Audit of hazardous products management

Abbreviations

AAFC

Agriculture and Agri-Food Canada

CMB

Corporate Management Branch

OHS

Occupational health and safety

RDC

Research and development centre

STB

Science and Technology Branch

WHMIS

Workplace Hazard Management Identification System

Executive summary

Agriculture and Agri-Food Canada (AAFC) uses hazardous products in a variety of workplaces, which include a network of 20 research and development centres (RDCs). These RDCs include workplace environments like laboratories and farms. Health and safety risks are high at these locations due to the presence of hazardous materials, specialized equipment and unique operational hazards.

Hazardous products are classified based on their hazardous nature and can pose risks to health, safety, property and the environment. The Canada Labour Code — Part II, the Hazardous Products Act and related regulations outline the proper use and handling of these products. AAFC must ensure that hazardous products are being used and handled in a manner that is safe and responsible for employees and in compliance with applicable regulations and guidelines.

This audit was included in AAFC's 2024-25 to 2028-29 Audit and Evaluation Plan due to the risks related to the handling of hazardous products, as well as the significant regulatory requirements.

The objective of the audit is to provide assurance that oversight and controls related to the management of hazardous products at AAFC RDCs are in place to support compliance with applicable regulations and guidelines.

We examined the oversight, processes and procedures and training in place to support the management of hazardous products, focusing on the safe storage, use, handling and disposal of laboratory chemicals, pesticides and fuel at AAFC RDCs.

Overall, we found that AAFC has elements of oversight and controls related to the management of hazardous products at RDCs to support compliance with applicable regulations and guidelines. However, opportunities exist for further improvement by:

• clarifying the National Laboratory Safety Program, as well as roles and responsibilities
• updating procedures and guidelines
• ensuring implementation of key requirements
• monitoring of specialized training completion

Management agrees with the audit recommendations and has developed an action plan to address them by June 2026. For further details see Annex B.

1.0 Introduction

1.1 Context

At AAFC, hazardous products are used in a variety of work environments due to the nature of work conducted across its RDCs. RDCs include a variety of unique work environments where staff may use a variety of hazardous products such as laboratory chemicals and pesticides to carry out their research in laboratories and greenhouses, as well as fuel for fleet vehicles and scientific equipment. AAFC must ensure that hazardous products are being used and handled in a responsible manner that is safe for employees and that aligns with applicable legislation, regulations and policies.

A variety of legislation outlines the proper use and handling of hazardous products including the Canada Labour Code - Part II, the Hazardous Products Act and related regulations. As a federal department, AAFC must comply with requirements and expectations set out in government-wide legislation, regulations and policies as well as the provincial legislation applicable to where each RDC is located. In addition, the department is required to have a prescribed program for the prevention of hazards unique to the workplace that includes an education and training program.

At a national level, AAFC's Corporate Management Branch supports the development, implementation, promotion and monitoring of Occupational Health and Safety (OHS) by providing information on hazards and their prevention, including hazardous products. In April 2025, following the completion of the audit testing, but before the report was issued, the Deputy Minister announced the creation of a new Human Resources Branch, headed by a Director General reporting directly to the Deputy Minister. The National OHS Program reports within this new branch.

Within RDCs, managers and employees have the responsibility to ensure that hazardous products are being used in a safe and responsible manner.

1.2 Risk context

AAFC's RDCs include work environments such as laboratories and farms which are higher risk workplace environments due to the hazardous materials present. Proper oversight and controls for the management of hazardous products are critical to ensuring the health and safety of employees and the public.

This audit was included in AAFC's 2024-25 to 2028-29 Audit and Evaluation Plan due to the risks related to the handling of hazardous products, including potential impacts on health and safety. AAFC senior management noted this as an area of potential concern in the event that safe handling, storage and monitoring practices are not established and being followed, particularly given the significant regulatory requirements around hazardous products in the workplace.

Following a risk assessment during the audit planning phase, we identified three audit criteria for further examination:

Criterion 1 — oversight

• Roles and responsibilities are clearly defined, and monitoring is conducted as required for the management of hazardous products.

Criterion 2 — Compliance with regulatory requirements

• Procedures are established and followed: Procedures for safe storage, use, handling and disposal of hazardous products are established and are being followed in accordance with prescribed procedures.
• Records and monitoring: Hazardous products that are used, handled or stored are recorded and monitored to ensure accuracy and completeness.

Criterion 3 — Specialized training

• Employees are provided with training and guidance to ensure safe handling of hazardous products and training is completed and monitored.

