Audit of occupational health and safety

Abbreviations

AAFC

Agriculture and Agri-Food Canada

ADRDT

Associate Director of Research, Development and Technology

DGMC

Director General Management Committee

HPP

Hazard Prevention Program

OHS

Occupational Health and Safety

RDC

Research and development centre

SMC

Senior Management Committee

Executive summary

Agriculture and Agri-Food Canada (AAFC) is a large organization with over 5,000 employees and students in 2024-25. The department's workplaces include office buildings as well as a network of 20 research and development centres (RDCs) and 30 satellite locations. These RDCs include workplace environments like laboratories and farms. Health and safety risks are higher at these locations due to the presence of hazardous materials, specialized equipment, and unique operational hazards. To safeguard people at its locations, AAFC must adhere to health and safety expectations set out in federal legislation and policies.

The Audit of Occupational Health and Safety (OHS) was included in the 2024-25 Audit and Evaluation Plan due to the complexity of delivering OHS in AAFC's diverse workplaces and the significant regulatory compliance and reporting requirements.

The audit objective was to provide assurance that AAFC has OHS procedures and practices in place to support compliance with the Canada Labour Code Part II, and other related regulations. The audit assessed AAFC's oversight, workplace-level OHS program implementation, and mandatory OHS training. The audit testing on the workplace-level OHS implementation focussed on RDC worksites due to their higher risk.

Overall, the audit concluded that AAFC has OHS procedures and practices in place for the areas assessed to support compliance with the Canada Labour Code Part II and related regulations. However, there were opportunities for improvement related to:

• OHS information shared with senior management and departmental senior management governance committees;
• Monitoring the National OHS Risk Assessment;
• Guidance and support for workplace OHS; and
• Mandatory 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 Overview of occupational health and safety

The Canada Labour Code Part II, the Canada OHS Regulations and other legislative requirements provide employers, employees and OHS policy committees with a set of rights, responsibilities, practices and expectations to follow. These are intended to prevent accidents and injuries in the workplace.

AAFC's 2024 OHS Policy outlines the departmental expectations for OHS, for ensuring "AAFC workplaces are healthy, safe, respectful and free of harassment and violence by meeting legal requirements and implementing best practices", and "OHS, including physical and psychological health and safety, is integrated into AAFC's management and business decision-making processes, and part of its corporate culture". AAFC, as an employer, must develop, implement and monitor a Hazard Prevention Program (HPP). Additionally, it must track data on OHS hazards and incidents.

At the time of the audit, the Corporate Management Branch was accountable for developing and implementing OHS policies and programs. In April 2025, following the completion of the audit testing, but before the report was issued, the Deputy Minister announced the creation of the Human Resources Branch, headed by a Director General reporting directly to the Deputy Minister. The National OHS Program reports within this new branch. The National OHS Program, as outlined in the AAFC OHS Policy, is responsible for developing policies, programs, guidelines, and tools that support compliance with OHS requirements and promote a consistent approach across AAFC. It also oversees, monitors, and reports on OHS matters throughout the department.

OHS is a shared responsibility between AAFC, as the employer, and all employees. AAFC's National OHS Policy Committee is a forum where senior management and employee representatives discuss OHS matters. The National OHS Policy Committee helps plan and implement national OHS changes, develop policies and programs with the National OHS Program team, monitor OHS programs and data, and make recommendations to the National OHS Program team and management.

At RDCs, the Associate Directors of Research, Development and Technology (ADRDTs) within the Science and Technology Branch are the Senior Building Officers responsible for OHS, in accordance with AAFC's OHS Policy. They are responsible for establishing a Workplace OHS Committee at sites with 20 or more employees and ensuring the committee fulfills its duties. They also serve as the employer co-chair on the Workplace OHS Committee and oversee the implementation of OHS program requirements and emergency response measures at RDCs.

1.2 Risk context

AAFC is a large organization with approximately 5,000 employees and students in 2024-25. The department's workplaces include office buildings as well as a network of 20 RDCs and 30 satellite locations. These RDCs include workplace environments like laboratories and farms which are higher risk workplace environments due to hazardous materials, specialized equipment and unique operational hazards. In April 2025, approximately half of AAFC's workforce was located at RDCs.

This audit was included in the 2024–25 Audit and Evaluation Plan due to the complexity of delivering OHS in AAFC's diverse workplaces and the significant regulatory compliance and reporting requirements.

Following a risk assessment during the audit's planning phase, we identified the following specific risk areas for further examination:

• Oversight
  • Oversight of the departmental OHS program is supported by complete and timely OHS information.
  • The Hazard Prevention Program is monitored for its effectiveness in preventing workplace hazards.
• Workplace-level occupational health and safety program implementation
  • At the workplace level, the OHS program is effectively administered and supported.
  • Procedures are in place to identify and communicate workplace hazards and safety measures.
  • Identified health and safety issues are resolved in a timely manner.
• Training and awareness
  • Employees, including students, complete training, and are provided with information to ensure they are aware of safety policies and their rights and responsibilities.

