Two provinces, one piece of equipment, opposite rules.
British Columbia, OHS Regulation section 8.2: the worker provides clothing needed for protection against the natural elements, general purpose work gloves, appropriate footwear including safety footwear, and safety headgear. The employer provides all other PPE required by the Regulation, at no cost to workers.
Quebec, per the CNESST: the employer supplies PPE free of charge from the day of hire, fitted to the worker — and owning your own equipment cannot be a hiring criterion. Their published example is a warehouse candidate asked whether he already has safety boots; the answer is that the employer cannot require it, and must supply them.
A single “company PPE policy” cannot be right in both places. That is why the record below opens with a table of who supplies what, and why filling that in comes before handing anything over.
PPE is the last control, and the record should show it
Alberta’s OHS Code makes the link that most issue sheets skip. Section 228(1) opens with a condition: PPE is required “if the hazard assessment indicates the need” for it. And section 9 puts it at the bottom of a legal hierarchy — eliminate the hazard if reasonably practicable, then engineering controls, then administrative controls that bring it as low as reasonably achievable, and only then personal protective equipment.
So the second section of the record asks for the hazard, the higher controls already in place, and why PPE is still needed. It is one column of writing and it changes what the sheet is: a reasoned issue rather than a distribution.
“Residual noise of 87 dBA at the operator position after enclosing the press” is an answer. “Company policy” is not — and it is the answer an officer will write down.
What each jurisdiction actually says
Alberta — the clearest employer duty
Section 228 puts four things on the employer where the assessment indicates PPE is needed: that workers wear equipment correct for the hazard, that they use and wear it properly, that it is in a condition to perform the function for which it is designed, and that workers are trained in the correct use, care, limitations and assigned maintenance.
That last list is worth reading slowly. “Limitations” is in the statute. A worker who does not know what the equipment does not protect against has not been trained within the meaning of section 228(1)(d) — and that is the most common gap in PPE training, not the fitting.
Section 228(2) then puts three duties on the worker: use and wear the appropriate equipment properly in accordance with the training and instruction received, inspect it before using it, and not use equipment unable to perform its function. And 228(3) adds a sentence that catches a real failure mode: the employer must ensure that the use of PPE does not itself endanger the worker.
Ontario — every duty is written as the worker’s
Reg. 851’s Protective Equipment sections are phrased consistently, and it is instructive to see them together:
80. A worker exposed to the hazard of head injury shall wear head protection appropriate in the circumstances.
81. A worker exposed to the hazard of eye injury shall wear eye protection appropriate in the circumstances.
82. A worker exposed to the hazard of foot injury shall wear foot protection appropriate in the circumstances.
“A worker … shall wear.” Nothing there about who buys it, and nothing about keeping a record.
The exception is section 79, and it is the tightest wording in the country:
A worker required to wear or use any protective clothing, equipment or device shall be instructed and trained in its care and use before wearing or using the protective clothing, equipment or device.
Before. Not in the first week, not at the next toolbox talk. That single word is the reason the training section of the record has a column headed “date (before first use)” rather than just “date” — the sequence is the requirement.
Note also section 84, which is easy to miss because it does not name an item of equipment: a worker exposed to skin contact with a noxious gas, liquid, fume or dust, a sharp or jagged object, a hot object or molten metal, or radiant heat, must be protected either by wearing apparel sufficient to protect or by a shield, screen or similar barrier. The regulation itself offers the barrier as an alternative to the PPE — which is the hierarchy of controls appearing inside a PPE clause.
British Columbia — the one with a written programme and a schedule
Beyond section 8.2 on who supplies what, BC adds two things the others do not.
A written programme, in defined cases. Where PPE is used against a chemical exposure or in an oxygen-deficient atmosphere, section 8.5 requires a programme that includes written procedures for selection, use, inspection, cleaning, maintenance and storage, plus instruction and training in correct use and maintenance. An issue sheet is not that programme; it is the record of one part of it.
Respirator fit testing, with a real schedule. A fit test is required before initial use of a respirator, at least once a year, whenever the facepiece changes — brand, model or size — and whenever a change in the wearer’s physical condition could affect the fit.
That last trigger is the one to build a habit around. Facial hair at the sealing surface, significant weight change, dentures, dental or facial surgery: all of them can invalidate a fit that passed six months ago. The record therefore carries a fit-test table with both a “next test due” date and the condition-based triggers written into the note, because a date alone would tell only half the rule.