1.3 Audit objective, scope and approach

The objective of the audit is to provide assurance that oversight and controls related to the management of hazardous products at AAFC RDCs are in place to support compliance with applicable regulations and guidelines.

The audit scope focused on laboratory chemicals, pesticides and fuel at RDCs, covering a two-year period from January 2023 to December 2024.

The audit did not assess the following:

• procurement practices related to purchasing hazardous products
• containment, Biosafety and Biosecurity or Radiation Safety Programs
• areas monitored and inspected by non-AAFC regulatory/government bodies
• transportation of Dangerous Goods, except for the certification required when handling hazardous waste

We gathered evidence through various methods including interviews with Science and Technology Branch and Corporate Management Branch, documentation review, analysis of training data and site visits at five RDCs. We used judgmental sampling at the locations visited to test controls and the implementation of processes. The results from the samples tested cannot be used to determine overall departmental compliance levels.

More details about the audit objective, scope, criteria and approach are in Annex A: About the audit.

2.0 Detailed observations and recommendations

2.1 Oversight

The Canada Labour Code — Part II requires that a prescribed program for the prevention of hazards unique to a workplace, including an education and training program, be developed, implemented and monitored.

We examined whether roles and responsibilities were clearly defined for the management of hazardous products and if monitoring was conducted as required.

Overall, we found that AAFC has elements of oversight for the management of laboratory chemicals, pesticides and fuel, but the components of the National Laboratory Safety Program and key roles and responsibilities for management of the program are not clearly defined.

2.1.1 Roles and responsibilities

Clearly defined roles and responsibilities around the implementation and monitoring of health and safety programs enable accountability for effective oversight and support compliance with regulations.

We examined whether roles and responsibilities were clearly defined and if monitoring was conducted as required for the management of hazardous products.

What the audit found

We found that key roles and responsibilities for the management and monitoring of hazardous products are not clearly defined.

Regulations require that employers develop a prescribed program for the prevention of hazards unique to the workplace. A prescribed program should be a formalized, documented approach that details the training, education, tools and resources for the prevention of hazards and should outline clear roles and responsibilities for how the program will be implemented and monitored.

At the departmental level, while we observed that AAFC has some components of a prescribed program for managing hazardous products, such as the Laboratory Safety Manual, Laboratory Orientation training and the AAFC Workplace Hazard Management Identification System (WHMIS) Standard, there are other key components that are not in place. While we observed reference to a prescribed program, titled the National Laboratory Safety Program, the program is not defined, as required by regulations, that brings the above-mentioned components together.

Roles and responsibilities for the management of hazardous products as noted in the Laboratory Safety Manual are unclear for both the national and local level. We found that the responsibility for monitoring the implementation of the National Laboratory Safety Program at a national level was not clearly assigned. Additionally, roles and responsibilities for senior management at RDCs do not state the implementation and monitoring expectations for the National Laboratory Safety Program at a local level. In the absence of a defined program, it is unclear what is expected to be implemented and monitored.

Why this matters

A clearly defined and prescribed program for the management of hazardous products is necessary so that AAFC can demonstrate conformance with regulations and also ensures that those with responsibility are aware of what needs to be implemented and monitored, and confirm that there is adequate coverage of responsibilities.

Recommendation 1

Assistant Deputy Ministers, Science and Technology Branch, in consultation with the Director General, Human Resources Branch, should ensure that key roles and responsibilities for the management of hazardous products are clarified, including how AAFC's National Laboratory Safety Program supports compliance with regulations.

2.2 Compliance with regulatory requirements

There are a number of federal and provincial requirements for the safe handling, management, and disposal of hazardous products including:

• Canada Labour Code — Part II
• Canada OHS regulations
• Hazardous Products Act and Regulations
• Transportation of Dangerous Goods Regulations
• National Joint Council OHS Directive
• Provincial requirements

We examined whether procedures for safe storage, use, handling and disposal of hazardous products were established in accordance with regulatory requirements, and being followed. We also examined whether hazardous products were recorded and monitored to ensure they are accurate and complete.

Overall, we found that processes and procedures exist for using laboratory chemicals, pesticides and fuel. However, updates are required for pesticide disposal. We found that gaps exist in the implementation of processes and procedures including the recording and monitoring of laboratory chemicals and pesticides.

2.2.1 Processes and procedures

Processes and procedures are essential to support safe work practices and ensure compliance with regulatory requirements.

We examined whether procedures for safe storage, use, handling and disposal of hazardous products were established and aligned with federal and provincial requirements.