1.3 Audit objective, scope and approach

The audit objective was to provide assurance that AAFC has OHS procedures and practices in place to support compliance with the Canada Labour Code and related regulations.

The audit scope included assessing AAFC's compliance with Canada Labour Code Part II, the Canada OHS regulation, and other relevant legislative requirements for the areas reviewed.

The audit examined workplace-level OHS implementation, with the focus on RDC worksites because of their highest risk.

The audit scope did not include assessing the following, as they will be considered for future audits:

• real property, except for consideration of the Workplace OHS Committee role for inspection
• vehicle maintenance
• workplace harassment and violence
• ergonomics

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

We examined whether oversight of the National OHS Program is supported by complete and timely OHS information and whether the HPP is monitored for its effectiveness in preventing workplace hazards.

Overall, we found that OHS information is provided to senior management with assigned OHS roles, such as for those who directly manage OHS programs or participate on the National OHS Policy Committee. However, AAFC's Deputy Minister-level and Director General-level senior governance committees are not regularly provided with OHS information and managers are not updated with OHS information for the AAFC locations where they have direct-reporting employees.

We also found that the National OHS Program team is monitoring the effectiveness of the HPP through various mechanisms. However, the risks identified in the HPP Review Plan are out of date and some are unassessed.

2.1.1 OHS information sharing with senior management

What the audit found

In addition to the National OHS Policy Committee, AAFC has two senior governance committees with departmental oversight roles for OHS: the Senior Management Committee (SMC) and the Director General Management Committee (DGMC). SMC is an Assistant Deputy Minister-level committee that provides strategic advice to support the Deputy Minister in fostering sound institutional management across its internal services, which includes OHS. Reporting to the SMC, DGMC is a Director General-level committee and OHS falls within its mandate covering human resources and people management.

To assess how these senior governance committees fulfilled their OHS-related mandates defined in their terms of reference, we reviewed SMC and DGMC meeting records from January 2018 to December 2024. We observed that OHS matters were not regularly presented to these senior governance committees. During this period, OHS was not included on the SMC agenda and was included twice on the DGMC agenda. The most recent OHS item presented to DGMC was in January 2021 on AAFC's Harassment and Violence in the Workplace Policy.

AAFC has an established National OHS Policy Committee with representation from the employer and employee unions. The committee provides an advisory role and participates in the development, implementation, and monitoring of the National OHS Program. The committee includes senior management representatives from Corporate Management Branch, Science and Technology Branch, and Programs Branch.

OHS information is prepared and shared with senior management involved in the management of the National OHS Program and members of the National OHS Policy Committee. Specifically, we observed that the National OHS Program team compiles the OHS data from across AAFC and prepares the mandatory departmental OHS reporting that it submits annually to Employment and Social Development Canada. These reports are related to the activities of the workplace OHS committees as well as hazardous incidents. The departmental reports are reviewed by the Assistant Deputy Minister Corporate Management Branch, the Director General Human Resources, and members of the National OHS Policy Committee.

There are no formal mechanisms in place to ensure OHS information is routinely provided to Science and Technology Branch Regional Directors General, who are each responsible for an AAFC region comprised of multiple RDCs. Interviews with these Regional Directors General noted they typically receive OHS information only for the sites where they are physically located. While they receive ad hoc OHS information from ADRDTs within their regions, they do not receive regular OHS reporting for all sites within their respective regions, and national OHS information is generally not shared with them.

The audit also noted through interviews that managers who have employees physically located at different locations than themselves are not provided with OHS data specific to their employees' physical locations.

Why this matters

Departmental senior management sets the tone for an organization's OHS culture. Their engagement in OHS demonstrates a commitment to workplace health and safety and enhances awareness of the OHS program. Providing senior governance committees with regular updates on the national OHS program increases awareness of departmental issues and risks and enhances the committees' ability to implement proactive safety measures.

As AAFC has moved toward having more regionally dispersed teams following the COVID-19 pandemic, it is important for managers to be aware of the OHS issues at all locations where they have employees so that they can provide them with informed support. For those employees located at RDCs, AAFC's Instrument of Human Resources Authorities notes that ADRDTs, as the senior employer representatives at RDCs, are the delegated authority for health and safety matters over employees from other branches (with some specific limitations). However, this delegated authority does not absolve other supervisors of their legal responsibility for the health and safety of employees reporting to them.

2.1.2 Monitoring of the HPP

Departmental roles and responsibilities for monitoring the HPP are defined in the HPP framework, which includes the Canada Labour Code Part II and regulations, guidance, and AAFC policies. This framework outlines the roles and responsibilities of key stakeholders, including the National OHS Policy Committee, the National OHS Program team, workplace OHS committees, and regional OHS advisors.

The Canada Labour Code Part II and regulations require the employer, in consultation with the National OHS Policy Committee, to monitor the HPP. Monitoring information is obtained from workplace data, OHS reports, and input from the workplace OHS committees.

