Evaluation of the Occupational Health and Safety Program, 2026

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List of figures

Figure 1: Compliance and enforcement continuum
Figure 2: Main reason for not reporting the most serious incident of sexual harassment, non-sexual harassment or violence experienced over the previous 24 months
Figure 3: Minor and disabling injuries (in thousands), (Between 2016 and 2023)
Figure 4: Annual fatalities, 2016 to 2023
Figure 5: Percentage of proactive activities of total activities conducted by OHS officers by fiscal year (Between 2016 to 2017 and 2023 to 2024)
Figure 6: Number of violations under Part II of the Code per 1,000 employees by fiscal year (Between 2016 to 2017 and 2023 to 2024)
Figure 7: Number of awareness activities, by fiscal year (Between 2016 to 2017 and 2023 to 2024)
Figure 8: Share of employees who rated their knowledge of workplace health and safety rules as "good" or "very good" by sector
Figure 9: Employers’ awareness of occupational health and safety rights and responsibilities
Figure 10: Reasons for not using government sources of information by employees
Figure 11: Annual numbers of calls and inquiries received and returned by early resolution officers within 24h, by fiscal year (Between 2019 to 2020 and 2023 to 2024)
Figure 12: Employees’ experiences during filing complaint
Figure 13: Program logic model
Figure 14: Internal complaint resolution process (ICRP)

List of tables

Table 1: Management action plan- Recommendation 1
Table 2: Management action plan- Recommendation 2
Table 3: Management action plan- Recommendation 3
Table 4: Management action plan- Recommendation 4
Table 5: Budget overview and human resources (FTEs), by fiscal year (Between 2016 to 2017 and 2023 to 2024)
Table 6: Harassment and violence: fatalities and occurrences (Between 2021 and 2023)
Table 7: DIFR, (Between 2016 and 2023)
Table 8: Violations by source: complaints and inspections, by fiscal year (Between 2016 to 2017 and 2023 to 2024)
Table 9: Results of compliance and enforcement actions (AVCs and Directions), by fiscal year (Between 2016 to 2017 and 2023 to 2024)
Table 10: Assignments finalized within 120 Days (%), by fiscal year (Between 2016 to 2017 and 2023 to 2024)
Table 11: Complaints resolved within service standards (120 days)
Table 12: OHS program evaluation matrix
Table 13: DIFR between 2016 and 2023, by sector
Table 14: Number of violations from proactive inspection by Industry* between 2016 to 2017 and 2023 to 2024

List of abbreviations

AVC: Assurance of Voluntary Compliance
EAHOR: Employer Annual Hazardous Occurrence Reports
EAHVOR: Annual Harassment and Violence Occurrence Report
ESDC: Employment and Social Development Canada
GBA Plus: Gender-Based Analysis Plus
HSO: Health and Safety Officer
ICRP: Internal Complaint Resolution Process
IFFS: Interactive Fact-Finding Service
ILS: Integrated Labour System
IPGs: Interpretations, Policies, and Guidelines
KIIs: Key Informant Interviews
LP: Labour Program
MoU: Memorandum of Understanding
OHS: Occupational Health and Safety
OPDs: Operation Program Directives
PIP: Performance Information Profile
RIAS: Regulatory Impact Analysis Statement
ROC: Regional Operations and Compliance
SEFJ: Survey of Employees under Federal Jurisdiction
SIs: Senior Investigators

Executive summary

The Occupational Health and Safety (OHS) program promotes and sustains safe and healthy workplaces for employees under federal jurisdiction by preventing or reducing the incidence of workplace-related accidents and injuries, including occupational diseases. It aims to do so by creating tools that raise awareness of health and safety issues and by assisting employers and employees in federally regulated sectors understand their rights and responsibilities under Part II of the Canada Labour Code (hereinafter "the Code") and the Non-smokers' Health Act.

Labour Program health and safety officers ensure compliance with the Code through inspections and investigations, and by using a range of enforcement tools such as Assurances of Voluntary Compliance (AVC), directions, administrative monetary penalties (AMPs), and prosecutions.

Part II of the Code applies to employers within industries such as banking; rail, air, road and marine transportation; federal Crown corporations; broadcasting and telecommunications; postal and courier services; grain and feed operations; uranium mining and atomic energy; the federal public service and Parliamentary precinct; and other federally regulated workplaces, including the Royal Canadian Mounted Police (RCMP).

The evaluation assessed the Program's performance from April 2016 to March 2024, its effectiveness and achievement of outcomes, integrating evidence from both qualitative and quantitative lines. The evaluation was completed consistent with departmental priorities.

Key findings

Finding 1: Evidence shows that the Program contributes to improving workplace health and safety, and that recent legislative changes addressed key gaps and increased reporting of workplace harassment and violence incidents. However, challenges persist in ensuring regulatory clarity, and continuing reduction of workplace injuries and fatalities to meet the established targets.

Finding 2: Proactive inspections are the key driver of violation detection and are perceived as effective in promoting occupational health and safety. However, challenges in strategic targeting and execution of inspections persist mainly due to operational constraints.

Finding 3: Program awareness activities were significantly reduced during the evaluation period. Usability barriers, communication issues, and uneven workplace outreach limited the effectiveness of promotional activities and tools. 

Finding 4: Assurance of voluntary compliance (AVC) and directions are an effective tool to address contravention and achieve compliance, with most employers correcting violations following interventions. Prosecutions and AMPs are recognized as important enforcement tools but remain underutilized.

Finding 5: The Program meets its service standard for responding to inquiries within one business day and finalizing assignments within 120 days. However, it has faced challenges in resolving complaints within 120 days.

Finding 6: The Program uses administrative data to support and target proactive and reactive activities. Limitations in data quality, integration, and completeness hinder its effectiveness for proactive planning and strategic analysis.

Recommendations

Recommendation 1: Enhance inspectors and investigators' capacity to effectively apply enforcement tools across the distinct operational contexts in federally regulated sectors.

Recommendation 2: Improve the reach and effectiveness of proactive awareness tools, with a focus on usability, relevance, and delivery channels.

Recommendation 3: Explore ways to strengthen the collection, integration, and quality of administrative data to enable risk-based planning and performance monitoring, within a strategic framework for data management.

Recommendation 4: Improve timeliness in resolving complaints by exploring opportunities to address underlying factors that may influence delays.

Management response action plan

Overall management response

The Labour Program welcomes the findings of this evaluation. The overall conclusions confirm that the Occupational Health and Safety (OHS) program continues to play a critical role in promoting and maintaining safe and healthy workplaces across federally regulated sectors.

Covering the period from April 2016 to March 2024, the evaluation reflects a time of significant transformation for the OHS program. Throughout this period, the Program implemented major legislative and regulatory changes, including the introduction of Administrative Monetary Penalties, the coming into force of the Work Place Harassment and Violence Prevention Regulations, and the deployment of a new internal data management system. In parallel, the COVID‑19 pandemic created unprecedented challenges that required rapid adaptation to emerging scientific information, new legal considerations, and revised operational procedures.

The recommendations of this evaluation support the Program's ongoing commitment to continuous improvement. They will inform efforts to strengthen service delivery, reinforce the capability of a well‑equipped inspectorate, and further enhance the tools, data, procedures, and communications that underpin the effective enforcement of Part II of the Canada Labour Code.

The Labour Program will carefully assess each recommendation and consider the operational impacts of proposed changes, ensuring that any enhancements improve program effectiveness while minimizing unnecessary burden on workplaces. As part of this work, the Program will also examine opportunities to align its approaches with international best practices in occupational health and safety, supporting a modern and forward‑looking regulatory framework.

In addition, the Government of Canada's Comprehensive Expenditure Review (CER) may influence the prioritization and sequencing of future actions. The CER process also presents opportunities to streamline activities, strengthen internal efficiencies, and ensure the Program continues to deliver value for Canadians.

Through these efforts, the Labour Program will refine and modernize its approaches, ensuring that the OHS program meets its objectives and supports safe and healthy workplaces for all federally regulated employees.

Recommendation 1

Enhance inspectors and investigators' capacity to effectively apply enforcement tools across the distinct operational contexts in federally regulated sectors

Management response:

The Labour Program agrees with this recommendation.

Effective enforcement is fundamental to improving compliance with occupational health and safety legislation and, in turn, fostering safer workplaces. Part II of the Canada Labour Code is supported by a graduated suite of enforcement tools, applied in proportion to the seriousness of the violation and the level of cooperation demonstrated by the workplace.

Since the introduction of Administrative Monetary Penalties (AMPs) in 2021, the Labour Program has updated its procedures to strengthen its approach to achieving compliance. A review of related procedures and guidance is currently underway to ensure inspectors and investigators can apply enforcement tools consistently, confidently, and in alignment with program expectations. The Program will also continue to refine and adapt its enforcement strategies to address sector‑specific operational contexts, emerging risks, and evolving workplace realities.

**Table 1: Management action plan- Recommendation 1**
Management action plan	Planned completion date	Accountable lead(s)
1.1 Conduct a comprehensive review and update of enforcement procedures, including guidance for AVCs, Directions, AMPs, and Prosecutions, to strengthen clarity and consistency in their application across operational contexts. This work will incorporate insights from recent training pilots and align enforcement expectations with updated program policies and sector specific requirements.	2027 April	Director General, Workplace Directorate
1.2 Strengthen the practical application of enforcement tools by updating training and coaching supports to emphasize real world practice, including scenario-based exercises, casework simulations, and coached application of enforcement tools. These improvements will build on recent training pilots and updated modules to ensure officers can confidently and consistently apply enforcement tools across the distinct operational contexts in federally regulated sectors.	2027 December	Director General, Workplace Directorate Director General, Regional Operations and Compliance Directorate

Recommendation 2

Improve the reach and effectiveness of proactive awareness tools, with a focus on usability, relevance, and delivery channels.

Management response:

The Labour Program agrees with this recommendation.

The Program is undertaking a comprehensive review of its outreach tools to strengthen their reach, usability, relevance, and overall effectiveness. This work aims to ensure that employers and employees in federally regulated workplaces have clear, accessible, and practical information to support compliance with occupational health and safety requirements.

As part of this effort, the Labour Program is modernizing its communication tools, enhancing its digital outreach capabilities, and expanding the use of event‑based education to improve awareness and access to information. The Program will also continue to use respectful and culturally appropriate communication when engaging with Indigenous clients and will incorporate feedback from Indigenous participants into future outreach materials.

The Labour Program will also continue to engage with key stakeholders-including employer and employee representatives, and federal, provincial, and territorial partners-through established mechanisms such as the Occupational Health and Safety Advisory Committee (OHSAC) and the Canadian Association of Administrators of Labour Legislation - Occupational Health and Safety (CAALL‑OHS). These platforms provide ongoing opportunities to exchange information, share best practices, and strengthen collaboration across jurisdictions.

**Table 2: Management action plan- Recommendation 2**
Management action plan	Planned completion date	Accountable lead(s)
2.1 Implement a National Proactive Strategy to strengthen outreach and engagement efforts and enhance the targeting of proactive inspections, including the identification of high-risk sectors. This strategy will support more consistent, risk-based planning and improve the effectiveness of proactive activities in promoting workplace health and safety across federally regulated sectors.	2027 March	Director General, Regional Operations and Compliance Directorate
2.2 Review and modernize OHS communication and outreach materials by improving usability, expanding availability in additional languages where appropriate, and updating content to reflect new regulatory and program guidance. These enhancements will strengthen awareness efforts, broaden reach, and support more accessible and relevant information for employers and employees across federally regulated workplaces.	2026 December	Director General, Workplace Directorate Director General, Regional Operations and Compliance Directorate
2.3 Strengthen the clarity and accessibility of OHS information by reviewing and updating Canada.ca content and implementing a cyclical review process to ensure pages remain current, user centred, and easy to navigate. These updates will improve usability and help employees and employers more easily find and understand the information they need to comply with occupational health and safety requirements.	2027 January	Director General, Workplace Directorate

Recommendation 3

Explore ways to strengthen the collection, integration, and quality of administrative data to enable risk-based planning and performance monitoring, within a strategic framework for data management.

Management response:

The Labour Program agrees with this recommendation.

Strengthening the quality and consistency of this data is essential to supporting risk‑based planning, informing strategic decision‑making, and improving the Program's capacity to monitor performance and outcomes across federally regulated sectors.

The Program has implemented a major update of its internal case management system that enhances its ability to collect, integrate, and leverage administrative data. Building on this foundation, the Labour Program is also exploring the development of modern digital tools and enhancing data management practices that would streamline processes and improve the completeness and reliability of data by advancing a more integrated and strategic approach to data management. This will allow the Program to be better positioned to monitor trends, identify emerging risks, and support continuous improvement in the delivery of the OHS program.