Section 8.3 covers the rest in a sentence: PPE must be selected and used in accordance with recognised standards, provide effective protection, and be maintained in good working order and in a sanitary condition.
Federal — Part XII, and the CSA standards named in it
Federally regulated employers work from the Canada Occupational Health and Safety Regulations, Part XII, “Protection Equipment and Other Preventive Measures”. Its structure is prescriptive by hazard: where there is a risk of head injury, protective headwear meeting the named CSA standard, and so on down the list.
Two practical consequences. The federal regulation, like Alberta’s Code, names the standard and its edition, so “CSA approved” is not a specification — write CSA Z94.1 for headwear, Z94.3 for eye and face, Z195 for footwear, Z94.4 for respirator selection, use and care. And the PPE duty sits inside the same Part XIX hazard-prevention programme discussed in the hazard assessment template: the equipment is one of the preventive measures the programme is supposed to have chosen.
Quebec — supplied, fitted, and never a condition of hire
Quebec is the strongest of the five on supply. The CNESST states that the employer must provide PPE free of charge from the day of hire, available as soon as the worker has to do the tasks that need it, and properly fitted to the worker. It also lists the acceptable ways of doing that: a supplier contract in the company’s name, an internal store or bank of equipment, or making the equipment available on condition it stays on site.
And the point that has no equivalent elsewhere in this article: possessing PPE cannot be a hiring criterion. An employer cannot make ownership of safety boots a condition of being taken on.
Quebec’s own regulatory language is French, and the instruments keep their names: the Loi sur la santé et la sécurité du travail and the Règlement sur la santé et la sécurité du travail. Legis Québec was unreachable on the day this article was written, so the citation here is the CNESST’s own page rather than the statute — a deliberate downgrade from primary text to the regulator, and one worth re-checking.
Why the record has a “size” column and a “service life” column
Neither is required anywhere in Canada. Both are here for the same reason: they are the two facts that cannot be reconstructed later.
Size is the one that decides whether the equipment works at all. Quebec makes fit an explicit employer duty; BC’s section 8.3 requires effective protection, which a wrong-sized respirator does not provide; Alberta requires equipment “in a condition to perform the function for which it is designed”. A record without sizes cannot support any of those claims.
Service life or expiry catches the equipment that fails without looking failed. Fall-arrest harnesses and lanyards, hard hats, filter cartridges: manufacturers set a life independent of visible wear, and a spotless harness can be out of service. That data is legible on the label at the moment of issue and effectively unavailable afterwards, which is why it belongs in the row.
What this record is not
- Not a waiver. A signature records receipt and instruction. It does not transfer the duty, and it is not an assumption of risk. The document says so above the signature line, so that the person collecting it knows too.
- Not the hazard assessment. It hangs off one: the first section asks which assessment the PPE comes from. PPE issued without an assessment behind it is the finding, not the control.
- Not the BC written programme required by section 8.5 for chemical exposures and oxygen-deficient atmospheres, and not a respiratory protection programme.
- Not the hazard-specific regimes. Asbestos, lead, silica, hearing conservation, fall protection, welding, confined space entry: each adds equipment requirements, training requirements and often medical surveillance.
- Not legal advice, and not a complete statement of any of these duties. Each source is linked and each is short.
- Not portable across borders. France supplies PPE and work clothing free of charge with no exceptions, and requires a written consigne d’utilisation plus practical training in wearing the equipment. Italy requires a written company procedure for the return and storage of PPE. Neither has an equivalent in Canadian law, and the reverse is true of BC’s footwear rule.
How to use it
- Settle section 3 first: which jurisdiction, federally regulated or not, and what — if anything — the worker supplies. Write the basis, not just the answer.
- Fill in the hazards (section 2) with the higher controls beside them. An empty “higher controls” column across the board is a message.
- Record size, standard and service life at the moment of issue (section 4). Afterwards the label is gone.
- Train before first use (section 5), and include limitations. Ontario’s “before” is not advisory, and Alberta’s “limitations” is in the statute.
- Book the fit test (section 6) with a date and keep the condition triggers visible.
- Open the return table (section 7) on the first issue, not on the first departure.
- Sign it (section 8), and read the line above the signature out loud once. It is the part people get wrong.
Then diary the annual fit tests and the service-life expiries. Those are the two dates that arrive silently.