Building a Practical PPE Management Program in Ontario: Lessons from the Field

A few years ago, I was visiting a mid-sized contractor in the GTA. Great people, hardworking crew. But during my walkaround, I noticed something that still sticks with me — half the workers had new hard hats, while others were wearing helmets so scuffed and faded you could barely read the CSA approval stamp. When I asked about their PPE management system, the site supervisor shrugged: “We hand out gear when people ask for it.”

That’s not uncommon. But here’s the truth: waiting for someone to “ask” usually means we’re already behind the curve. Personal Protective Equipment (PPE) is the last line of defence. If it’s not in place, not inspected, or not fit for purpose, it can turn a near-miss into a critical injury.

In Ontario, the law is clear. Under the Occupational Health and Safety Act (OHSA) and its regulations (like O. Reg. 851/90 for Industrial Establishments or O. Reg. 213/91 for Construction Projects), employers must provide and maintain appropriate PPE, and workers must use it properly. Inspectors with the Ministry of Labour, Immigration, Training and Skills Development (MLITSD) will expect you to demonstrate how you’re managing this responsibility.

So, how do we move from a “hand-out-when-needed” approach to a real PPE management program that works? Let’s break it down.

Step 1: Know Your Hazards First

You can’t manage PPE until you know what you’re protecting people from. This means hazard assessments.

• Construction site? You’ll need fall protection harnesses, CSA-approved headwear, and high-visibility clothing.

• Warehousing? Think about foot protection, traffic vests, and hearing protection near forklifts.

• Office settings? Even here, ergonomics and respiratory concerns (think toner or cleaning chemicals) might trigger PPE needs.

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I always say: PPE is hazard-driven, not “one-size-fits-all.” And that’s exactly what MOL inspectors want to see — a clear link between your hazard assessments and your PPE choices.

Step 2: Get the Right Gear, the Right Way

It’s tempting to go for the cheapest supplier. But buying bargain-bin safety glasses that fog up within minutes? That only guarantees workers will “forget” to wear them.

Instead, invest in CSA-approved PPE and involve your workers in the selection process. You’ll be surprised how much buy-in you get when you ask: “Which pair of gloves do you actually like working with?” Comfort equals compliance.

💡 Free Resource Tip: IHSA offers fact sheets and PPE guidance documents that can help you choose correctly without reinventing the wheel (ihsa.ca).

Step 3: Train, Retrain, Remind

Handing someone a harness is not enough. Under OHSA, you need to train workers on proper use, care, and limitations of PPE.

I’ve seen too many people wearing earplugs halfway out of their ears or cutting the chin straps off hard hats. That’s not training, that’s habit.

Make PPE training part of orientation, reinforce it with toolbox talks, and refresh it whenever new equipment comes in. The WSIB’s Health and Safety Excellence program (HSEp) even offers rebates for companies who develop structured PPE initiatives — worth looking into.

Step 4: Inspection and Maintenance — Not “Set It and Forget It”

PPE wears out. Helmets expire. Respirators need cleaning. If your management system doesn’t include inspection schedules, you’re only half-covered.

Some companies I’ve worked with keep a simple spreadsheet: issue date, inspection record, replacement due. Others go digital with safety management software. The point is to have a system — not a pile of receipts in a drawer.

Step 5: Document Everything (because MOL will ask)

Auditors and inspectors don’t just want to hear that you manage PPE. They’ll ask for records:

• Proof of training

• Inspection logs

• Replacement schedules

• Policies showing employer and worker responsibilities

  
  

And here’s where many companies stumble — they do the right things but don’t keep the paperwork. In Ontario, “not documented” usually means “not done.”

Step 6: Keep Improving

Finally, remember that PPE management isn’t static. New hazards emerge, products improve, and worker feedback can change your program for the better.

Ask your crews regularly: “Does this gear work for you?” Sometimes the biggest improvement comes from something small, like swapping out hot, heavy vests for lighter, more breathable ones. Workers notice when you listen.

Final Thoughts

At the end of the day, a PPE management program isn’t about ticking boxes for COR, IHSA, or the MOL. It’s about making sure the people who come to work in the morning go home safe at night. And that’s what this is really about.

If you’re starting from scratch, lean on free resources from IHSA, WSIB, and even your PPE suppliers — many offer free training sessions or sample inspection checklists. Build your program step by step, and don’t overcomplicate it.

Because here’s the thing: PPE is simple. But the way you manage it shows whether your company takes safety seriously. And believe me, workers and inspectors can spot the difference a mile away.