**Table 3: Management action plan- Recommendation 3**
Management action plan	Planned completion date	Accountable lead(s)
3.1 Develop a strategic data management framework that defines required data and analytical outputs and strengthens data governance-including a coordinated approach to information‑sharing agreements with provincial and territorial partners and improving integration of regulatory partner data to support a more complete picture of the federal jurisdiction. This will enhance data completeness and improve the Program's ability to support risk‑based planning and evidence‑informed decision‑making across federally regulated workplaces.	2027 September	Director General, Workplace Directorate Director General of Regional Operations and Compliance Directorate
3.2 Strengthen the quality, consistency, and reliability of administrative data by reviewing and modernizing data management processes, refining data tools and delivering targeted data‑management training programs to support accurate and standardized data entry. This will reduce data‑quality issues and improve the Program's ability to monitor trends, assess compliance, and support operational planning.	2027 December	Director General, Workplace Directorate Director General, Regional Operations and Compliance Directorate
3.3 Explore and implement digital and data integration solutions-such as improved linkages between internal datasets and enhanced mechanisms for collecting data from regulatory partners-to strengthen data completeness and analytical readiness. These solutions will support more efficient reporting processes and enable a more comprehensive understanding of workplace risks and compliance across the federal jurisdiction.	2028 March	Director General, Workplace Directorate

Recommendation 4

Improve timeliness in resolving complaints by exploring opportunities to address underlying factors that may influence delays.

Management response:

The Labour Program partially accepts this recommendation.

The Program disagrees in part with the statement that it has faced challenges in meeting its target for resolving 70% of complaints within 120 days. The Program consistently meets this service standard. While the service standard encompasses a range of case types-some of which are more complex and require additional time-the overall target continues to be achieved.

The Labour Program remains committed to continuous improvement and to ensuring that clients receive timely, efficient, and high quality services. To support this commitment, the Program is undertaking a review of its internal procedures for managing OHS complaints to assess their effectiveness and identify opportunities to enhance efficiency in complaint resolution. This work will help ensure that workflows remain responsive to program needs and evolving operational realities. The Program will also refine its performance measurement approach to strengthen meaningful monitoring and drive ongoing improvements in the timeliness and quality of complaint resolution. Together, these efforts will reinforce the Program's ability to manage complaints effectively across all case types.

**Table 4: Management action plan- Recommendation 4**
Management action plan	Planned completion date	Accountable lead(s)
4.1 Explore and implement digital solutions-such as the Online Employee Portal, the upgrade of case management system to the Cloud platform, and the internal chatbot-to streamline the OHS complaint process, improve workflow efficiency and transparency, and strengthen integration with existing program systems. This will support more timely, consistent, and user focused complaint resolution.	2027 September	Director General, Workplace Directorate
4.2 Review and update OHS service standards and performance indicators to ensure they reflect program realities and support meaningful monitoring, informed by ongoing work to refine expected outcomes and indicators through the Program's Logic Model. This work will follow the Program's planned review cycles-with service standards updated by 2027 and performance indicators refreshed in 2028-to ensure that monitoring approaches and service expectations remain current, appropriate, and aligned with legislative, regulatory, and program changes.	2028 March	Director General, Workplace Directorate Director General, Regional Operations and Compliance Directorate

Introduction

This report presents the findings of the evaluation of the Occupational Health and Safety program (OHS), or hereafter referred to the Program, administered by Employment and Social Development Canada (ESDC).

The last evaluation of the Program was completed in 2019. It covered the period from April 2011 to March 2016. This evaluation covers the period from April 2016 to March 2024 and examines the Program's performance, encompassing both effectiveness and efficiency.

This evaluation was conducted consistent with departmental priorities and addresses the following the key areas:

The legislative and regulatory changes to workplace health and safety
Conducting inspections and raising awareness (Proactive Activities)
Compliance and enforcement measures (Reactive Activities)
Timeliness in responding to complaints and inquiries
The use of administrative data for strategic enforcement

The evaluation employs a mixed-methods approach, integrating evidence from multiple lines of evidence including Literature Review, Document Review, Key Informant Interviews, Administrative Data Review, and online evaluation surveys of Employers and of Employees. Evidence from the 2022 Survey of Employees under Federal Jurisdiction conducted by Statistics Canada were also integrated into the evaluation framework. To enhance the validity of findings and mitigate potential biases, data triangulation was applied across all lines of evidence.

More details on the evaluation approach and lines of Evidence can be found in Annex A: Evaluation approach.

Program description

The Occupational Health and Safety program promotes and sustains safe and healthy workplaces for all federal jurisdiction employees by preventing or reducing the incidence of workplace-related accidents and injuries, including occupational diseases. It aims to do so by creating tools to increase awareness of health and safety issues and assisting employers and employees, in sectors under federal jurisdiction, to understand their duties and rights under Part II of the Canada Labour Code (hereinafter "the Code"), and the Non-smokers Health Act.

The Program is also responsible for the development and amendment of legislation and regulations under Part II of the Code, as well as the Non-smokers' Health Act. This work supports the goal of ensuring safe and healthy workplaces, while also helping them respond to the evolving needs of the workforce.

As of late 2023, 19,600 employers (1.4% of all employers in Canada) and 1,405,000 employees (7.9% of all employees in Canada) were covered under the Code. This employee count reflects an increase of about 15.2% from approximately 1,220,000 employees in 2016.

Compliance to occupational health and safety requirements is achieved through a range of activities, from increasing awareness to initiating prosecutions for non-compliance. The Program uses two approaches when ensuring compliance under Labour Code:

Proactive interventions: include education and awareness sessions, counselling, and inspections as a preventive measure in identified priority sectors.
Reactive interventions: include conducting investigations of all serious accidents, fatalities, complaints, and refusals to work.

Details on Program's activities, outputs, intermediate and immediate outcomes are outlined in the Logic Model (Annex B).

Part II of the Code is enforced by the following series of escalating actions, determined by the severity of the violation(s) and the co-operation of workplace parties:

Figure 1: Compliance and enforcement continuum - Text description follows — **Figure 1: Compliance and enforcement continuum**

Program governance

Two directorates within the Labour Program oversee the Occupational Health and Safety program:

The Workplace Directorate: Leads program design, delivery, guidance and policy interpretation. Develops supporting regulations and manages appeals of decisions made by the Regional Operations and Compliance Directorate.
The Regional Operations and Compliance Directorate: Ensures consistent implementation of compliance strategies and quality services to clients in federally regulated workplaces. Provides information to various stakeholders on provisions of the Code and investigates complaints.

Part II of the Canada Labour Code is enforced by approximately 90 active Health and Safety Officers (HSOs) and Senior Investigators (SIs). These officers are distributed across 16 office locations in five regions: Atlantic, Québec, Ontario, Central, and Northwest Pacific. The Labour Program Headquarters is located in Gatineau, Quebec, within the National Capital Region.

Budget overview (2016 to 2024)

Program expenditures have generally increased over the evaluation period, with actual spending consistently exceeding planned spending in most years.

**Table 5: Budget overview and human resources (FTEs), by fiscal year (Between 2016 to 2017 and 2023 to 2024)**
Fiscal Year	Planned Spending	Actual Spending	FTEs
2016 to 2017	$21.76M	$20.13M	207
2017 to 2018	$21.52M	$24.02M	205
2018 to 2019	$23.57M	$27.87M	205
2019 to 2020	$29.33M	$28.49M	200
2020 to 2021	$29.99M	$33.61M	223
2021to 2022	$31.93M	$35.02M	260
2022 to 2023	$30.44M	$32.49M	257
2023 to 2024	$30.44M	$31.16M	228

Source: Program documentation/Chief financial officer branch

Notable legislative and regulatory changes

Several legislative and regulatory changes were implemented since 2016 to contribute to occupational health and safety in workplaces under federal jurisdiction. These changes were designed to enhance protection from hazards, reduce harassment and violence, strengthen compliance and enforcement mechanisms, and clarify rights and responsibilities.

Amendments included:

June 2019:
- Modernized fall-protection: The regulations were updated to reflect modern industry standards, replacing outdated specifications. This includes clearer definitions of acceptable equipment and installation practices.
- Modernize respiratory protection requirements: Standards were revised to incorporate newly developed technologies and certifications, ensuring that equipment meets current safety benchmarks.
July 2019:
- Part II of the Code extended to parliamentary workplaces.
January 2021:
- Administrative monetary penalties (AMPs) were introduced to enforce compliance with regulations: Employers can face financial penalties for violations, adding a layer of accountability.
- Bill C-65 was implemented to address workplace harassment and violence: This replaced previous approaches with a unified system, requiring: mandatory training for employees, clear reporting procedures, and employer obligations to investigate and resolve incidents.
June 2021:
- Various amendments were made to ensure consistent language and authority/delegation across various regulations.
- Updates to confined spaces regulations: introduced a clear definition of "confined" and "hazardous confined" spaces, requiring employers to assess, document, and post signage for each space. They also mandated detailed entry procedures, emergency plans, and continuous monitoring,
May 2022:
- Amendments to ensure the provision of certified respiratory protective equipment: This change replaces previous general requirements with a specific obligation to use equipment that meets recognized certification standards, improving worker protection in hazardous environments.
December 2023:
- Employers are required to make menstrual products available to workers at no cost while they are in the workplace.

Key findings

Legislative and regulatory changes and workplace health and safety

Finding 1

Evidence shows that the Program contributes to improving workplace health and safety, and that recent legislative changes addressed key gaps and increased reporting of workplace harassment and violence incidents. However, challenges persist in ensuring regulatory clarity, and continuing reduction of workplace injuries and fatalities to meet the established targets.

Recent legislative and regulatory changes have addressed gaps, modernized safety standards, and strengthened compliance. Nonetheless, challenges persist regarding regulatory clarity, enforcement consistency, and practical application

A large majority of key informants interviewed (24 out of 29), including Employer and Employee Associations, Partner Organizations, and Program Officials highlighted that recent legislative and regulatory changes improved workplace health and safety by addressing gaps, modernizing outdated provisions, and strengthening compliance. The most frequently cited positive aspects included updates related to workplace harassment and violence, fall protection, confined spaces, and administrative monetary penalties.

Workplace Harassment and Violence Regulations (Bill C-65, 2021)
Some key informants (13 out of 29), including a Partner Organizations, Employee and Employer Associations, and Program Officials, highlighted Bill C-65 as a significant improvement for enhancing psychological safety, reducing the duration of unresolved cases, and ensuring structured employer responses. More specifically, these changes were recognized for introducing a clearer, more structured resolution process that replaced the outdated one. The new framework provides defined timelines, mandating resolution within one year, which has improved procedural fairness and reduced the emotional toll on complainants.

"....Previously, cases could remain open for years, affecting the mental health of complainants. The newly defined timelines benefit both employees and employers..."

-Key Informant Interviewee

Still, some key informants (12/29) including Employer and Employee Associations, and Program Officials also described the harassment and violence regulations as difficult to navigate and enforce:

They expressed a confusion regarding the role of the Program in addressing workplace harassment and violence, noting uncertainty about when and how the Program becomes involved in the process.
Concerns were also raised about the neutrality of investigations, as employers are selecting the investigator, which can undermine employee trust in the process. Although regulations require mutual agreement between the employer and the designated recipient, this is not always followed, particularly when employees are unaware of their rights or feel intimidated about challenging the employer's choice.
Also, investigations involve a cost for employers who do not always have the required resources or prefer to allocate it to addressing physical safety hazards.
Additionally, a lack of clarity and standardization in how harassment and violence claims are handled was also highlighted, which contributes to inconsistent application of the regulations across employers and limits the effectiveness of support mechanisms.

Fall Protection and Confined Spaces (June 2019)
Some key informants (10 out of 29), including Employer and Employee Associations and some Program Officials noted that updated regulations reflect current safety standards, clarify employer responsibilities, and help prevent serious injuries. The changes made these regulations more prescriptive and risk-based, helping employers better understand what is required to reduce exposure and prevent injuries. The fall protection amendments were seen as necessary to keep pace with evolving equipment and practices. Confined space regulations were viewed as clarifying previously ambiguous requirements, making it easier for employers to develop compliant safety programs. These improvements were described as realistic and implementable, and contributing to a more proactive safety culture.

On the other hand, a few key informants (4 out of 29), including Employer Associations and Program Officials highlighted barriers in relation to applying regulations related to confined spaces and fall protection:

The misalignment with provincial regulations and standards creates confusion, especially for organizations operating across jurisdictions, as definitions, signage requirements, and safety procedures often differ.
Challenges in interpreting federal guides and resources make it difficult to understand and apply confined space terminology correctly.
Fall protection regulations, particularly those related to "working at heights," were described as inconsistent and difficult to interpret.
conflicting standards and evolving definitions of safe working conditions have led to operational strain, delays, and uncertainty in compliance.

