Can an Employer Require WAH Retraining Before Certification Expires?

 

An employer may require additional Working at Heights instruction, hands-on practice, or competency reassessment before a worker’s certificate expires when the work, equipment, hazards, or worker performance changes. This does not necessarily renew or replace the worker’s CPO-approved certificate. Ontario Working at Heights certification remains valid for three years, while employers must also ensure workers receive appropriate site-specific instruction for the actual work being performed. 

 

If your work conditions, equipment, or confidence level have changed, you likely need a WAH refresher certification course to stay compliant with the Occupational Health and Safety Act and current safety standards. 

Refresher Training and Workplace Retraining Are Not the Same

 

Training action	Why it happens	Does it renew the certificate?
CPO-approved WAH refresher	The three-year validity period is ending	Yes, after successful completion
Site-specific instruction	The worker enters a new site or encounters different hazards	No
Equipment-specific instruction	New harnesses, lifelines, anchors or systems are introduced	No
Competency reassessment	A supervisor observes uncertainty or unsafe performance	No
Corrective retraining	An incident, near miss or investigation identifies a knowledge or skill gap	No, unless it is also an approved refresher program

 

Ontario states that approved Working at Heights training is valid for three years. Workers must successfully complete refresher training to extend that validity for another 3 years. You can’t work with an expired certificate as doing so can create compliance risk.

When Should an Employer Reassess a Worker Before Expiry?

There is no need to send every worker for formal certification renewal whenever something at the workplace changes.

 

The employer should first identify what has changed and what type of instruction is needed.

 

The following situations may justify a competency review, targeted retraining or additional hands-on practice.

1. New Fall-Protection Equipment Is Introduced

Fall-protection equipment is not interchangeable simply because the components appear similar.

 

A worker who has used one harness, lifeline or connection system may not automatically understand another system’s:

• Inspection requirements
• Adjustment points
• Connection methods
• Equipment limitations
• Compatible components
• Manufacturer instructions
• Storage requirements
• Removal-from-service criteria

For example, introducing a new self-retracting device does not necessarily mean every worker must immediately renew their Working at Heights certificate.

 

It does mean the employer should confirm that affected workers understand how the device is selected, inspected, connected and used for the assigned application.

 

The training should reflect the equipment and fall-protection system actually used at the project. Ontario guidance explains that foundational Working at Heights training must be supplemented by employer-provided training on the applicable fall-protection system.

 

A practical demonstration may be appropriate. The worker should be able to show that they can use the equipment correctly rather than only confirm that they attended a previous course.

2. The Worker Moves to a Different Task or Site

Working at heights on one project does not prepare a worker for every possible elevated-work environment.

 

The hazards involved in roof work can differ from those involved in scaffold access, leading-edge work, formwork or maintenance performed from an elevated platform.

 

A reassessment may be needed when a worker:

• Moves from ground-level duties to elevated work
• Begins using a fall-arrest system for the first time
• Starts working near an unprotected edge
• Moves from fixed anchors to temporary anchor systems
• Begins working from scaffolding
• Takes on roofing or leading-edge work
• Returns to elevated work after a long absence
• Becomes responsible for supervising other workers at height

The employer should review the new task, the available fall-protection methods and the project’s rescue arrangements.

The worker may need a site orientation, task-specific instruction or supervised practice. That instruction does not change the expiry date printed on the worker’s approved training record.

It prepares the worker for the real conditions they are about to face.

3. A Near Miss or Fall-Related Incident Occurs

A near miss should lead to an investigation, not an automatic assumption that the worker simply needs another course.

 

The employer should determine what allowed the event to occur.

 

Possible contributing factors include:

• An unsuitable anchor point
• Incorrect equipment selection
• A missing guardrail or protective system
• Inadequate supervision
• Unclear work procedures
• Defective or damaged equipment
• Failure to inspect equipment
• Incompatible fall-protection components
• Insufficient rescue planning
• A gap in the worker’s knowledge or practical ability

 

The corrective action should address the cause.

If the worker misunderstood how to connect a system, targeted instruction and a practical reassessment may be appropriate.