What the audit found

We found that processes and procedures for the safe storage, use, handling and disposal of hazardous products were established at the departmental and RDC levels.

Departmentally, AAFC has a Laboratory Safety Manual and a Chemical Emergency Response Plan Standard, which outline the proper storage, use, handling and disposal of hazardous products and what to do in the event of a chemical spill. We also observed that AAFC has a Job Safety Analysis document that outlines the safe work procedures while using a fuel station.

At the RDCs visited, documentation for the safe storage, use, handling and disposal of laboratory chemicals, pesticides and fuel were in place in the form of safe work procedures, standard operating procedures, guidelines and/or Job Safety Analysis documents. While these processes and procedures generally aligned with federal and provincial requirements, we did note that RDC-level documentation lacked procedures for disposal of empty pesticide containers as required by the National Joint Council OHS Directive.

Why this matters

Complete site-specific procedures for the safe storage, handling, use and disposal of hazardous products, such as pesticides, support safe work practices and ensure compliance with regulations.

2.2.2 Compliance with processes and procedures

Ensuring that appropriate processes and procedures are followed when working with hazardous products help to prevent work-related injuries and ensures compliance with required regulations.

We examined whether processes and procedures for safe storage, use, handling and disposal of laboratory chemicals, pesticides and fuel are being followed in accordance with prescribed procedures. To complete this work, we performed control testing at the five RDCs visited in the following areas:

• Chemical Emergency Response Plans
• Safety Data Sheets
• Hazardous products storage, labelling and warning signs

What the audit found

Chemical Emergency Response Plans

Each AAFC RDC is required to complete the AAFC Chemical Emergency Response Plan Standard template based on their site-specific operations, to plan for response to potential chemical spills. The site-specific updates must include establishing an inventory of high-risk locations and situations that may be considered a major risk for chemical spills. This inventory is then used to conduct a risk assessment to establish the workplace response for the RDC. We found that these inventories have not been reviewed and discussed on an annual basis by the Workplace OHS Committee, as required by the Chemical Emergency Response Plan Standard.

All five RDCs visited had a site-specific Chemical Emergency Response Plan. However, inventories of high-risk areas in the workplace and annual review of risk assessments were not consistently conducted or discussed at Workplace OHS Committees. Of the five RDCs visited, three had not updated their Chemical Emergency Response Plan based on the current AAFC Standard and had not conducted a site-specific risk assessment. In addition, in reviewing Workplace OHS Committee meetings minutes from 2023 and 2024, we noted that four RDCs did not have the required discussions on the inventory of high-risk areas.

Safety Data Sheets

A Safety Data Sheet is a document that provides information about the hazards and advice on safety precautions when working with the product. The Canada OHS Regulations requires that Safety Data Sheets for hazardous products be readily available for examination by employees, in both English and French, and that they be updated every three years. In addition, for pesticides, the National Joint Council OHS Directive requires that Safety Data Sheets be readily accessible in both paper and electronic formats.

We observed that Safety Data Sheets for hazardous products were generally available at the RDCs visited. However, they did not conform to all requirements. Specifically:

• Safety Data Sheets were stored on-site and readily available for all laboratory chemicals that were sampled except for one RDC. We observed however, that 20 of 38 Safety Data Sheets were not the most recent version and that 36 of 38 were not bilingual as required
• Half of the sampled Safety Data Sheets for pesticides were not available in both paper and electronic format, and the majority were not the most recent version or bilingual
• Safety Data Sheets for fuel were not readily available. Of the five RDCs visited, three did not have a readily accessible Safety Data Sheet. Two sites had Safety Data Sheets readily accessible and up-to-date; however, they were not bilingual

Hazardous products storage, labelling and warning signs

Canada OHS Regulations, WHMIS, Transportation of Dangerous Goods Regulations, and departmental policies outline the requirements for proper storage, labelling and warning signs for the hazardous products in a workplace. We observed that there is room for improvement for chemical waste labelling and the posting of warning signs.

The AAFC WHMIS Standard requires that each laboratory entrance be appropriately labelled with accurate WHMIS symbols to provide guidance to visitors about the hazardous products used inside the laboratory. Of the 16 laboratories we visited, 31% did not have the required WHMIS symbols posted at the laboratory entrances.

We also examined whether laboratory chemical hazardous waste containers included key information as stated in the Laboratory Safety Manual. For the sample reviewed, we found that 40% of waste container labels did not include the required information.

At the RDCs visited, all pesticides sampled were properly stored and labelled, and had warning signs were posted outside the storage areas. Of the 50 laboratory chemicals sampled, all were properly stored and had the necessary labels. However, 11 of 40 applicable labels were not up-to-date with the current WHMIS labelling requirements.