Administrative Monetary Penalties (AMPs) (January 2021)
Some key informants (9 out of 29) including Employer Associations, Employee Associations, and Program Officials viewed the new enforcement tool positively. AMPs were described as a flexible enforcement mechanism that bridges the gap between a formal written order (Directions) and prosecutions, encouraging timely corrections of contravention or dangerous condition through financial consequences for non-compliance. The financial implications of AMPs were seen as a strong motivator for employers to adhere to health and safety regulations.

Some key informants (12 out of 29), including Employee Associations, and Program Officials, pointed to ambiguity in interpreting recent legislative changes in relation to AMPs:

AMPs were frequently described as complex, inconsistently enforced, and difficult to apply in practice, due to the intricate administrative processes involved and the multiple layers of required approvals.
The training materials provided were not very helpful so far, leaving compliance officers without the necessary guidance to implement the penalties effectively.
In practice, AMPs were often avoided and not applied in a way that meaningfully influenced employer's behavior.

"…I believe the introduction of AMPS could enhance health and safety by providing an additional compliance tool. However, in my view, the Labour program was not fully prepared to implement it operationally, and even now, nearly four years later, it still appears unready..."

-Key Informant Interviewee

Potential legislations/regulations or changes needed - What we Heard

During interviews, a majority of key informants (16 out of 29), including all Partner Organizations and several representatives from employer and employee associations, as well as program officials, identified key areas for improving and further modernizing occupational health and safety (OHS) regulations in federally regulated workplaces.

A focus was placed on psychological health and safety, with 6 informants calling for clearer legislative language, proactive measures, and stronger accountability.
Another 6 informants emphasized the need to modernize technical safety standards, citing outdated regulations in areas such as electrical systems, scaffolding, and ergonomics.
Four (4) informants highlighted the importance of addressing emerging workplace hazards linked to new technologies like AI and nanoparticles.
Additionally, 3 informants raised concerns about climate-related risks, such as extreme weather and poor air quality, advocating for updated regulations to reflect these environmental challenges.
Lastly, 3 informants pointed out gaps in the legal framework regarding workplace access for non-employees, calling for clearer definitions in the Canada Labour Code to ensure consistent safety protections for all individuals present.

The Program has made progress in increasing the reporting of workplace harassment and violence incidents. However, some employees may still choose not to file complaints due to fear of negative consequences and limited trust in the employer's response and resolution processes

One of the Program's key objectives is to enhance the reporting of workplace harassment and violence (H&V) incidents by employers. This is reflected in the 2018 Performance Information Profile (PIP), where the number of reported H&V incidents serves as an indicator of progress toward the ultimate outcome: "workplaces are safer and healthier." Although no specific target is set for this indicator, the Program anticipated a medium-term increase in reported incidents (up to FY 2024 to 2025), followed by a long-term decrease (after FY 2025 to 2026), as awareness, prevention, and compliance improve.

Recent data from the "Annual Reports-Taking Action Against Harassment and Violence in Workplaces Under Canadian Federal Jurisdiction" supports the initial anticipated upward trend.

Following the implementation of the 2021 Workplace Harassment and Violence Regulations, reported occurrences in federally regulated workplaces have increased significantly. Between 2021 and 2023, total reported incidents rose from 4,950 to 7,114, a 33% increase. Incidents of sexual harassment and violence more than doubled, from 447 to 1,029, while fatalities remained rare, with 4 cases reported over the three-year period. This increase in reported cases of workplace harassment and violence reflects improved transparency and compliance with reporting requirements. However, it also highlights the ongoing need for employer support, effective enforcement, and proactive measures to address the root causes of workplace harassment and violence.

**Table 6: Harassment and violence: fatalities and occurrences (Between 2021 and 2023)**
Year	Fatalities related to harassment and violence	Total number of harassment and violence occurrences	Change	Sexual harassment and violence occurrences	Non-sexual harassment and violence occurrences
2021	0	4,950	N/A	447	4,503
2022	3	6,226	+20.5%	722	4,915
2023	1	7,114	+12.5	1,029	6,060

Source: “Annual reports – Taking action against harassment and violence in workplaces under Canadian federal jurisdiction

To complement employer-reported data, the Program also draws on evidence from the 2022 Survey of Employees under Federal Jurisdiction (SEFJ), conducted by Statistics Canada. SEFJ indicators, while not tied to specific targets in the Program's Performance Information Profile, offer valuable insights into employee experiences and perceptions of workplace safety:

5.6% of employees, across 8 major industries and sectors in federal jurisdiction, experienced some form of harassment or violence in the workplace within the previous two years. Non-sexual harassment was the most common (73.6%), followed by sexual harassment (20.1%) and workplace violence (18.4%). Female employees (6.5%) working in the federal jurisdiction were more likely to report having experienced workplace harassment or violence compared to men (5.1%).

An intermediate outcome of the Program is to foster greater openness in workplaces to report incidents and file complaints related to harassment and violence. Evidence from the SEFJ indicates that significant barriers still exist when it comes to reporting workplace harassment and violence incidents.

Among employees who experienced workplace harassment and violence within the previous two years (5.6%), a majority of employee (64.4%) reported the most serious ones to their employer, while the others (35.6%) chose not to report the most serious incidents. The main reasons cited were fear of negative consequences (44.2%) and doubts about whether reporting the most serious incidents would make a difference (17%). Even among those who did report incidents, 62.7% expressed dissatisfaction with how their cases were resolved. These findings highlight persistent challenges in employer response and a lack of trust in existing reporting and resolution processes, which may hinder progress toward safer and more transparent workplaces when it comes to harassment and violence.

Figure 2: Main reason for not reporting the most serious incident of sexual harassment, non-sexual harassment or violence experienced over the previous 24 months - Text description follows — **Figure 2: Main reason for not reporting the most serious incident of sexual harassment, non-sexual harassment or violence experienced over the previous 24 months**

Reason for Not Reporting	Percentage
Afraid of negative consequences	44.2%
Did not believe it would make a difference	17.0%
Resolved the issue on their own	10.0%
Did not think the issue was serious enough	9.7%
Had concerns about the formal complaints process	5.8%
Other	3.6%
Changed jobs	3.0%
There was no specific reporting procedure	2.2%
Did not know what to do, where to go, or who to ask for help	2.2%
Person in authority found out about the behaviour in another way	1.6%
The persons responsible changed jobs	0.7%

Despite these challenges, SEFJ results suggest generally positive perceptions of workplace safety and employer compliance:

82.6% of employees under 8 major industries within federal jurisdiction "strongly agree" or "agree" that their workplace is safe, healthy, and free from harassment or violence.
77% of employees "strongly agree" or "agree" that their employer is doing enough to protect them from harassment and violence.

These indicators suggest that while there is room for improvement in reporting of harassment and violence incidents and associated resolution processes, a large majority of employees harbor an overall positive perception of workplace health and safety.

Despite an overall reduction in the number of workplace injuries, the Program did not meet its target of reducing the Disabling Injury Frequency Rate (DIFR) by 2% each year

The Program aims to reduce the number of workplace injuries and fatalities (Intermediate Outcome). The evaluation examined trends in overall number of workplace injuries and fatalities as well as the year-over-year percentage change in the DIFR to determine whether the Program's activities have contributed to measurable improvements in workplace safety.

Workplace injuries declined by 23% between 2016 and 2023

Total injuries decreased from 54,227 in 2016 to 41,668 in 2023, reflecting reductions in minor injuries^{Footnote 1} (from 34,063 to 22,801) and disabling injuries^{Footnote 2} (from 20,097 to 18,796), as shown in Figure 3. In 2023, the four industries with the highest share of reported disabling injuries were:

Road Transportation (36.2%)
Air Transportation (23.5%)
Federal Public Services, Public Service Departments and Crown Corporations (17.1%)
Postal Services and Postal Contractors (8.1%)

Changes in the number of workplace injuries between 2016 and 2023, at the industry level, confirmed a decreasing trend in all key industries, notably a 12% reduction in Road Transportation, 27% in Air Transportation, 6.6% in Federal Public Services and 53% in Postal Services. Continued monitoring and targeted efforts are needed to maintain these improvements.

Figure 3: Minor and disabling injuries (in thousands), (Between 2016 and 2023) - Text description follows — **Figure 3: Minor and disabling injuries (in thousands), (Between 2016 and 2023)**

Year	Minor Injuries	Disabling Injuries
2016	34	20
2017	28	20
2018	28	21
2019	26	21
2020	21	16
2021	20	16
2022	21	18
2023	23	19

Fatalities decreased during the pandemic years, likely due to reduced economic activity, and have since returned to levels similar to those observed before the pandemic

The count of fatalities in workplaces fluctuated during the evaluation period either consistently decreasing (from 2018 to 2021) reaching historically low levels during the pandemic and reverting back to pre-pandemic levels in 2022 and 2023 (Figure 4). In 2023, most fatalities were concentrated in the Road transportation sector and the Federal Public Service.

Figure 4: Annual fatalities, 2016 to 2023 - Text description follows — **Figure 4: Annual fatalities, 2016 to 2023**

Year	Number of annual fatalities
2016	67
2017	61
2018	79
2019	66
2020	49
2021	44
2022	67
2023	71

To further assess the effectiveness of the Program's efforts, it is useful to examine performance against its key metric: the Disabling Injury Frequency Rate. This indicator provides a standardized measure of injury trends across sectors and helps evaluate progress toward the Program's ultimate goal of reducing serious workplace injuries.

The Disabling Injury Frequency Rate (DIFR) has decreased over the evaluation period. However, the program did not meet its target of a 2% annual reduction, except during the pandemic years

The DIFR measures the number of disabling injuries per 1 million hours worked, allowing for meaningful comparisons across sectors and different economic environments by accounting for the scale of economic activity. The Program uses the annual percentage decrease in the DIFR to assess its performance toward its ultimate outcome: safe and healthy workplaces.

Between 2016 and 2023, the national DIFR in federally regulated workplaces declined from 9.13 to 7.7, a 15% reduction, largely influenced by the COVID-19 pandemic's impact on economic activity, workplace conditions, and staffing levels. As shown in Table 7: DIFR, (Between 2016 and 2023), DIFR increased in most years except for 2020, which saw a significant drop of 22.4% during the pandemic, and 2021, the recovery year, which recorded a modest 2.6% decrease. Despite the overall decline, the reduction did not meet the Program's target of a consistent 2% annual decrease.

In 2023, four sectors had DIFRs significantly above the national average of 7.77: Air Transportation (21.38), Postal Services (16.43), Road Transportation (19.24), and Longshoring and Port Operations (9.75). These sectors have consistently exceeded the national DIFR since 2016 highlighting persistent safety challenges in relatively higher-risk environments. Notably, the DIFR in Air Transportation increased from 16.1 to 21.4 translating in a 33% increase over this period, underscoring the need for targeted interventions in that industry. (See Annex E: DIFR between 2017 and 2023, by sector for additional details on DIFR).

**Table 7: DIFR, (Between 2016 and 2023)**
Year	DIFR	Change % (Target 2% decrease)
2016	9.13	N/A
2017	9.17	0.4%
2018	9.3	1.4%
2019	9.39	1.0%
2020	7.29	-22.4%
2021	7.1	-2.6%
2022	7.61	7.2%
2023	7.77	2.1%

Source: 2017-2023 Annual Reports - Occupational Injuries in the Canadian Federal Jurisdiction

Conducting proactive inspections and raising awareness (Proactive activities)

Finding 2

Proactive inspections are the key driver of violation detection and are perceived as effective in promoting occupational health and safety. However, challenges in strategic targeting and execution of inspections persist mainly due to operational constraints.

Proactive inspections are consistently prioritized and are effective in detecting violations. The Program consistently met its target of devoting 60% of its activities to prevention

Proactive inspections have been a sustained priority for the Program and are strongly associated with the detection of workplace violations. This approach aligns with published research, which has found that proactive and targeted inspections contribute to improved compliance and reductions in workplace injuries (Bouchard St-Amant, 2017^{Footnote 3}; Noack et al., 2020^{Footnote 4}).

One of the Program's outcomes is "Proactive and reactive compliance activities are effectively undertaken across federally regulated industries". To measure performance against this outcome, the Program targets devoting 60% of OHS activities to prevention. Administrative data confirm consistent allocation of resources towards proactive activities. Between 2016 to 2017 and 2019 to 2020, proactive activities represented 65%-70% of total activity, exceeding the Program's 60% target. After a temporary decline during the pandemic, the Program returned to this standard, with proactive activity reaching 70% in 2022 to 2023 and 68% in 2023-2024. In identified priority sectors, proactive activities fluctuated below the 80% target between 2019 to 2020 (68%) and 2022 to 2023 (79%), dropped to 55% in 2020 to 2021, and surpassed the target in 2023 to 2024 (82%).

