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As federal, provincial, and territorial labour ministers consider plans for occupational safety and health (OSH) harmonization across Canada, workers and their unions have a critical message: while we improve workplace safety, the process must genuinely integrate worker voices, and harmonization must never result in diminished standards, nor become a race to the bottom.
Recent reports about ministerial meetings between governments and the growing momentum for safety harmonization reveal a troubling pattern: discussions are happening largely without meaningful participation from organized labour, the only independent voice that can truly represent workers’ interests, lived experiences and expertise. This exclusion threatens both the effectiveness of any harmonized standards and workers’ trust in the regulatory system itself.
Under the premise of promoting economic efficiency and worker mobility, government safety regulators are meeting to talk about harmonization of occupational health and safety (OHS) legislation across Canadian jurisdictions. In principle, this makes sense in certain contexts. While economic arguments must never place workers in harm’s way, workers should be able to move between provinces confident that safety standards remain consistently high and clearly understood. Employers operating in multiple jurisdictions benefit from streamlined compliance requirements. However, harmonization efforts must be guided by a fundamental principle: existing protections must never be watered down.
Indeed, the current regulations protecting Canadian workers were not created in a vacuum. They were fought for by unions and other workers’ groups, often in direct response to terrible tragedies that cost workers their lives or health. These standards, quite literally, were written in blood—emerging from pandemics, construction accidents, mining disasters, industrial exposures, and countless workplace incidents that harmed workers and their families. Any harmonization process that fails to recognize this history risks repeating it. This not only results in tragedy but also imposes enormous costs on businesses through compensation claims, work stoppages, and damaged reputations.
Lack of participation sets a dangerous precedent
The current approach to harmonization sets a dangerous precedent by proceeding without clear, meaningful engagement with worker representatives. While governments speak of “stakeholder engagement,” the reality is that under the current description of the process, workers are being excluded from fundamental decisions about their own safety and health protection.
This exclusion goes beyond a simple oversight in process; it undermines the very foundation of Canada’s occupational safety and health system. The internal responsibility system, which forms the conceptual foundation of OHS legislation across the country, depends on trust and collaboration between workers, employers, and government to be effective.
The argument that harmonization should focus first on “high-risk and safety-sensitive industries” like mining, construction, and health care is misguided. Precisely because these are high-risk industries, reviews must be careful and deliberate to reduce the likelihood of harm and have worker participation at their heart. These sectors have some of the most comprehensive and hard-won safety protections precisely because workers and their unions have fought for them in response to tragic accidents and occupational diseases.
All parties must also clearly understand any changes expected of them; if implementation is rushed, the likelihood of harm increases. Workers and their representatives also possess irreplaceable expertise about workplace hazards and the effectiveness of safety measures. In order to raise the bar and actually achieve what regulations are intended to do – save lives and limit harm – workers must be able to speak to their knowledge and experience.
Indeed, worker representatives must have direct input on which regulations ought to be harmonized, and when.
As ministers prepare for their fall meeting, they must remember that workplace safety is not just a matter of regulatory efficiency; it’s about protecting the people who build our infrastructure, care for our communities, extract our resources, and drive our economy. And they can only do that by including labour.
A path forward: Meaningful engagement
To be clear: workers and their unions are not opposed to harmonization per se. The current momentum for OSH harmonization presents both an opportunity and a risk. We recognize that consistent, high standards across jurisdictions can benefit both worker safety and economic efficiency. Done right, with transparency and genuine worker participation and a commitment to raising standards, harmonization could strengthen protection for all Canadian workers. Done wrong, it could undermine decades of progress won through worker advocacy and paid for with workers’ lives and health. By excluding organized labour – the only body that can speak independently on behalf of workers – from harmonization discussions, governments risk creating regulations that don’t reflect workers’ realities and needs, and place them at dire risk.
To ensure harmonization serves workers’ interests and maintains public trust, we call for:
- Immediate establishment of formal tripartite mechanisms with equal representation from government, employers, and organized labour.
- Full transparency about scope, timeline, and implementation plans for any harmonization initiatives.
- Commitment that harmonization will raise standards to the highest level currently existing in any jurisdiction, not reduce them to the lowest.
- Adequate time and resources for worker education and transition to any new harmonized standards.
- Regular review and evaluation mechanisms that include worker feedback on the effectiveness of harmonized regulations.
At the end of the day, workers need to be engaged in meaningful discussions with government and industry as equal partners. Existing regulations must never be watered down – harmonization must raise the bar, establishing the highest common standard rather than settling for the lowest common denominator.
The old saying rings true: if you’re not at the table, you’re on the menu. Workers have too much at stake to be excluded from decisions about their own safety and health protection.
Nathan Hauch is the national representative, health, safety and environment for the Canadian Labour Congress.
Troy Winters is the national health and safety co-ordinator for the Canadian Union of Public Employees.
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