Electrical Safety Program Requirements in Canada

By Jeff MacKinnon, P.Eng., PE

Something that I have been thinking about lately is: What are the electrical safety program requirements in Canada.

OSHA covers all of the USA, and the minimum Electrical Safety Program requirements can be found here - 1910 Subpart S.

In Canada, the Canada Occupational Health and Safety Regulations, part VIII mentions written procedures a couple of times, but not very clear if this needs to be an electrical safety program, or just a couple of written checklists.

"the employer shall issue written instructions with respect to the procedures to be followed for the safe performance of that work"

from Canada Occupational Health and Safety Regulations

How about the provinces?

The rest of this article will have the various provincial regulations to find out what they say, and how clear they are regarding the requirement of an electrical safety program.

Newfoundland and Labrador

The Occupational Health and Safety Regulations in NL are pretty clear in the assumption that the employer has an electrical safety program in place. They mention it by name in two different places:

  • Low voltage electrical equipment - 482(2)
    • "Where it is not practicable to completely disconnect low voltage electrical equipment, work shall be performed in accordance with an electrical safety program in accordance with a standard acceptable to the minister that... "
  • Isolation and Lockout - 490(2)
    • "Where it is not practicable to completely isolate high voltage electrical equipment an employer shall conduct a formal hazard assessment and develop an electrical safety program that..."
From the NL Occupational Health and Safety Regulations

Newfoundland and Labrador appears to be very clear that they expect employers that interact with electrical equipment to have an electrical safety program. They mention it by name in two places, both having to do with the isolation of electrical equipment.

In section 484(2)(e) they even mention that current diagrams are required. These diagrams, in my opinion, don't just include the single line, but all control and protection infromation for the equipment. Many times the wiring and schematic diagrams for control panels are not updated after changes.

Nova Scotia

The Nova Scotia Occupational Safety General Regulations Part 11 covers electrical safety, but they don't mention an electrical safety program specically. In fact, the NS regulations are written in a fashion that makes it seem that working on energized equipment below 750V is NOT hazardous work. You read that correctly. Here is the quote from subsection 125(2)

125 (2) An employer shall ensure that no work is performed on an energized electrical installation rated at greater than 750 v phase to phase unless the competent person performing the work is accompanied by another competent person.

From NS Occupational Safety General Regulations on May 9, 2019

This is crazy! CSA Z462-2018 uses 30V as the threshold for whether the shock hazard exists, and if a shock hazard exists mitigation techniques need to be implemented to lower the risk. The shock protection boundaries start in at 30V in tables 1A and 1B. The only limiting distances mentioned in the NS regulations are for overhead lines, and they start at 750V.

From NS Occupational Safety General Regulations - Subsection 126(4), retrieved May 9, 2019

Prior to the 2018 version of CSA Z462, the threshold voltage was 50V, it was lowered to 30V; the 750V threshold that is implied to be a part of "Hazardous Work" is way too high. Wow.

I'm not done yet.

I have the two provinces that I do the majority of my work in covered. More to come as time allows.