If the incident resulted from missing edge protection or a poorly planned work area, sending the worker to refresher training would not correct the underlying site condition.

Retraining should never be used as a substitute for proper hazard control.

4. A Supervisor Observes Unsafe Equipment Use

A certificate should not prevent a supervisor from intervening when unsafe work is observed.

 

Examples of warning signs include a worker:

• Wearing a harness incorrectly
• Failing to complete a pre-use inspection
• Connecting incompatible components
• Using an unsuitable anchorage
• Leaving unnecessary free-fall distance
• Working while disconnected from the required system
• Misusing a travel-restraint system
• Failing to recognize damaged equipment
• Altering equipment without authorization
• Being unable to explain the rescue procedure

In these situations, the priority is to stop the unsafe activity and determine why it occurred.

 

The worker may have forgotten a critical step. The equipment may be unfamiliar. The procedure may have been poorly communicated. There may also be a wider problem affecting other workers performing the same task.

 

The employer can then provide focused instruction and require the worker to demonstrate the correct procedure before returning to the work.

This does not necessarily renew the worker’s provincial certification. It confirms whether the worker can safely perform the assigned task under current workplace conditions.

5. The Worker Cannot Demonstrate Practical Competency

Proof of training is important, but it is not the only factor an employer should consider.

A worker may have a valid certificate but struggle to apply the training after a lengthy absence from elevated work. Another worker may understand the theory but be unable to inspect, adjust or connect the equipment correctly.

 

A practical reassessment may be justified when the worker cannot:

• Identify the fall hazards associated with the task
• Select the appropriate method of fall protection
• Inspect a harness, lanyard or connecting device
• Fit and adjust the equipment correctly
• Identify the intended connection point
• Distinguish between travel restraint and fall arrest
• Follow the site’s fall-protection procedure
• Explain what to do after a fall
• Describe the project’s rescue process

The goal is not to find reasons to fail the worker.

The goal is to identify the exact gap before that gap contributes to an injury.

A valid certificate establishes that approved training was successfully completed. Ongoing workplace instruction and supervision help ensure that the knowledge is applied to the task being performed.

What Should an Employer Do When a Working at Heights Skill Gap Is Found?

When a supervisor identifies a concern, the response should match the actual risk.

 

Sending every worker back to a formal refresher course may not solve the problem. The concern could relate to unfamiliar equipment, inadequate site orientation, unclear procedures, poor supervision or a missing fall-protection control.

A structured response helps the employer correct the immediate issue and identify whether the problem affects other workers.

1. Pause the affected work

The worker should not continue the elevated task until the concern has been assessed.

This does not mean the worker’s certificate is invalid. It means the employer needs to confirm that the task can be completed safely under the present conditions.

The supervisor should secure the work area and address any immediate hazards before work resumes.

2. Identify the exact competency concern

Avoid recording the issue as simply “needs more training.”

Describe the specific knowledge or performance gap.

For example:

• The worker could not adjust the harness correctly.
• The worker selected an unsuitable anchor point.
• The worker did not recognize damaged webbing.
• The worker could not distinguish between travel restraint and fall arrest.
• The worker did not understand the site’s rescue procedure.
• The worker connected components that were not intended to be used together.
• The worker entered an elevated work area without following the required procedure.

A precise finding leads to a more effective corrective action.

3. Review the work environment and procedure

The worker may not be the only source of the problem.

The employer should also examine whether:

• The work procedure is clear and accessible.
• The fall-protection plan reflects current conditions.
• The correct equipment is available.
• Anchors and connection points are clearly identified.
• Equipment instructions are available.
• Workers received an adequate site orientation.
• Supervision is appropriate for the task.
• The rescue plan is realistic and understood.
• Other workers are making the same error.

Retraining is less effective when the workplace continues to expose workers to unclear instructions, unsuitable equipment or poorly controlled hazards.

4. Provide targeted instruction

The instruction should address the identified gap.

