violence and harassment in the workplace, to prepare a policy and implement a program on workplace violence and harassment, and to ensure that its employees were adequately trained with respect to same.  The assigned Ministry of Labour Investigator conducted follow-ups as these orders became past due, ultimately issuing an order of non-compliance when it determined that 7 out of the 10 orders had not been complied with.  Justice of the Peace Ryan, in an ex parte hearing, agreed that the company had failed to comply with the orders, and proceeded to issue a $10,000.00 fine for each incident of non-compliance, for a total fine of $70,000.00.

The order demonstrates that the Ministry of Labour can and will use the power of monetary fines to ensure compliance with the legislation, and that employers who do not achieve full compliance can face real consequences for not doing so.

by Carly Dunster

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    interested, feel free to shoot me an e-mail.

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