Violence and harassment prevention plans: what Canadian employers must have

Of all the program requirements in Canadian OHS law, this is the one most often missing entirely at small industrial companies — usually with the honest explanation that “we’re a tight crew, that’s an office problem.” The law disagrees, in every jurisdiction, at every company size. And the incidents that make it matter — a customer threatening a service tech, an aggressive motorist at a flagging station, harassment inside the crew — are field problems as much as office ones.

Alberta: one plan, both hazards

OHS Code Part 27 (ss. 390–391.1) treats violence and harassment as workplace hazards like any other — assessed, controlled, documented. The structural point people miss: section 390 requires a single prevention plan covering both violence and harassment — you don’t need two parallel documents; you need one plan with both scopes. It must include:

• A policy stating the employer’s commitment and that incidents will be addressed
• Prevention procedures grounded in an assessment of where the risks are in your operation (working with the public, handling cash or drugs, working alone, late hours, sites you don’t control)
• Reporting and response procedures — how a worker reports, how it’s investigated, how confidentiality is handled
• Worker involvement in developing the plan, and training on it
• Review on a cycle and after incidents

Federal: the prescriptive regime

Federally regulated employers (interprovincial carriers, banks, telecom, pipelines) follow the Work Place Harassment and Violence Prevention Regulations, SOR/2020-130 — newer and much more prescriptive:

• Workplace assessment (s. 5) — identify risk factors, jointly with the policy committee/representative
• Prevention policy (s. 10) — with mandated content
• Emergency procedures (s. 11) — for occurrences that pose immediate danger
• Training (s. 12) — for employees, and specific training for designated recipients of complaints

It also imposes defined timelines for responding to occurrences and a resolution process with named roles. Federal carriers that copied a provincial template are usually missing the assessment and the training records — the two things ESDC asks for first.

Manitoba, and the rest of the map

Manitoba’s Workplace Safety and Health regime requires a harassment prevention policy from every employer, at any size — there is no threshold. BC, Saskatchewan and the other provinces each impose their own versions of violence/harassment duties with local structures. The safe generalization for a Canadian employer: assume you need a written plan, worker training and a working complaint procedure, everywhere you operate.

What makes a plan real (and audit-proof)

1. An honest risk assessment. A trucking company’s risks (road rage, customer sites, remote fuel stops, in-cab harassment on team runs) are not a dental office’s. Generic templates fail here first.
2. A reporting path people would actually use — including when the problem is the supervisor. Name an alternate route.
3. Investigations that conclude. Documented, confidential where required, ending in findings and corrective actions — the same closed-loop discipline as any incident investigation.
4. Training with records. A policy nobody was trained on is, for audit purposes, close to no policy.
5. Review after every incident. The plan is a living control, not a filing requirement.

This is one of the requirement sets Vigil Advisor drafts with a per-policy decision questionnaire — reporting routes, investigation roles, training cadence — so the plan comes out specific to your operation and cited to the sections above, instead of a template with your logo on it.