Illustrative case study: Planning and scoping a proactive inspection

Jim, a Health and Safety Officer (HSO) prepared a proactive inspection at a federally regulated transportation facility, identified as part of a priority sector under Labour program. Pre inspection planning included confirming jurisdiction, defining scope and objectives, reviewing available safety information, and gaining an understanding of the facility’s operations and potential hazards. On site, Jim entered the workplace, requested a workplace committee representative to participate, examined conditions and records (for example, training, monthly inspection records, committee minutes, hazard prevention program, and preventive maintenance), and interviewed employees. Jim debriefed workplace parties and followed up in writing on any identified non compliance, consistent with the Program’s compliance policy and authorities under Part II of the Labour Code. Different enforcement measures might apply depending on the type of violation and history of employer.

Figure 5: Percentage of proactive activities of total activities conducted by OHS officers by fiscal year (Between 2016 to 2017 and 2023 to 2024) - Text description follows — **Figure 5: Percentage of proactive activities of total activities conducted by OHS officers by fiscal year (Between 2016 to 2017 and 2023 to 2024)**

Fiscal Year	Proactive Activities (%)	Target (%)
2016 to 2017	70%	60%
2017 to 2018	65%	60%
2018 to 2019	67%	60%
2019 to 2020	68%	60%
2020 to 2021	52%	60%
2021 to 2022	65%	60%
2022 to 2023	70%	60%
2023 to 2024	68%	60%

Proactive inspections were also the primary mechanism for identifying non-compliance, with 98%–99% of recorded violations detected through this approach in most years. A temporary decrease to 83% in 2020 to 2021 coincided with pandemic-related disruptions, after which detection rates returned to 99%, reinforcing the effectiveness of proactive inspections in assessing compliance with occupational health and safety legislations and regulations.

**Table 8: Violations by source: complaints and inspections, by fiscal year (Between 2016 to 2017 and 2023 to 2024)**
Fiscal Year (Date Initiated)	Violations from Proactive Inspection	Violations from Complaints	Proactive Inspection Hours
2016 to 2017	8,587	146	35,133
2017 to 2018	11,765	251	31,399
2018 to 2019	11,933	288	32,136
2019 to 2020	14,160	183	34,791
2020 to 2021	883	186	12,159
2021 to 2022	7,450	112	25,608
2022 to 2023	12,993	144	27,448
2023 to 2024	12,494	136	28,090

Source: Administrative Data, ILS and LA2000

Looking into hours allocated for inspection, they varied over time, with increases in some years not always resulting in more violations. For example, in 2022 to 2023, inspection hours rose by 1,840 compared to the previous year, and violations increased by 5,543. However, in 2023 to 2024, inspection hours increased again, and violations declined by 499. These shifts highlight that inspection outcomes are not solely determined by the time allocated. Industry-level data shows that Road Transportation and Air Transportation consistently accounted for the highest number of violations, contributing over 9,000 violations in 2022 to 2023 alone. In contrast, sectors such as Energy/Mining and Indigenous workplaces reported very few violations across all years, with totals of 15 and 201, respectively. This suggests that inspection effectiveness is shaped by how efforts are strategically targeted across industries. Returns may vary depending on the risk profile, compliance history, and nature of workplaces inspected, making the allocation of inspection resources just as important as the overall volume of activity. (See Annex F: Number of violations from proactive inspection by Industry* between 2016 to 2017 and 2023 to 2024 for additional details on violations by sector).

Considering that violations occur when employers do not comply with requirements set out under Part II of the Code, the Program collects data on the number of violations measured per 1,000 federally regulated employees as a key indicator for the Program's outcome "Employers comply with occupational health and safety legislation and regulations."

The rate of health and safety founded violations under Part II of the Canada Labour Code, measured per 1,000 federally regulated employees, has fluctuated in recent years. After peaking at 12 violations per 1,000 employees in 2019 to 2020, the rate dropped to 1 in 2020 to 2021, due in part to the temporary reduction in the scale of employers' operations and number of inspections during the Covid 19 pandemic. The rate rose again to 10 in 2022 to 2023 before declining to 9 in 2023 to 2024. Although the rate has been reverting back to historical pre-COVID levels, the rate stood within its target of no more than 9 violations per 1,000 employees pointing to improvements in compliance relative to fiscal years 2018 to 2019 and 2019 to 2020.

Figure 6: Number of violations under Part II of the Code per 1,000 employees by fiscal year (Between 2016 to 2017 and 2023 to 2024) - Text description follows — **Figure 6: Number of violations under Part II of the Code per 1,000 employees by fiscal year (Between 2016 to 2017 and 2023 to 2024)**

Fiscal Year	Number of Violations per 1,000 employees
2016 to 2017	8
2017 to 2018	10
2018 to 2019	11
2019 to 2020	12
2020 to 2021	1
2021 to 2022	6
2022 to 2023	10
2023 to 2024	9

Key informant interviews further support the role that proactive inspections play in supporting enforcement and compliance. A large majority of key informants (27 out of 29) including Partner Organizations, Employer Associations, Employees Associations, and Program Officials viewed inspections as effective in terms of:

Prompting corrective actions: When inspectors identify issues, employers are more likely to respond quickly and implement corrective measures. This immediacy was seen as essential to preventing accidents and maintaining safe working conditions.
Clarifying employer responsibilities: Inspections provide concrete examples and direct guidance. This clarity supports better compliance and reduces confusion about legal obligations.
Reinforcing the seriousness of safety requirements: The presence of inspectors signals that safety is a priority and that non-compliance has consequences. This was seen as a powerful motivator for organizations to maintain high standards and foster a culture of accountability.

Strategic targeting and execution of inspection activities face persistent operational constraints

The document review and interviews with Program Officials highlighted that the process for determining Occupational Health and Safety (OHS) inspections is guided by formal criteria, regional planning practices, but also officer discretion, resulting in variation in the process across and within regions.

The Regional Operations and Compliance (ROC) Strategic Operational Plan (2023 to 2024) indicates that the Labour Program is currently developing a National Proactive Plan to outline priority sectors, clarify the intent of proactive inspections, and define criteria for proactive work. The document also identifies ongoing challenges to proactive inspections related to the number of officers, experience levels, and the complexity of work. These issues are exacerbated by turnover and the redistribution of experienced staff for training, onboarding, and special projects.

Key informant interviews identified several factors that hinder the consistency, effectiveness, and reach of inspections. A large majority of key informants (26 out of 29) including Employee Associations, Employer Associations, Partner Organizations and Program Officials cited constraints faced by inspection. While not all informants spoke to every issue, the following themes emerged across the interviews:

Resource limitations: Insufficient human and financial resources, especially across large geographies, limit thorough and frequent inspections. The number of available personnel is insufficient to support regular inspections across large geographic areas, resulting in uneven coverage. Resource limitations further restrict travel to remote sites.
Training, recruitment, and inspector competency: There are limitations in the quality and content of training, including insufficient emphasis on sector-specific risks, inspection techniques, and regulatory interpretation. These gaps, combined with an increasing share of inspectors with lesser years of experience (due to high-turnover), were seen as contributing to inconsistent inspection practices and reduced capacity to address complex workplace hazards. The absence of quality assurance mechanisms further limits opportunities for continuous improvement and performance monitoring.
Inspection's focus and interpretation: There were instances where inspections emphasized minor issues over serious hazards, and where interpretations of occupational health and safety requirements varied by officers and across regions. This challenge is particularly relevant in complex or specialized industries, where understanding technical operations and machinery is essential for identifying high-risk conditions.
Geographical challenges: Geography poses a major barrier to effective inspections, especially in remote or rural areas where long travel times limit on-site presence. These challenges are more severe in large provinces, and in regional offices covering multiple provinces and territories.

Finding 3

Program awareness activities were significantly reduced during the evaluation period. Usability barriers, communication issues, and uneven workplace outreach limited the effectiveness of promotional activities and tools. 

The program utilizes a variety of tools and activities to promote and raise awareness about employers' responsibilities and employees' rights in terms of occupational health and safety (OHS), including:

Counselling sessions/Information sessions (for example open houses)
Published materials such as brochures, pamphlets, videos, and infographics
Online resources, including official websites and social media
Self-inspection tools
1-800 helpline
General inquiry email

Awareness strategies aim to promote occupational health and safety (OHS). Research suggests that awareness campaigns can moderately improve compliance (Tompa et al., 2016)^{Footnote 5}, and that tailoring outreach strategies to workplace characteristics, such as size and sector, is essential for effectiveness. Small and medium-sized enterprises (SMEs), in particular, are less likely to engage with traditional communication channels, highlighting the need for targeted approaches (Schulte et al., 2018)^{Footnote 6}.

Program's awareness activities decreased during the evaluation period

Administrative data comparison between the pre-pandemic baseline (2016 to 2017 through 2019 to2020) and recent figures (Between 2022 to 2023 and 2023 to 2024) points to a reduction in overall OHS awareness activities. Prior to the pandemic, annual sessions averaged 1,170, peaking at 1,238 in 2019 to 2020. In comparison, a total of 754 sessions were held in fiscal year 2022 to 2023 and 780 sessions in fiscal year 2023 to2024, close to a 40% reduction relative to the peak level observed in 2019 to 2020.

Figure 7: Number of awareness activities, by fiscal year (Between 2016 to 2017 and 2023 to 2024) - Text description follows — **Figure 7: Number of awareness activities, by fiscal year (Between 2016 to 2017 and 2023 to 2024)**

Fiscal Year	Number of Awareness Activities
2016 to 2017	1,199
2017 to 2018	1,087
2018 to 2019	1,158
2019 to 2020	1,238
2020 to 2021	534
2021 to 2022	968
2022 to 2023	754
2023 to 2024	780

A large majority of federally regulated employees (82%) across key sectors reported having good or very good knowledge of general safety rules. However, awareness of specific rights and responsibilities is lower among those who filed complaints or made inquiries to the Labour Program. Only 40% were aware of the internal complaint resolution process

Under Part II of the Canada Labour Code, employers are responsible for providing employees with the information, instruction, and training necessary to understand and exercise their occupational health and safety (OHS) rights and obligations. The Labour Program supports this by developing policies, tools, and guidance to help employers meet their obligations.

One of the program's outcomes is for employees to have a clearer understanding of and to be knowledgeable about their rights and obligations. Results from the 2022 Survey of Employees Under Federal Jurisdiction (SEFJ) on workplace health and safety conducted by Statistics Canada indicate that employees across eight major industries under federal jurisdiction in 2020^{Footnote 7} have a good personal knowledge of workplace safety rules. A large majority (82.1%) of federally regulated employees, of key sectors, rated their knowledge of workplace health and safety rules as "good" or "very good".

Figure 8: Share of employees who rated their knowledge of workplace health and safety rules as “good” or “very good” by sector - Text description follows — **Figure 8: Share of employees who rated their knowledge of workplace health and safety rules as “good” or “very good” by sector**

Sector	Percentage Rating Knowledge as "Good" or "Very Good"
Telecommunications and broadcasting	79%
Feed, flour, seed and grain	88%
Banks	84%
Courier and pipelines	78%
Maritime transportation	86%
Road transportation	83%
Rail transportation	87%
Air transportation	80%
All sectors	82%

A GBA Plus analysis explored whether self-reported knowledge of workplace safety rules varied across demographic groups. While differences were observed across language background and union coverage, the majority of respondents in all groups reported high levels of knowledge.

Gender: No significant differences were observed; both men and women reported similar levels of high knowledge (Good and Very good of 82%).
Union coverage: Non-unionized respondents reported higher knowledge (84% Good and Very good) than unionized respondents (77%), though all groups showed strong overall knowledge.
Language: Unilingual English and French speakers reported the highest knowledge (84% and 83% Good and Very good), followed by non-official language speakers (77%) and bilinguals (75%). Despite variation, most respondents across language groups reported high knowledge.

The survey also collects data for 1 key indicator monitored by the program: the percentage of employees who reported receiving training related to harassment and violence in the workplace^{Footnote 8}. According to the results, over 60% of employees in the federal jurisdiction indicated that they had received training within the past two years on how to prevent harassment and violence in the workplace.

In addition to reviewing evidence from the SEFJ, the evaluation conducted the 2025 Evaluation Survey of Employees who interacted with the Labour Program through complaints or inquiries. The survey aimed to assess their level of awareness regarding specific rights and responsibilities, particularly among those most likely to report barriers related to occupational health and safety.

When asked which specific rights and responsibilities they were aware of, respondents most frequently identified the following:

The right to refuse unsafe work (65%);
Employers must provide training on safety in the workplace (64%) and;
Employers must provide OHS information to employees (63%).