For all RDCs visited, we found that the access to fuel was controlled to prevent any unauthorized access, however three of the five fuel stations did not have warning/hazard signs posted to warn of the presence of the hazardous substance. In addition, standard operating procedures and spill response plans for fuel stations were not readily available at the fuel stations at the sites visited, as required.

Why this matters

Regular risk assessments, current and bilingual Safety Data Sheets, and clear hazard warning signs support compliance with the Canada Labour Code and Canada OHS Regulations. Ensuring that safety information is current and bilingual helps ensure that employees respond quickly and safely in emergencies, such as a chemical spill.

2.2.3 Records and monitoring

Maintaining accurate records of hazardous products is essential for demonstrating compliance with regulatory requirements and supporting workplace safety.

We examined whether laboratory chemicals and pesticides that are used, handled or stored were recorded and monitored to ensure accuracy and completeness.

What the audit found

The Canada Labour Code — Part II requires that Workplace OHS Committees conduct annual inspections of the entire workplace to identify hazards. We found that monthly inspections are being performed in laboratories and other areas where hazardous products are being used, and the results are being recorded and discussed during Workplace OHS Committee meetings.

The Canada OHS Regulations also require that every employer keep a record of all hazardous substances that are used, handled or stored in the workplace. We observed that inventories of chemicals exist at RDCs in varying levels of completeness but are not being consistently maintained.

AAFC's Laboratory Safety Manual requires that each facility maintain an inventory of the hazardous substances used within each RDC. Prior to 2018, AAFC took a national approach to maintaining chemical inventories by using one system across the department for recording and monitoring laboratory chemicals. In 2018, this system was decommissioned and AAFC was in the process of procuring a new system as of the beginning of 2025.

Based on interviews, the delay in the procurement of a new national inventory system has resulted in confusion at RDCs and lack of clarity regarding requirements for the maintenance and monitoring of inventories. Of the five sites visited, one centre was not able to provide us an inventory of chemicals.

Interviews noted that RDCs are maintaining inventories to varying degree. Three of the sites visited were not consistently conducting physical verification of their inventories for chemicals. Furthermore, inventories of chemicals were incomplete as we found that 9 of 47 laboratory chemicals sampled could not be found in the inventories provided.

For the four RDCs visited that use pesticides, inventories were maintained and verified annually, as required by the National Joint Council OHS Directive. However, inventories were incomplete as we found that 3 of 12 pesticides sampled were not found in the inventories.

Why this matters

Maintaining accurate and complete inventories of hazardous substances on a consistent basis helps ensure that employees are aware of the hazardous substances present in each work area and to comply with regulatory requirements.

Recommendation 2

Assistant Deputy Ministers, Science and Technology Branch, should ensure that local hazardous products safety procedures/guidelines are updated, and ensure that key requirements are implemented including the recording and monitoring of hazardous products inventories to comply with regulations.

2.3 Specialized training

Providing education and specialized training to employees who handle hazardous products helps to ensure safe practices, prevent harm and supports compliance with health and safety requirements.

We examined whether employees were provided with training and guidance to ensure safe handling of hazardous products and if training was being completed and monitored as required.

We found that specialized training for hazardous products was provided to employees, however the tracking and monitoring of specialized training completion needs improvement.

2.3.1 Training provided, completed and monitored

What the audit found

Training provided

We found that specialized training was provided at RDCs through departmentally developed in-person training and through third-party providers.

Specialized training requirements for dealing with laboratory chemicals, pesticides, hazardous waste and fuel are outlined in the Laboratory Safety Manual and the AAFC OHS Training Standard. Training requirements include the following:

• AAFC Laboratory Safety Orientation training, which RDCs update for their specific centre and is delivered to new employees prior to working in a laboratory
• WHMIS training is delivered, across the department by a third party that is hired by the CMB Corporate OHS team. Employees are required to retake WHMIS every three years
• Provincial training, provided to employees who spray pesticides or who handle hazardous waste at their RDC, as required by the National Joint Council OHS Directive and Transportation of Dangerous Goods Regulations
• Job specific training is provided by supervisors and managers, such as refuelling vehicles, to employees before they perform a hazardous task

Training completion and monitoring

We found that while certain specialized training is being completed, the tracking and monitoring of specialized training related to hazardous products can be improved.