It may include:

• Reviewing the fall-protection procedure
• Demonstrating correct equipment use
• Practising harness fitting and adjustment
• Reviewing inspection criteria
• Explaining anchor selection
• Reviewing equipment compatibility
• Clarifying travel-restraint and fall-arrest requirements
• Practising the site’s emergency and rescue procedure

Ontario’s Construction Projects regulation requires employers to ensure workers who may use a fall-protection system are adequately trained in its use. Workers must also receive adequate oral and written instructions from a competent person.

The instruction should therefore cover the system the worker will actually use, not only general fall-protection theory.

5. Require a practical demonstration

A conversation alone may not confirm competency.

After receiving instruction, the worker should demonstrate that they can safely perform the relevant steps.

Depending on the task, this may include:

• Inspecting the equipment
• Putting on and adjusting a harness
• Selecting the correct components
• Identifying an appropriate connection point
• Connecting the system correctly
• Maintaining the intended type of fall protection
• Explaining equipment limitations
• Following the rescue procedure

The supervisor or competent evaluator should observe the demonstration and correct any remaining errors.

The worker should return to the task only after the employer is satisfied that the identified gap has been addressed.

Document the Retraining and Reassessment

Training records help employers confirm what instruction was provided, why it was required and whether the worker demonstrated the expected competency.

For workplace-specific retraining, the internal record should include:

• Worker’s name
• Date of instruction
• Reason for reassessment
• Task or equipment covered
• Hazards reviewed
• Instructor or evaluator’s name
• Practical skills demonstrated
• Corrective actions completed
• Any limitations placed on the worker
• Date the worker was cleared to resume the task

This internal record does not replace the worker’s official proof of Working at Heights training.

 

Ontario Regulation 297/13 separately requires employers to maintain records for mandatory approved Working at Heights training. Those records must identify the worker, approved provider, completion date and approved program completed. A worker’s proof of successful completion issued by the Chief Prevention Officer can serve as the required training record.

 

Employers should therefore maintain a clear distinction between:

1. The worker’s CPO-approved Working at Heights training record
2. Employer-provided site, equipment or task-specific instruction
3. Practical reassessments or corrective retraining

Keeping these records separate prevents workplace retraining from being mistaken for formal certification renewal.

When Is the Formal Working at Heights Refresher Required?

Formal WAH refresher training is required when the worker needs to keep their approved Working at Heights training valid beyond its three-year validity period.

Formal refresher training is appropriate when:

• The three-year validity period is approaching its end.
• The worker must maintain valid approved training for covered construction work.
• The worker is eligible to complete the approved refresher program.
• The employer needs recognized proof that the worker’s approved training has been revalidated.

Workplace retraining may be appropriate when:

• Equipment changes before the expiry date.
• A worker moves to a different task or site.
• A supervisor observes unsafe equipment use.
• A near miss identifies a practical skill gap.
• The worker returns after a long absence.
• Site-specific procedures or rescue arrangements change.
• The worker cannot demonstrate the required competency.

Completing workplace retraining does not normally change the expiry date of the worker’s approved training.

 

Need to renew an Ontario Working at Heights certificate?

Register for Achieve Safety’s CPO-approved Working at Heights refresher training before the worker’s three-year validity period ends. See whats covered here.

Can an Employer Require Retraining Even When the Certificate Is Valid?

 

Yes.

 

A valid certificate confirms that a worker successfully completed an approved training program within the applicable validity period. It does not prevent an employer from requiring further instruction, supervised practice or competency reassessment.

The employer remains responsible for ensuring that workers receive appropriate information, instruction and supervision for the work being performed.

The employer may temporarily remove a worker from a specific task when there is a reasonable concern about the worker’s ability to perform it safely. The worker may return after the employer has addressed the concern and confirmed competency.

 

However, employers should avoid describing every internal retraining session as “Working at Heights certification” or “approved refresher training.”

 

Only training delivered through an approved program and provider should be represented as CPO-approved Working at Heights training. Ontario recently warned employers and workers about fraudulent Working at Heights cards, reinforcing the importance of verifying approved training and documentation

 

👉 Book your Working at Heights Training in Ontario here. We also serve various surrounding areas such as Toronto, Barrie and many more.