Other Employers related responsibilities with relatively high level of awareness among employees who were surveyed include:

Employers and employees must work together to resolve workplace health and safety issues (59%)
Employers must post regulations about safety and health representatives and committees (58%)
Employers must share records of hazardous substances (57%)

Among other employers' responsibility, awareness was lower for the internal complaint resolution process (40%) and supporting the selection of a health and safety representative or committee (51%). A few respondents (9%) indicated that they were not aware of any of the listed responsibilities.

Employers reported high self-rated awareness of OHS rights and responsibilities

According to results from the 2025 Evaluation Survey of Employers who engaged with the program, a large majority of employers (78%) reported high or very high general awareness of OHS rights and responsibilities.

More specifically, a large majority of respondents (more than 75%) reported that employers were aware of key responsibilities such as:

providing occupational health and safety (OHS) information to employees (85%)
posting OHS policies and regulations (82%), offering safety training (89%)
acknowledging employees' right to refuse unsafe work (89%), promoting collaboration between employers and employees to resolve health and safety issues (80%)
posting the Canada Labour Code
regulations about health and safety representatives and committees (both at 77%)

Meanwhile, a majority of respondents (between 72% and 75%) indicated employer awareness of responsibilities such as:

sharing records of hazardous substances (75%)
supporting the selection of health and safety representatives or committees (74%)
recognizing employees' specific responsibilities (74%)
maintaining an internal complaint resolution process (72%).

Figure 9: Employers awareness of occupational health and safety rights and responsibilities - Text description follows — **Figure 9: Employers’ awareness of occupational health and safety rights and responsibilities**

Awareness Level	Percentage
Very high	22%
High	56%
Moderate	19%
Low	3%

Barriers and systemic challenges limit the reach and effectiveness of awareness tools

Barriers and systemic challenges continue to limit the reach and effectiveness of occupational health and safety (OHS) awareness tools. According to the 2025 Evaluation Surveys of Employees and Employers, nearly all surveyed employers (98%, n=142) reported using Government of Canada or Labour Program sources for OHS information. In contrast, only 23% of employees (n=132) reported doing the same.

Among surveyed employees, the most frequently cited barriers to accessing Government of Canada or Labour Program OHS information, included lack of awareness and difficulty locating resources. Specifically, 28% of employees, who did not use Government of Canada resources, indicated they did not know where to find the information, while 26% were unaware that such information was available. Additional barriers included difficulty reaching the appropriate contact (17%), unclear communication (11%), insufficient or unhelpful guidance (11%), complexity or irrelevance of information (12%), and slow response times (8%). Smaller proportions reported distrust in government sources (6%), preference for industry or legal advisors (6%), and lack of suitable formats (3%).

Figure 10: Reasons for not using government sources of information by employees - Text description follows — **Figure 10: Reasons for not using government sources of information by employees**

Reason	Percentage
Info not in preferred language/format	3%
Preferred industry/legal sources	6%
Distrusted government info	6%
Slow response times	8%
Other reasons	9%
Poor communication with officers	11%
Guidance from officers was insufficient	11%
Info was too complex, inconsistent, or irrelevant	12%
Hard to reach Labour Program contact	17%
Unaware info was available from GC / Labour Program	26%
Didn't know where to find info	28%
Didn't know / No answer	29%

During interviews, a large majority of key informants (23 out of 29), including Partner Organizations, Employee and Employer Associations, and Program Officials cited issues that may have impacted the employee and employer's awareness of their rights and responsibilities. While not all informants spoke to every issue, the following themes emerged across the interviews:

Outdated or incomplete promotional materials: Brochures, pamphlets, and videos were described as outdated and lacking engaging formats, such as infographics, which could help simplify complex information and improve reach among diverse audiences.
Inconsistencies and gaps in information delivery by Program Officials: Information provided by the Program can sometimes be inconsistent or vague. Conflicting interpretations of regulations and limited access to interpretive guidance (for example Interpretations, Policies, and Guidelines) contribute to confusion and reduce trust in the program's messaging.
Resource constraints and capacity issues: Limited staffing, funding, and infrastructure were identified as key barriers to improving outreach. These constraints affect the frequency, quality, and customization of promotional efforts, making it difficult to maintain up-to-date materials and expand reach.
Limited reach and visibility of the Program: Many employers, especially small businesses, and those in remote or underserved areas, remain unaware of the program and its tools. Traditional outreach methods like mail-outs and phone calls have limited success, and the program's social media presence is considered weak.
Website usability and navigation issues: The Canada.ca website was described as difficult to navigate, with key resources buried or poorly organized. Even program officials reportedly struggle to locate materials, undermining the site's role as a central hub for occupational health and safety (OHS) information.
Access and reach of information: While materials may be relevant, they often fail to reach frontline workers, small business owners, and non-English/French speakers. The shift toward digital content has reduced access for those who rely on printed materials, and the lack of alternative formats limits access across diverse audiences.

Awareness gaps can affect the effectiveness of the Internal Complaint Resolution Process (ICRP)

The Internal Complaint Resolution Process (ICRP) is designed to empower employees to address workplace issues collaboratively and at the earliest possible stage. It aligns with the Labour Program's emphasis on proactive resolution mechanisms under Part II of the Canada Labour Code, which promotes employee participation and employer accountability in occupational health and safety matters. Annex C provides details on the ICRP.

While comprehensive statistics on employee awareness of the ICRP across federally regulated sectors are not readily available, the 2025 evaluation survey of employees found that only 40% of respondents (n=228) were aware of the process. Under the Code, employers are responsible for informing employees of their rights and responsibilities, including the steps involved in the ICRP.

A large majority of Key informants (22 out of 29), including Partner Organisations, Employee Associations, Employer Associations, and Program Officials, spoke to the importance of employee awareness of the ICRP's to ensure its effectiveness. They explained that awareness of the Informal Conflict Resolution Process (ICRP) is essential for maintaining a safe and healthy workplace. When employees are unaware of the process, they may wait until a problem becomes serious before taking action, often resorting to filing a formal complaint with the Labour program. However, if the ICRP has not been followed, the Labour program may be unable to intervene, resulting in delays and frustration. This not only prolongs the time needed to address the issue but can also allow potential hazards to persist. In contrast, when employees are aware of the ICRP, they are more likely to engage in early discussions with their employer as soon as they an OHS related issue. This leads to faster, more efficient resolution of issues, often with fewer resources and less disruption to the workplace.

Compliance and enforcement measures (Reactive Activities)

Finding 4

Assurance of Voluntary Compliance (AVC) and Directions are an effective tool to address contravention and achieve compliance, with most employers correcting violations following interventions. Prosecutions and AMPs are recognized as important enforcement tools but remain underutilized.

Illustrative Case Study: Enforcement Escalation Following a Complaint Investigation

Andy, an employee at a federally regulated trucking company submitted a formal complaint to the Labour program, alleging unsafe stacking of heavy materials in his workplace. The internal complaint resolution process was followed but did not resolve the issue, prompting referral to a Labour program Health and Safety Officer (HSO).

The HSO/investigator conducted an investigation of the complaint, focusing solely on the subject matter raised. Upon confirming a contravention, the officer issued an Assurance of Voluntary Compliance (AVC). This is a written commitment by the employer to correct the violation and submit a written confirmation or action plan by a specified date. The officer is not required to verify in person that the corrective actions have been completed, unless there is reason to believe the issue remains unresolved.

If the employer fails to complete the corrective actions outlined in the AVC, the officer will issue a Direction, a formal legal order requiring compliance within a specified timeframe. Continued non-compliance may result in an Administrative Monetary Penalty (AMP), a financial penalty that can be issued through a notice of violation, or in serious or persistent cases, the Labour program may initiate Prosecution with the Minister's consent.

Investigations are viewed as the foundation for compliance actions but face challenges

Investigations play a key role in ensuring compliance with Part II of the Canada Labour Code, as they allow Health and Safety Officers to examine specific incidents or complaints and determine whether corrective action is required. During interviews, a majority of key informants (16 out of 29), including representatives from Partner Organizations, Employee Associations, Employer Associations, and Program Officials, viewed investigations as effective in identifying non-compliance and uncovering root causes. These investigations were seen as helping employers take meaningful corrective actions, which in turn improve regulatory adherence and reduce future violations.

However, during interviews, a large majority of Key informants (24 out of 29), including Partner Organisations, Employee Associations, Employer Associations and Program Officials identified challenges that limit the effectiveness of investigations. While not all informants spoke to every challenge, the following themes emerged across the interviews:

Delays in the process: Staffing constraints, overlapping provincial and federal jurisdictions, as well as coordination challenges with external agencies, including coroner services and law enforcement, were noted as factors contributing to delays in initiating and completing investigations.
Inconsistent follow-through: Investigations do not always lead to corrective actions and opportunities for broader learning are often missed. The reactive nature of the process, combined with limited communication and information sharing, was seen as reducing the preventive potential of investigations.
Limitations in investigator training and capacity: The current training is too basic, lacking the depth needed to navigate complex workplace contexts or interpret regulations effectively. The absence of industry-specific content and limited exposure to complex cases were seen as barriers to skill development, especially in sectors with technical operations or specialized risks.
Outdated policies and guidelines: Outdated policies and unclear role definitions between inspectors and investigators were viewed as structural issues that undermine the coherence and effectiveness of the investigation process.

AVCs and Directions result in high rates of final compliance, but have limitations

Assurance of Voluntary Compliance (AVCs) and Directions are enforcement tools used by Health and Safety Officers as part of the Labour Program's approach to ensuring compliance with Part II of the Canada Labour Code. AVCs are written commitments by employers to correct identified violations voluntarily, while Directions are formal orders issued by health and safety officers requiring corrective action within a specified timeframe.

In relation to the Program's intermediate outcome "Employers comply with occupational health and safety legislation and regulations", administrative data show that AVCs and Directions are effective in achieving final compliance.

Between 2016 to 2017 and 2019 to 2020, most enforcement actions concluded through these measures resulted in employers being either "In Compliance" or having an "Action Plan Accepted". The number of employers found "Not in Compliance" declined from 23 in 2016 to 2017 to 5 in 2019 to 2020. This trend continued in 2022 to 2023 and 2023 to 2024, with 418 and 348 employers "In Compliance" respectively, and only 6 and 5 "Not in Compliance".

**Table 9: Results of compliance and enforcement actions (AVCs and Directions), by fiscal year (Between 2016 to 2017 and 2023 to 2024)**
Fiscal Year	Action Plan Accepted	In Compliance	Not in Compliance
2016 to 2017	143	372	23
2017 to 2018	173	400	10
2018 to 2019	153	338	5
2019 to 2020	160	363	5
2020 to 2021	76	109	1
2021 to 2022	100	231	6
2022 to 2023	202	418	6
2023 to 2024	176	348	5

Source: Administrative Data, ILS and LA2000

Key informant Interviews provided further insight on these tools.

Some Program Officials (6 out of 19) described AVCs as effective and non-confrontational, helping build trust and encouraging proactive compliance. AVC is viewed as an effective and non-confrontational approach, especially when employers are cooperative. AVCs are often used as a first step before escalating to more formal measures. The 6 Program Officials highlighted that AVCs are particularly useful in outlining contraventions and guiding employers with relevant regulatory information.

However, some key informants (14 out of 29) including representatives of Employee Associations, Employer Associations, and Program Officials noted that AVCs often lacked enforceability, particularly due to the absence of mandatory follow-up. This allows employers to ignore action plans without consequence. They shared that AVCs are only effective when employers are already willing to comply voluntarily. AVCs were also criticized for being overly administrative, repetitive, and burdensome, with limited added value.

Directions were also viewed as a strong compliance tool because of their formal nature and clear timelines, by some Program Officials (5 out of 19), but were also criticized by a few key informants (6 out of 29) including Program Officials and Employee Associations for procedural complexity and delays. They noted that the language in the Code can be vague or restrictive, making it difficult to issue directions with confidence. They also described the process of issuing directions as lengthy and bureaucratic, often requiring multiple layers of review and approval from senior investigators or program advisors which can discourage officers from using the tool and delay enforcement.

Prosecutions and AMPs are recognized as important enforcement tools but remain underutilized

Prosecutions represent the most formal enforcement mechanism under Part II of the Canada Labour Code, typically reserved for serious or repeated violations. Only 12 prosecutions were conducted during the evaluation period between 2016 to 2017 and 2023 to 2024.

Administrative Monetary Penalties (AMPs), introduced in 2021, are financial deterrents issued under Part IV of the Canada Labour Code to address non-compliance with occupational health and safety requirements. AMPs may be issued when voluntary compliance measures have been exhausted or when the severity or recurrence of a violation warrants earlier intervention.