We requested and reviewed training completion data from the five RDCs visited and found that specialized training was being completed for the following:

• Transportation of Dangerous Goods certifications and pesticide applicator licences were completed and up-to-date for employees who handle hazardous waste or who spray pesticides.
• Laboratory Safety Orientation training completion records for recently hired laboratory workers were provided by four of the five RDCs visited. One RDC noted that they do not keep records of Laboratory Safety Orientation training completion.

We heard through interviews that AAFC has a culture that is committed to the health and safety of its employees and interviewees were aware of training requirements. However, evidence of completed training in the areas of refuelling safe work procedures and WHMIS were lacking. Our review of training records and interviews found that:

• Evidence of signed safe work procedures for refuelling a vehicle did not exist to support that they had been reviewed by employees as required. However, interviews noted that new employees are provided with the safe work procedures and shown how to safely use fuel pumps before refuelling a vehicle.
• WHMIS training completion is not being accurately monitored. Based on interviews with RDCs, there are differing practices for tracking and follow-up of WHMIS training completion such as relying on corporate OHS WHMIS training data and tracking at individual RDCs. Analysis of corporate OHS WHMIS training data for indeterminate employees identified that as of October 31, 2024, only 37% had completed WHMIS training in the past three years.

Why this matters

Ensuring that all employees are provided specialized training to safely perform their work, that accurate records of training completion are maintained, and that follow-up is conducted to confirm that training is up-to-date helps to increase the safety of all employees and ensures that the department is in compliance with Canada Labour Code requirements.

Recommendation 3

Assistant Deputy Ministers, Science and Technology Branch and the Director General, Human Resources Branch, should ensure that the monitoring and follow-up of mandatory specialized training for working with hazardous products is improved.

3.0 Conclusion

The audit concluded that AAFC has elements of oversight and controls related to the management of hazardous products at AAFC RDCs to support compliance with applicable regulations and guidelines.

However, opportunities exist for further improvement by:

• clarifying the National Laboratory Safety Program, as well as roles and responsibilities
• updating procedures and guidelines
• ensuring implementation of key requirements
• monitoring of specialized training completion

Management response and action plan

Management agrees with the audit recommendations and has developed an action plan to address them by June 2026. For further details see Annex B.

Annex A: About the audit

Statement of conformance

The audit conformed to the Institute of Internal Auditors' International Professional Practices Framework, as supported by the results of AAFC's internal audit quality assurance and improvement program. Sufficient and appropriate evidence was gathered in accordance with the Global Internal Audit Standards to provide a reasonable level of assurance over the findings and conclusion in this report. The findings and conclusion expressed in this report are based on conditions as they existed at the time of the audit and apply only to the areas included in the audit scope.

Audit objective

To provide assurance that oversight and controls related to the management of hazardous products at AAFC RDCs are in place to support compliance with applicable regulations and guidelines.

Audit scope

The audit scope focused on laboratory chemicals, pesticides and fuel at RDCs, covering the period of January 2023 to December 2024. We also looked at relevant activities prior to this period to gain a more complete understanding of the subject matter.

The audit did not assess the following:

• Procurement practices related to purchasing hazardous products
• Containment, biosafety and biosecurity or radiation safety programs
• Areas monitored and inspected by non-AAFC regulatory/government bodies
• Transportation of dangerous goods, except for the certification required when handling hazardous waste

Audit criteria

Based on a risk assessment, the following criteria were developed to ensure sufficient and appropriate evidence was collected and examined to support the audit conclusion:

Criterion 1 — Oversight

• Roles and responsibilities are clearly defined and monitoring is conducted as required for the management of hazardous products.

Criterion 2 — Compliance with regulatory requirements

• Procedures are established and followed: Procedures for safe storage, use, handling and disposal of hazardous products are established and are being followed in accordance with prescribed procedures.
• Records and monitoring: Hazardous products that are used, handled or stored are recorded and monitored to ensure accuracy and completeness.

Criterion 3 — Specialized training

• Employees are provided with training and guidance to ensure safe handling of hazardous products and training is completed and monitored.

Audit approach

The audit approach was risk-based and consistent with the Institute of Internal Auditors' International Professional Practices Framework. The Global Internal Audit Standards require that the audit be planned and performed in such a way as to conclude against the audit objective. The audit was conducted in accordance with an audit program, which defined audit tasks to be performed to obtain and examine sufficient and appropriate evidence to assess each audit criterion.

The audit conducted the following work to complete the engagement:

• review of documents, such as applicable legislation and regulations, AAFC and RDC documentation related to hazardous products
• interviews with STB and CMB management and employees
• analysis of WHMIS training data
• site visits to five RDCs

Annex B: Management response and action plan