A Working at Heights card answers only part of a manufacturing team’s recordkeeping question. The work might fall under Ontario’s construction rules, or it might require a different training record. Start with the activity, then connect each worker’s evidence to the equipment and work involved. Ontario’s training overview explains the approved training requirement for construction projects.
- Classify the work before assigning an approved course or a renewal period.
- Check both the approved program and approved provider for the Ontario training route.
- Track successful completion, expiry and planned refresher dates separately.
- Keep the underlying proof and system-specific instruction record accessible.
- Use the template as an index, with evidence behind every completed entry.
Start with the work, not the industry label
Section 6 of O. Reg. 297/13 covers workers required under the Construction Projects regulation to use travel restraint, fall restricting or fall arrest systems, safety nets, work belts or safety belts. For the Ontario training route, section 7 requires a Chief Prevention Officer-approved program delivered by an approved provider, with unexpired training. O. Reg. 297/13, sections 6 and 7.
A factory can also be the location of construction work. The Occupational Health and Safety Act’s definition includes alteration, repair, structural maintenance and machinery installation. Ontario’s Construction Health and Safety Program explains that definition. A plant expansion or equipment installation therefore deserves a scope check; the word “maintenance” on a work order is not enough to settle the classification. Contractor involvement does not, by itself, resolve it either.
For a practical recordkeeping process, record the task being evaluated, where it will happen and who confirmed the applicable requirements. Keep unresolved classification questions with the work planning record. This article cannot determine the governing regulation for a particular shutdown, repair or contractor assignment from a short task description.
There are specific exceptions and alternative routes. The regulation recognizes prescribed Newfoundland and Labrador training. Ontario's training overview adds that workers with WorkplaceNL fall protection training must also complete basic occupational health and safety awareness training and site-specific fall protection system training before working at heights on an Ontario construction project, and that the employer keeps a copy of the WorkplaceNL certificate. Its automobile exemption depends on both the workplace activity and direct employment by the automobile manufacturer or assembler that owns and operates that workplace. It is not a blanket exemption for parts suppliers or contractors. Check the complete conditions in section 7.
Industrial fall-protection instruction is a separate question
Outside the construction requirements, do not turn “approved Working at Heights course not required” into “training not required.” Where Regulation 851 applies, section 79 requires instruction and training in the care and use of required protective clothing, equipment or devices before use. That includes the protective equipment relevant to the task. Regulation 851, section 79.
Keep the applicable industrial instruction identifiable in your records. As a recommended structure, distinguish the equipment, care and use covered, instruction date, instructor and any assessment evidence. Do not automatically apply the construction program’s three-year renewal cycle to every industrial fall-protection entry. Establish the applicable requirements first, then document the review or retraining decision.
Keep foundational and system-specific evidence together
For construction work, a valid foundational course does not replace training on the system being used. Section 26.2 of O. Reg. 213/91 requires adequate training and oral and written instructions from a competent person. The employer must ensure the trainer prepares and signs an individual written record identifying the worker and training dates, and must make it available to an inspector on request. O. Reg. 213/91, section 26.2.
Ontario’s fall-prevention guidance treats foundational training and instruction on the specific fall-protection system as separate requirements. Organize them as separate evidence items linked to the same worker. A generic “fall protection complete” entry makes it difficult to see which requirement was actually addressed.
For example, use one entry for the approved course and another for the relevant project system instruction. Describe the second entry precisely enough that a reviewer can distinguish it from a course certificate. This is a suggested filing approach, not a prescribed software format.
Record completion and plan the refresher
The normal validity period for Ontario-approved training is three years from successful completion. Ontario’s guidance says successful refresher training provides another three years of validity. Eligibility requires previous successful completion of both the basic theory and practical modules; check eligibility with the approved provider. Ontario training overview.
The program standard, sections 11.1 and 11.2, describes refresher training as successful completion of the practical module under the program and provider standards. Its renewed three-year period starts from successful refresher completion. Booking a place is therefore different from recording a completed refresher.
Do not mark expired training valid because a refresher is booked. Keep three dates visible: the actual successful completion date, the verified expiry date and the planned refresher date. A booking can help schedule work, but should remain pending until completion evidence is received. For the recognized Newfoundland and Labrador route, use the expiry shown on the WorkplaceNL proof rather than imposing the Ontario calculation. Ontario training overview.
As an internal practice, choose a reminder lead time that fits course availability and work planning. Assign someone to resolve missing or inconsistent dates. Keep the earlier evidence when adding a refresher record so the history remains understandable.
Keep the required record behind the tracker
For the Ontario-approved route, section 10 requires the worker’s name, approved provider’s name, successful completion date and approved program’s name. The employer must retain a record and make it available to an inspector on request; CPO-issued completion proof can serve as that record. O. Reg. 297/13, section 10.
Ontario also explains how employers can check proof, including ministry verification with worker consent. If evidence is missing, resolve that gap through the published verification or replacement process. An internal spreadsheet status should not stand in for missing proof. Ontario training overview.
Use the tracker as an evidence index
The CSV provides the following working fields. Keep the evidence location meaningful to the people responsible for reviewing it.
| Template field | Recommended use |
|---|---|
| Employee | Match the worker’s name to the completion proof. |
| Employee number | Use an internal identifier to distinguish similar names. |
| Role | Give reviewers work context without treating a title as a scope decision. |
| Provider | Transcribe the provider shown on the proof. |
| Program name | The approved program's name exactly as shown on the proof of completion. |
| Program approval number | Copy an identifier only when supplied; do not guess one. |
| Training date | Record successful completion, not booking or payment. |
| Expiry date | Check against the applicable training route and evidence. |
| Refresher due | Record the planned completion deadline separately. |
| Evidence on file | Identify the actual proof or its controlled file location. |
The CSV includes a separate program-name column. Keep the underlying proof of completion containing the approved program’s name; an approval number is not a substitute. Treat this template as a tracking aid, not a standalone statutory record. Employee number, role and planning fields are practical additions.
Before relying on an entry, open its supporting file and check that it belongs to the correct worker and course. Confirm that another authorized reviewer can retrieve it. Use a clear pending status for unresolved evidence rather than filling an empty date with an estimate.
Download the tracker template.
What TrainGrid does and does not do
TrainGrid organizes employees, course assignments, completion records and supporting evidence in a training matrix. It is standard-agnostic: the organization defines the training requirements it needs to track. See the assignments and completions guide for the record workflow and evidence attachments.
TrainGrid is not a Working at Heights training provider and does not deliver the approved course. It does not approve providers, authenticate a ministry card or decide whether a task is construction work. Keep those checks connected to the underlying recordkeeping process. This CSV is a planning template, not a promise of training-history import into TrainGrid.