Despite their potential, administrative data show that since AMPs were introduced in January 2021, 50 AMPs have been issued to date to 36 employers, with 8 of them with two or more AMPs. Of the total, 21 AMPs (45.7%) were fully paid, and the remaining AMPs were reported as unpaid. The unpaid AMPs reflect only the current status of payment and do not necessarily indicate unwillingness to pay.

During key informant Interviews, the majority of Program Officials (11 out of 19) indicated that AMPs fill a gap between Directions (formal written order) and Prosecutions. A direction might not be sufficient to enforce compliance, and prosecutions are too complicated and resource-intensive. They mentioned that AMPs can motivate compliance among less cooperative/resistant employers and encourage them to follow safety rules by applying financial pressure when other enforcement tools are ineffective. However, some Program Officials (9 out of 19) also noted that AMPs are underutilized and questioned its effectiveness due to:

Low penalty amounts: Program officials noted that AMPs amounts are often too small to act as meaningful deterrents, particularly for larger employers who may absorb the cost without changing their practices.
Procedural constraints: The use of AMPs is hindered by unclear policies, and a lack of standardized procedures, which reduce confidence in their consistent and fair application.
Insufficient training: Program officials highlighted gaps in training related to the use of AMPs, including limited guidance on when and how to apply them effectively, which contributes to underutilization.

A few Program Officials (4 out of 19) acknowledged that the risk of prosecutions is a deterrent for employers. However, the majority of Program Officials (10 out of 19) noted that prosecutions are rarely pursued due to their complexity, resource demands, and lengthy timelines. The process requires significant legal support and coordination, which limits its practical use within the Program's current operational capacity

The Program's timeliness in responding to complaints and inquiries

Finding 5

The Program meets its service standard for responding to inquiries within one business day and finalizing assignments within 120 days. However, it has faced challenges in resolving complaints within 120 days.

The Program responds to almost all inquiries within one business day, consistently meeting its service standard

As part of its modernization and service delivery improvements, the Program introduced formal service standards to improve responsiveness and transparency in client interactions. Service standards were developed and published in November 2018 as part of a broader strategy to address stakeholder concerns about timeliness and consistency in service delivery.

One of the key service standards focuses on responding to inquiries within one business day, reflecting the Program's commitment to accessible and timely support for federally regulated workplaces. Administrative data show that this standard is consistently met since fiscal year 2019 to 2020 (Figure 11). In 2022 to 2023, 98.9% of inquiries were returned within one business day, and while performance declined slightly in 2023 to 2024, it remained high at 94.4%.

Figure 11: Annual numbers of calls and inquiries received and returned by early resolution officers within 24h, by fiscal year (Between 2019 to 2020 and 2023 to 2024) - Text description follows — **Figure 11: Annual numbers of calls and inquiries received and returned by early resolution officers within 24h, by fiscal year (Between 2019 to 2020 and 2023 to 2024)**

Fiscal Year	1‑800 Calls Returned Within 1 Business Day	Emails & Referrals Returned Within 1 Business Day
2019 to 2020	96.8%	96.8%
2020 to 2021	99.5%	99.5%
2021 to 2022	98.8%	98.8%
2022 to 2023	98.9%	98.9%
2023 to 2024	94.4%	94.4%

The Program met its target for finalising assignments in 120 days

Assignments consist of every activity initiated and recorded in response to reactive action (for example investigating complaints, incidents) or proactive action (for example inspections, education) to identify or ensure compliance with the provisions of Part II and pursuant to Regulations of the Code. While some assignments are initiated in response to complaints, others may result from inspections, investigations, or educational activities. Assignments do not include activities with durations beyond the Program's control (for example prosecutions, appeals, and technical surveys). The Program has a service standard for finalizing assignments within 120 days.

Timely completion of complaints and assignments within service standards is a key component of service delivery in the Occupational Health and Safety (OHS) program. The 120-day program service standard reflects operational expectations for efficiency and responsiveness.

Administrative data indicate that performance against the 70%^{Footnote 9} target for completing assignments within 120 days from the Performance Information Profile (PIP) was met for almost all years except 2016 to 2017 (69%), and 2020 to 2021 (63%), the pandemic-affected year, with annual assignment totals ranging from 9,282 to 14,934.

While delays beyond the 120-day standard persist, they have become less frequent: between 2016 to 2017 and 2023 to 2024, 22% of assignments were finalized late, with 4% completed within 1 to 15 days of the deadline, 3% within 16 to 30 days, and 15% after more than 30 days. The proportion of assignments delayed by over 30 days dropped from 21% in 2016 to 2017 to 10% in 2023 to 2024, indicating stronger adherence to service standards and improved timeliness over time.

Looking at the type of assignments, those related to hazardous occurrences are the most delayed, with 85% taking more than 150 days to be completed, though they represent only 1% of total assignments. In contrast, assignments stemming from proactive inspections are among the timeliest, with 80% finalized within the 120-day service standard, and they account for 93% of total assignments. However, due to the high volume of proactive inspection assignments (93% of all assignments), they also make up the majority of delayed cases: 81% of all assignments completed beyond 150 days originated from proactive inspections.

**Table 10: Assignments finalized within 120 Days (%), by fiscal year (Between 2016 to 2017 and 2023 to 2024)**
Fiscal Year (Date Initiated)	Number of assignments^{Footnote 10}(N)	Assignments finalised within 120 days. (N)	Assignments finalised within 120 days. (%)	Assignments finalised within 120 and 135 days. (N)	Assignments finalised within 120 and 135 days. (%)	Assignments finalised within 135 and 150 days. (N)	Assignments finalised within 135 and 150 days. (%)	Assignments finalised above 150 days. (N)	Assignments finalised above 150 days. (%)
2016 to 2017	9,282	6,360	69%	545	6%	437	5%	1940	21%
2017 to 2018	12,623	8,982	71%	520	4%	622	5%	2499	20%
2018 to 2019	12,881	10,104	78%	569	4%	311	2%	1897	15%
2019 to 2020	14,934	12,642	85%	425	3%	275	2%	1592	11%
2020 to 2021	1,363	865	63%	62	5%	14	1%	422	31%
2021 to 2022	8,046	6,409	80%	108	1%	179	2%	1350	17%
2022 to 2023	13,837	10,732	78%	648	5%	341	2%	2116	15%
2023 to 2024	13,516	11,155	83%	667	5%	361	3%	1333	10%

Source: Administrative Data, ILS and LA2000

Timeliness in resolving OHS complaints has improved over time but continues to be affected by staffing constraints, case complexity, and external dependencies

A 120-day service standard applies to complaints, with an annual target of resolving 70% of complaints within that timeframe.

The complaint filing process is a key point of interaction between employees and the Occupational Health and Safety (OHS) program. Under Part II of the Canada Labour Code, employees are entitled to a process that is fair, timely, and responsive.

Complaints related to occupational health and safety typically begin with the Internal Complaint Resolution Process (ICRP), where employees report concerns to their supervisor. If the issue remains unresolved, it is escalated to the workplace health and safety committee or representative. If the internal process does not lead to resolution, the complaint may be referred to a Labour Program health and safety officer, who verifies procedural compliance and investigates further. At this stage, a case assignment is created in the system and must be finalized within 120 days. Annex C provides a full description of the complaint resolution process.

Administrative data indicate that the Program did not meet its target of resolving complaints within 120 days in any of the years but 2023 to 2024. As shown in table 11, number of resolved complaints increased from 41 in 2016 to 2017 to 399 in 2023 to 2024. Performance has improved over the evaluation period. In 2016 to 2017, only 28% of complaints were resolved within the 120-day timeframe, compared to 70% in 2023 to 2024.

While delays beyond the 120-day standard remain, the proportion of complaints resolved after 150 days dropped significantly from 53% in 2016 to 2017 to 21% in 2023 to 2024, suggesting improved responsiveness.

No major difference in delays is observed across complaint types.

During interviews, a majority of key informants (21 out of 29), including Partner Organizations, Employer Associations, Employees Associations, and Program Officials noted that the ability to process occupational health and safety (OHS) complaints in a timely and effective manner is influenced by a combination of structural, procedural, and contextual challenges. While not all informants spoke to every challenge, the following themes emerged across the interviews:

Resource limitations and staff challenges: Staffing constraints, heavy workloads, and gaps in training were commonly mentioned as factors that may reduce the program's ability to handle complaints efficiently. Workforce pressures, turnover, and limited specialized expertise could also affect responsiveness.
Workplace relationships: Strained employee-employer relationships may slow down investigations and make resolution efforts more difficult.
Complex cases and external dependencies: Resolving complaints involving complex cases may be delayed due to reliance on external reports (such as law enforcement, health professionals, and other external partners) which are outside the program's control.

**Table 11: Complaints resolved within service standards (120 days)**
Fiscal Year (Date Initiated)	Number of complaints (N)	Complaints resolved within 120 days.(N)	Complaints resolved within 120 days (%).	Complaints resolved Within 120 and 135.(N)	Complaints resolved Within 120 and 135.(%)	Complaints resolved Within 1135 and 150.(N)	Complaints resolved Within 135 and 150.(%)	Complaints resolved above 150.(N)	Complaints resolved above 150.(%)
2016 to 2017	146	41	28%	18	12%	10	7%	77	53%
2017 to 2018	251	114	45%	11	4%	6	2%	120	48%
2018 to 2019	290	109	38%	26	9%	16	6%	139	48%
2019 to 2020	184	70	38%	21	11%	2	1%	91	49%
2020 to 2021	282	130	46%	3	1%	9	3%	140	50%
2021 to 2022	388	181	47%	8	2%	21	5%	178	46%
2022 to 2023	473	263	56%	15	3%	14	3%	181	38%
2023 to 2024	568	399	70%	30	5%	17	3%	122	21%

Source: Administrative Data, ILS and LA2000

Among employees for whom the Internal Complaint Resolution Process did not lead to a resolution and who subsequently filed a formal complaint to the Labour Program, satisfaction with the complaint process is low, particularly regarding fairness, timeliness, and employer responsiveness

When asked about their satisfaction with the formal complaint process, respondents to the 2025 Evaluation Survey of Employees^{Footnote 11} reported low levels of satisfaction across seven assessed aspects of the complaint process.

A majority of respondents reported being "Not at all" satisfied with the employer's changes (60%), the overall process (54%), the fairness of the ruling (52%), and the timeliness of service (52%). Similarly high dissatisfaction was observed with the effort required (46%) and officers' assistance (44%).

Figure 12: Employees experiences during filing complaint - Text description follows — **Figure 12: Employees’ experiences during filing complaint**

Description of the experiment	Not at all	Slightly	Moderately	Mostly	Fully	Employee didn't know / preferred not to answer
Service was timely	52%	16%	12%	11%	8%	4%
Ruling was fair and accurate	52%	13%	9%	5%	9%	12%
Employer made changes	60%	12%	7%	3%	8%	15%
Satisfied with resolution process	54%	17%	7%	13%	6%	2%
Satisfied with officer assistance	44%	17%	13%	9%	13%	4%
Effort to resolve was reasonable	46%	16%	12%	14%	9%	3%
Paperwork was reasonable	23%	14%	18%	28%	12%	5%

The use of Program administrative data for strategic enforcement

Finding 6

The Program uses administrative data to support and target proactive and reactive activities. Limitations in data quality, integration, and completeness hinder its effectiveness for proactive planning and strategic analysis.

Administrative data plays a central role in the Program's compliance and enforcement activities. It is used to inform planning, prioritize interventions, and support compliance activities. Up to 2021, the Labour Program collected information on its activities using the LA2000 system. In fiscal year 2021 to 2022, the Labour Program migrated their data to a new system: Integrated Labour System (ILS).

Program Officials identified several benefits, including improved targeting and decision-making through tools like ILS and Power BI. However, persistent limitations in data quality, usability, and integration affect its usefulness for strategic analysis. Gaps in coverage, system flexibility, and connectivity with external sources were noted, along with the need for additional fields and indicators to strengthen analytical capacity.

Administrative data is used to support proactive and reactive planning

Best practices for using administrative data in compliance and enforcement involve leveraging historical data and fostering collaboration. Evidence suggests that using archived data, such as that from LA2000, can guide prevention efforts. Historical data archived in LA2000 are useful for guiding the Labour Program's prevention efforts in the short term (until a better data collection mechanism is put in place), and more data should be abstracted from the archived reports. (Keefe et al., 2021^{Footnote 12}).

During interviews, a majority of Program Officials (13 out of 19), reported that administrative data, particularly from the ILS system, was actively used to prioritize interventions and support compliance with health and safety regulations. Examples include:

Proactive and Reactive Planning Using ILS Data: Historical employer data, site history, and annual reports were used to identify priority sectors and plan inspections. Integration of employer-specific data, such as past incidents and compliance history, enables more targeted interventions.
Usefulness of Power BI Reports and Data Visualization: Power BI reports generated from ILS data were viewed as valuable tools for monitoring, reporting, and supporting decision-making.
System Improvements Over Previous Tools: ILS was viewed as a superior database compared to previous tools, citing improved reporting and tracking capabilities.

Limitations in data quality, system usability, and integration constrain the effectiveness of administrative data for strategic planning

While administrative data is actively used for operational planning, evidence suggests that its current limitations in quality, completeness, and integration reduce its utility for more advanced strategic analysis.

During key informant interviews, a large majority of Program Officials (17 out of 19), identified challenges and gaps that limit the Program's ability to rely on administrative data for improving employer compliance with OHS legislation, including:

Data Quality and Data Gaps: The accuracy, completeness, and reliability of data in the ILS system are key concerns. Information is often outdated, inconsistently entered, or missing. The system is limited to basic categories and lacks flexibility, for example, the inability to add new fields such as follow-up actions nor does it enforce mandatory data entry. There is a need for severity-level indicators to help build a more accurate historical profile of employers and to better inform inspection planning and investigation efforts.
System Usability and User Experience: ILS is difficult to use, with inefficient workflows. It also requires excessive manual input. The existence of multiple unsynchronized versions (for example Prod A and Prod B) was also reported as a source of confusion.
Data Coverage and Integration: Limited scope and lack of integration with other relevant data sources were highlighted. ILS does not provide a comprehensive list of employers or inspection histories and lacks connectivity with external databases such as workers' compensation boards or provincial systems.

“…I think ILS has produced several useful tools. However, the system itself isn’t very user-friendly. It feels like it was designed for a different purpose, and we've had to adapt labour’s needs to fit into it, rather than having something developed specifically for our use…”

-A program official

Administrative Data analysis revealed systemic limitations that affect the Program's ability to implement risk-based strategies and assess intervention impacts:

Limited Sociodemographic Data: While some basic information such as location and job title is collected, the absence of structured variables such as age, gender, and language, prevents meaningful Gender-Based Analysis Plus.
Data Integrity and Fragmentation Issues: Incomplete migration from LA2000 limits a consistent and complete historical view of employer compliance.
Disconnected Data on Administrative Monetary Penalties: The absence of links between penalty data and case files prevents systematic analysis of their effectiveness.

Recommendations

The following recommendations were developed based on key findings and evidence gathered during the evaluation. Each recommendation is mapped to the corresponding key findings to ensure transparency and traceability of the evidence base.

Recommendation 1: Enhance inspectors and investigators' capacity to effectively apply enforcement tools across the distinct operational contexts in federally regulated sectors.

Alignment of Findings to Recommendation 1:

Positive contributions to workplace health and safety were made during the evaluation period, but regulatory clarity and consistently reducing workplace injuries and fatalities remain challenges (Finding 1). Inspectors and investigators need stronger capacity to interpret and apply requirements consistently, as proactive inspections face operational challenges (Finding 2) and AMPs and prosecutions are underused due to the complexity of their application (Finding 4). It is recommended to strengthen the capacity of inspectors and investigators by focusing on clearer procedures, guidance, and tools to enable confident application of enforcement tools and adaptation to sector-specific contexts.

Recommendation 2: Improve the reach and effectiveness of proactive awareness tools, with a focus on usability, relevance, and delivery channels.

Alignment of Findings to Recommendation 2:

Awareness efforts declined during the evaluation period, and barriers related to usability and limited reach (Finding 3). Employees subject to the Canada labour code, face barriers accessing occupational health and safety (OHS) information, including lack of awareness, difficulty locating resources, and ineffective communication from program staff. Challenges such as outdated materials, limited outreach capacity, and website usability issues further reduce the effectiveness and reach of awareness tools. Enhancing the reach, relevance, and delivery of OHS awareness tools will make it easier for employees to find and understand safety information tailored to their roles and needs. This will also strengthen outreach and engagement, ensuring that resources are consistently visible, up-to-date, and effectively communicated.

Recommendation 3: Explore ways to strengthen the collection, integration, and quality of administrative data to enable risk-based planning and performance monitoring, within a strategic framework for data management.

Alignment of Findings to Recommendation 3:

Administrative data supports planning but suffers from quality, and integration issues (Finding 6). Strengthening data systems will enable risk-based targeting, better monitoring of enforcement tools, and more strategic decision-making. Linking enforcement data to case files will allow the Program to assess the effectiveness of AMPs and other tools, while improved integration and linkage of data sources and applying GBA+ analysis will support targeted interventions and evidence-based decisions. In implementing this recommendation, considerations such as privacy, minimizing administrative burden, and leveraging multiple data sources within a strategic framework should be taken into account.

Recommendation 4: Improve timeliness in resolving complaints by exploring opportunities to address underlying factors that may influence delays.

Alignment of Findings to Recommendation 4:

The Program consistently meets its service standard for responding to inquiries within 24 hours, and finalizing assignments within 120 days. However, it has faced challenges in meeting its target for resolving 70% of complaints within 120 days. These challenges are linked to structural and operational factors such as staffing constraints, complex cases, and reliance on external parties. Employee satisfaction with the complaint process is low, especially regarding fairness, timeliness, and responsiveness (Finding 5). Improving timeliness in complaint resolution would help the Program better meet its commitments and strengthen employee confidence in the process.

Annexes

Annex A: Evaluation Approach

A mixed-methods data collection approach is adopted to address the evaluation questions. This involves collecting and analyzing both quantitative and qualitative data from multiple sources and lines of evidence. The quantitative component involves an analysis of administrative data and survey responses. The qualitative component gathers information from a range of key stakeholders, through key informant interviews. Qualitative information is also collected as part of the literature and document reviews. Evidence is triangulated, to minimize bias and validate the consistency of findings.

The following indicators matrix provides an overview of the lines of evidence the evaluation will use to collect and analyze the data in response to the evaluation questions.

**Table 12: OHS program evaluation matrix**
Evaluation Question	Line of Evidence-Administrative Data review	Line of Evidence-Document review	Line of Evidence-Literature review	Line of Evidence-Key Informant Interviews	Line of Evidence-Employee/ Employer Surveys
1. To what extent did the legislative and regulatory changes, implemented since 2016, effectively contribute to ensuring safe and healthy workplaces within federal jurisdiction?	X	X	X	X	X
2. To what extent did the Program promote awareness and understanding of employers' responsibilities and employees' rights regarding OHS in the workplace?	X	X	X	X	X
3.1 To what extent did proactive activities (versus reactive activities) encourage employers' compliance with OHS legislations and regulations?	X	X	X	X	X
3.2 How effective were the compliance and enforcement measures, in correcting and/or reducing violations of the Code?	X	X	X	X	X
3.3 To what extent were the Program's administrative data used effectively to support and target proactive and reactive activities? Are additional data needed?	X	X	N/A	X	N/A
4.To what extent did the Program ensure timely responses and processing of complaints of non-compliance within service standards?	X	X	X	X	X

Lines of Evidence

Document review

The evaluation included a review of selected program documents that addressed the evaluation questions and indicators. The review focused on official and comprehensive sources that provided reliable data. Both thematic and content analysis methods were applied.

Several limitations were identified in the documentation. These included gaps in tracking enforcement effectiveness, limited evidence on stakeholder awareness of the complaint process, and a lack of data on the impact of promotional activities. Additionally, some documents were outdated, and there was limited coverage of sector-specific or regional issues.

Literature review

A targeted sampling strategy was used to identify peer-reviewed journal articles and grey literature, including government reports and relevant publications on Occupational Health and Safety (OHS). The literature was selected based on its relevance to evaluation indicators such as the implementation of OHS activities, reach and usability of shared information, the role of compliance and enforcement measures, and the impact of regulatory and legislative changes on compliance. The review also considered challenges, limitations, gaps, and success stories in addressing non-compliance complaints.

Limitations included a small number of studies focused specifically on OHS in Canada and a lack of detailed assessments in provincial publications. While global publications provided useful insights, differences in regulatory frameworks limited their comparability to the Canadian context.

Key informant interviews

Key informant interviews were conducted with program officials, partner organizations, and representatives from employer and employee associations and unions. Nineteen interviews were held with a mix of National Headquarters officials, Regional and Hub Managers, Senior Investigators, and Health and Safety Officers. Two of the three core partner organizations participated. Eight representatives from employer and employee associations and unions were also interviewed, representing approximately one million employees and 5,000 employers, covering 70% of federally regulated employees and 25% of federally regulated employers. Interviews were conducted virtually, transcribed, and analyzed using MAXQDA software.

Limitations included potential sampling bias due to the purposive sampling approach and non-response from some invited organizations. To mitigate these issues, the evaluation team applied selection criteria emphasizing sectoral diversity, geographic reach, organizational size, and relevance to the Program. A semi-structured interview format allowed flexibility in exploring informants' areas of expertise.

Administrative Data

The evaluation used two primary sources of administrative data: the Integrated Labour System (ILS) and Labour Applications 2000 (LA2000). LA2000 was used for historical data up to 2021 to 2022, while ILS became the current system following its implementation in June 2022. Open cases from LA2000 were transferred to ILS to ensure continuity.

Descriptive statistics were used to identify trends over the evaluation period. Although data from the COVID-19 pandemic years (2019 to 2020 and 2020 to 2021) were included, the analysis focused primarily on the 2022 to 2023 fiscal year. Data from 2023 to 2024 were incomplete at the time of analysis, and many cases from that period had not yet been finalized.

Limitations included the absence of sociodemographic data for complainants, which restricted the ability to conduct Gender-Based Analysis Plus (GBA+). Data integrity issues emerged during the migration from LA2000 to ILS, particularly regarding enforcement measures, which were not reflected in ILS. AMP data were stored in a separate module within ILS and could not be linked to individual cases.

2025 Evaluation Surveys of Employers and Employees

Two electronic surveys were conducted between May 7 and May 28, 2025, with support from Employment and Social Development Canada's Interactive Fact-Finding Service (IFFS). The surveys targeted employers and employees in federally regulated industries who had prior interactions with the Program. As a result, findings are not generalizable to all federally regulated employers and employees. The sample was limited to individuals with valid email addresses, potentially excluding those less digitally connected.

In the employer survey, 4,641 key contacts were invited to participate, and 145 completed the OHS section, resulting in a 3% response rate. Survey participants included individuals from r all federally regulated sectors, with the majority from Road Transportation Services (39%) and Air Transportation (20%). Most responses came from Ontario (22%), British Columbia (17%), and Quebec (14%), with no participation from Prince Edward Island and Nunavut.

In the employee survey, 25,562 individuals were invited, and 568 completed the survey, representing a 2% response rate. Survey participants included individuals from nearly all federally regulated sectors except Uranium Mining and Processing and Atomic Energy. Most participants were from Road Transportation (22%) and the federal public service (14%). Responses were received from most provinces and territories, with no participation from Prince Edward Island, Northwest Territories, and Nunavut. The majority of respondents were located in Ontario (41%) and Quebec (23%).

Survey data enabled the identification of general patterns across sectors and regions. Due to limited participation within certain sub-groups, disaggregated analysis was restricted. The analysis focused on overall trends.

Scale used to report the findings

All: Findings reflect the input of 100% of respondents.
Large Majority: Findings reflect the input of more than 75% but less than 100% of respondents.
Majority: Findings reflect the input of at least 51% but up to 75% of respondents.
Half: Findings reflect the input of 50% of respondents.
Some: Findings reflect the input of at least 25% but less than 50% of respondents.
A Few: Findings reflect the input of at least two but less than 25% of respondents.
One: Findings reflect the input of a single respondent.

Annex B: Program logic model

Figure 13: Program Logic Model - Text description follows — **Figure 13: Program Logic Model**

Annex C: Internal complaint resolution process (ICRP)

Figure 14: Internal complaint resolution process (ICRP) - Text description follows — **Figure 14: Internal complaint resolution process (ICRP)**

Annex D: Gaps and limitations in performance measurement and data tracking

A review of program documents and the Program Information Profile (PIP) conducted during the evaluation highlights gaps and limitations in performance measurement and data tracking that further constrain the strategic use of administrative data:

Limitations in indicator design and absence of targets and thresholds:
Some indicators do not fully capture the intended outcomes. For example:
Employee understanding of harassment and violence (Immediate Outcome 3) is measured by training participation, which do not reflect actual comprehension.
Injury-related indicators exclude fatalities, limiting the scope of safety-related analysis.
Many performance indicators lack defined targets. Without these targets, it is not possible to assess whether the Program is meeting its intended outcomes or improving over time. Such as % of employees trained on Harassment and Violence, and % of employees who rate their workplace as safe, healthy, and free from harassment and violence.
Lack of disaggregated outcome data: Outcome data is not disaggregated by key demographic variables such as ethnicity, education level, job tenure, or disability status. This limits the Program's ability to conduct Gender-Based Analysis Plus (GBA+).

Annex E: DIFR between 2016 and 2023, by sector

**Table 13 DIFR between 2016 and 2023, by sector**
Industry	DIFR 2023	DIFR 2022	DIFR 2021	DIFR 2020	DIFR 2019	DIFR 2018	DIFR 2017	DIFR 2016
National DIFR	7.77	7.61	7.1	7.29	9.39	9.3	9.17	9.13
Air transportation (AIRT)	21.38	17.38	16.1	13.34	15.4	16.29	16.03	15.92
Banking and banks (BANK)	0.62	0.61	1.07	1.93	1.8	1.65	1.89	2.05
Broadcasting (television, radio, Internet) (BROAD)	3.34	3.6	4.51	5.99	5.87	6.29	3.99	3.92
Communications (COMM)	6.55	5.33	5.53	3.69	5.05	5.54	5.84	6.07
Energy, mining and mineral processing (ENER)	3.17	3.18	2.01	2.05	2.47	3.33	0.87	3.69
Federal public services, public service departments and crown corporations (PUBS)	3.88	4.77	3.49	3.95	5.39	4.43	4.89	4.65
Feed, flour and seed (FEED)	7.74	9.39	9.3	9.43	12.1	11.02	7.62	10.5
Grain handling and grain elevators (GRAIN)	6.39	5.76	4.3	7.16	6.13	6.88	8.37	8.33
Indigenous (INDG)	2.66	2.66	2.39	2.46	2.4	3.59	3.8	3.78
Interprovincial Infrastructure (bridges, tunnels, canals, causeways) (BRID)	2.94	1.85	0	0	4.76	2.43	7.4	N/A
Longshoring, stevedoring, port, harbour operations and pilotage(LONG)	9.75	14.93	11.74	8.84	11.16	21.13	17.89	19.46
Pipeline transportation (PIPE)	1.02	0.98	0.42	0.88	0.72	1.25	0.81	1.36
Postal services and postal contractors (POST)	16.43	18.6	21.25	21.29	32.26	37.82	41.39	41.88
Rail transportation (RAIL)	6.85	5.38	4.71	6.52	10.49	8.71	8.87	8.12
Road transportation (ROAD)	19.24	19.89	18.67	17.88	21.2	19.76	18.32	16.26
Water transportation (shipping and ferries)(WATER)	6.06	7.51	9.88	7.96	10.11	10.76	9.68	12.39

Source: GC Infobase, Occupational Injuries amongst Federal Jurisdiction Employers reports

Annex F: Violations from Proactive Inspection by Industry

**Table 14: Number of violations from proactive inspection by Industry* between 2016 to 2017 and 2023 to 2024**
Workplace/Industry	2016 to 2017	2017 to 2018	2018 to 2019	2019 to 2020	2020 to 2021	2021 to 2022	2022 to 2023	2023 to 2024	Total
Air Transportation (N)	1,476	1,394	1,705	1,865	38	449	2,667	2,557	12,151
Air Transportation (%)	12.15	11.47	14.03	15.35	0.31	3.7	21.95	21.04	100
Banking / Banks (N)	79	88	142	280	18	525	126	130	1,388
Banking / Banks (%)	5.69	6.34	10.23	20.17	1.3	37.82	9.08	9.37	100
Broadcasting (N)	28	161	162	168	10	108	169	228	1,034
Broadcasting (%)	2.71	15.57	15.67	16.25	0.97	10.44	16.34	22.05	100
Communications (N)	247	448	643	586	27	115	784	853	3,703
Communications (%)	6.67	12.1	17.36	15.83	0.73	3.11	21.17	23.04	100
Energy / Mining / Mineral Processing (N)	0	3	6	6	0	0	0	0	15
Energy / Mining / Mineral Processing (%)	0	20	40	40	0	0	0	0	100
Feed, Flour and Seed (N)	619	1,018	913	337	113	979	1,030	1,265	6,274
Feed, Flour and Seed (%)	9.87	16.23	14.55	5.37	1.8	15.6	16.42	20.16	100
Grain Handling / Grain Elevators (N)	92	605	273	575	11	429	593	457	3,035
Grain Handling / Grain Elevators (%)	3.03	19.93	9	18.95	0.36	14.14	19.54	15.06	100
Indigenous / Aboriginal / First Nation (N)	95	37	5	7	1	17	37	2	201
Indigenous / Aboriginal / First Nation (%)	47.26	18.41	2.49	3.48	0.5	8.46	18.41	1	100
Interprovincial Infrastructure (N)	4	11	3	14	0	6	12	7	57
Interprovincial Infrastructure (%)	7.02	19.3	5.26	24.56	0	10.53	21.05	12.28	100
Longshoring / Stevedoring / Port/Harbo. (N)	226	260	33	309	5	97	475	294	1,699
Longshoring / Stevedoring / Port/Harbo. (%)	13.3	15.3	1.94	18.19	0.29	5.71	27.96	17.3	100
Other (N)	123	97	97	62	2	45	35	94	555
Other (%)	22.16	17.48	17.48	11.17	0.36	8.11	6.31	16.94	100
Postal Services / Postal Contractors (N)	79	469	858	712	30	346	210	193	2,897
Postal Services / Postal Contractors (%)	2.73	16.19	29.62	24.58	1.04	11.94	7.25	6.66	100
Rail Transportation (N)	580	525	490	736	43	341	139	670	3,524
Rail Transportation (%)	16.46	14.9	13.9	20.89	1.22	9.68	3.94	19.01	100
Road Transportation (N)	4,550	5,487	4,851	6,297	534	3,672	6,224	4,829	36,444
Road Transportation (%)	12.48	15.06	13.31	17.28	1.47	10.08	17.08	13.25	100
Water Transportation (N)	71	128	33	143	10	82	141	100	708
Water Transportation (%)	10.03	18.08	4.66	20.2	1.41	11.58	19.92	14.12	100
Federal Public Services (N)	281	872	1,485	1,959	41	187	329	705	5,859
Federal Public Services (%)	4.8	14.88	25.35	33.44	0.7	3.19	5.62	12.03	100
Fisheries / Fishing (N)	1	0	0	0	0	0	0	0	1
Fisheries / Fishing (%)	100	0	0	0	0	0	0	0	100
Total (N)	8,551	11,603	11,699	14,056	883	7,398	12,971	12,384	79,545
Total (%)	10.75	14.59	14.71	17.67	1.11	9.3	16.31	15.57	100

* 0.9% of missing for Workplace/Industry Unknown

Footnotes

Footnote 1

Minor injury is an employment injury or an occupational illness for which medical treatment is provided and excludes a disabling injury.

Return to footnote 1 referrer

Footnote 2

Disabling injury is an injury or illness that prevents an employee from performing their regular duties or results in permanent impairment or loss of body function.

Return to footnote 2 referrer

Footnote 3

Bouchard St-Amant, P.-A. (2017). Optimizing Health and Safety Inspections in Canada. International Journal of Occupational Safety and Health, 7(2), 3-16. https://doi.org/10.3126/ijosh.v7i2.22890

Return to footnote 3 referrer

Footnote 4

Noack, A. M., Hoe, A., & Vosko, L. F. (2020). Who to inspect? Using employee complaint data to inform workplace inspections in Ontario. Canadian Public Policy, 46(3), 429-443. https://doi.org/10.3138/cpp.2018-065

Return to footnote 4 referrer

Footnote 5

Tompa, E., Kalcevich, C., Foley, M., McLeod, C., Hogg-Johnson, S., Cullen, K., MacEachen, E., Mahood, Q., & Irvin, E. (2016). A systematic literature review of the effectiveness of occupational health and safety regulatory enforcement. American Journal of Industrial Medicine, 59(11), 919-933. https://doi.org/10.1002/ajim.22605

Return to footnote 5 referrer

Footnote 6

Schulte, P. A., Cunningham, T. R., Guerin, R. J., Hennigan, B., & Jacklitsch, B. (2018). Components of an occupational safety and health communication research strategy for small- and medium-sized enterprises. Annals of Work Exposures and Health, 62(Suppl_1), S12-S24. https://doi.org/10.1093/annweh/wxy054

Return to footnote 6 referrer

Footnote 7

Rail Transportation, Road Transportation, Air Transportation, Postal services and pipelines, Feed, flour, seed and grain, Maritime Transportation, Telecommunications and Banks.

Return to footnote 7 referrer

Footnote 8

There is no set target for this indicator in the PIP.

Return to footnote 8 referrer

Footnote 9

The Program’s Performance Information Profile (PIP) sets a target of completing 70% of assignments within 120 days, which was applied throughout the evaluation period for consistency. In Departmental Results reports, this indicator’s target increased from 70% to 80% starting in 2021 to 2022. The Program has either met or come very close to achieving the higher 80% departmental target in 2021 to 2022, 2022 to 2023, and 2023 to 2024.

Return to footnote 9 referrer

Footnote 10

Excluding prosecutions, appeals, and technical surveys.

Return to footnote 10 referrer

Footnote 11

196 respondents filed a formal complaints with the Labour Program.

Return to footnote 11 referrer

Footnote 12

Keefe, A., Davies, H., Fenton, S., & Peters, C. (2021). A content analysis of archived reports to explore the roles of hazard investigations in resolving hazardous issues at federally regulated workplaces: A pilot project.

Return to footnote 12 referrer

Page details

2026-08-13

Evaluation of the Occupational Health and Safety Program, 2026

On this page

Alternate formats

List of figures

List of tables

List of abbreviations

Executive summary

Key findings

Recommendations

Management response action plan

Overall management response

Recommendation 1

Recommendation 2

Recommendation 3

Recommendation 4

Introduction

Program description

Program governance

Budget overview (2016 to 2024)

Notable legislative and regulatory changes

Key findings

Legislative and regulatory changes and workplace health and safety

Finding 1

Recent legislative and regulatory changes have addressed gaps, modernized safety standards, and strengthened compliance. Nonetheless, challenges persist regarding regulatory clarity, enforcement consistency, and practical application

Potential legislations/regulations or changes needed - What we Heard

The Program has made progress in increasing the reporting of workplace harassment and violence incidents. However, some employees may still choose not to file complaints due to fear of negative consequences and limited trust in the employer's response and resolution processes

Despite an overall reduction in the number of workplace injuries, the Program did not meet its target of reducing the Disabling Injury Frequency Rate (DIFR) by 2% each year

Workplace injuries declined by 23% between 2016 and 2023

Fatalities decreased during the pandemic years, likely due to reduced economic activity, and have since returned to levels similar to those observed before the pandemic

The Disabling Injury Frequency Rate (DIFR) has decreased over the evaluation period. However, the program did not meet its target of a 2% annual reduction, except during the pandemic years

Conducting proactive inspections and raising awareness (Proactive activities)

Finding 2

Proactive inspections are consistently prioritized and are effective in detecting violations. The Program consistently met its target of devoting 60% of its activities to prevention

Strategic targeting and execution of inspection activities face persistent operational constraints

Finding 3

Program's awareness activities decreased during the evaluation period

Employers reported high self-rated awareness of OHS rights and responsibilities

Barriers and systemic challenges limit the reach and effectiveness of awareness tools

Awareness gaps can affect the effectiveness of the Internal Complaint Resolution Process (ICRP)

Compliance and enforcement measures (Reactive Activities)

Finding 4

Investigations are viewed as the foundation for compliance actions but face challenges

AVCs and Directions result in high rates of final compliance, but have limitations

Prosecutions and AMPs are recognized as important enforcement tools but remain underutilized

The Program's timeliness in responding to complaints and inquiries

Finding 5

The Program responds to almost all inquiries within one business day, consistently meeting its service standard

The Program met its target for finalising assignments in 120 days

Timeliness in resolving OHS complaints has improved over time but continues to be affected by staffing constraints, case complexity, and external dependencies

Among employees for whom the Internal Complaint Resolution Process did not lead to a resolution and who subsequently filed a formal complaint to the Labour Program, satisfaction with the complaint process is low, particularly regarding fairness, timeliness, and employer responsiveness

The use of Program administrative data for strategic enforcement

Finding 6

Administrative data is used to support proactive and reactive planning

Limitations in data quality, system usability, and integration constrain the effectiveness of administrative data for strategic planning

Recommendations

Annexes

Annex A: Evaluation Approach

Lines of Evidence

Document review

Literature review

Key informant interviews

Administrative Data

2025 Evaluation Surveys of Employers and Employees

Scale used to report the findings

Annex B: Program logic model

Annex C: Internal complaint resolution process (ICRP)

Annex D: Gaps and limitations in performance measurement and data tracking

Annex E: DIFR between 2016 and 2023, by sector

Annex F: Violations from Proactive Inspection by Industry

Page details

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