What the audit found

We found that the National OHS Program team collects and analyzes HPP monitoring data from various sources. This includes information on Workplace OHS Committee activities and annual reports submitted to Employment and Social Development Canada's Labour Program. These annual reports include the Workplace Committee Report and the Employer's Annual Hazardous Occurrence Report, which document Workplace OHS Committee activities, hazardous incidents, and other workplace safety information. They are provided to the National OHS Policy Committee for review and discussion.

The National OHS Program team conducted a 15-question self-assessment survey of workplace OHS committees in 2023 on workplace health and safety practices and gaps. While it yielded useful information, it did not fully cover all responsibility areas so, for 2025, the National OHS Program team enhanced the survey to obtain more comprehensive feedback across all areas of the HPP.

We found that AAFC has an HPP Review Plan that includes the monitoring of 51 OHS programs. We observed that 48 of the programs had been reviewed within the three-year requirement and while three programs were overdue for review, work was underway and being monitored by the National OHS Program team.

We also found that the HPP Review Plan includes a National OHS Risk Assessment, which supports the identification of new programs that are needed or existing programs that require updates. However, the risk assessment has not been updated since 2017. Additionally, 16 of the 42 identified risks have not been evaluated for potential impact and likelihood, limiting the ability of decision-makers to effectively prioritize the implementation of corrective actions.

Why this matters

Monitoring the HPP helps ensure compliance with federal legislation, AAFC policies, and established safety guidelines. It also identifies and addresses gaps in workplace health and safety practices and enables proactive risk management and compliance measures.

The audit also identified findings related to the monitoring of mandatory training that, coupled with the findings above, lead to Recommendation 1. Refer to section 2.3 Training and awareness.

Recommendation 1

The Director General, Human Resources Branch should ensure that:

• Annual updates on the OHS program, including the monitoring of mandatory training, are provided to relevant senior governance committees.
• Managers are informed about OHS issues at locations where they have employees.

Recommendation 2

The Director General, Human Resources Branch should ensure the National OHS Risk Assessment, as a part of the HPP Review Plan, is regularly updated and the risks are assessed in a timely manner.

2.2 Workplace-level OHS program implementation

We assessed the effectiveness of the OHS program's administration and support at the workplace level, as provided by workplace OHS committees and regional OHS advisors. We determined whether their roles and responsibilities are clearly defined and whether they are effectively carrying out tasks related to administering the OHS program, including identifying health and safety issues and resolving them in a timely manner.

We found that workplace OHS committees have clearly defined roles and responsibilities outlined in their terms of reference and effectively administer the OHS program in most areas. However, the information documented for tracking health and safety issues is inconsistent and makes it difficult to determine whether issues are being resolved in a timely manner.

We also found that while the roles and responsibilities of regional OHS advisors are documented, ADRDTs remain unclear about the level of support advisors are expected to provide to RDCs.

Since December 2023, regional OHS advisors have reported to the Corporate Management Branch National OHS Program team, supporting OHS implementation at RDCs by providing OHS-related services to managers, supervisors, employees, and workplace OHS committees within their designated regions. Prior to December 2023, this position reported functionally to the National OHS Program team within the Corporate Management Branch and administratively to the ADRDTs in the Science and Technology Branch. They provided support to the RDCs where they were physically located as well as to the other AAFC facilities in their region.

What the audit found

We selected a judgmental sample of six RDCs and reviewed their Workplace OHS Committee documentation to assess the effectiveness of workplace OHS program implementation controls and did not assess overall departmental compliance levels. We found that all six have terms of reference for their committees that clearly outline roles and responsibilities, including for addressing health and safety issues and participating in incident investigations with trained investigators. These committees establish health and safety inspection schedules at their respective RDCs and conduct inspections in a timely manner. Additionally, the committee membership includes representation from both the employer and employees that aligns with their terms of reference.

However, we observed incomplete and inconsistent documentation and monitoring of health and safety issues across workplace OHS committees sampled. More specifically, we observed workplace OHS committees are using several different tools to document and track issues, including spreadsheets and Workplace OHS Committee meeting minutes. The level of detail recorded for OHS issues varied, ranging from comprehensive to incomplete, with some records missing critical information such as the date of the original occurrence, risk level of the issue, recommendations for resolution, individuals assigned to resolution, and the status of actions taken. The tracking documentation does not always accurately reflect the status of reported issues as some RDCs do not update the documentation until the following year's inspection cycle. As a result, it was difficult to determine whether issues identified during inspections are being resolved in a timely manner. We interviewed the National OHS Program team, ADRDTs, and Workplace OHS Committee members and confirmed that they had concerns about the issue tracking and follow-up practices.

Additionally, interviews raised concerns about inconsistencies among workplace OHS committees when recording health and safety issues identified during inspections. Although training on inspections provides general guidance on hazard identification and classification, we observed differences in practice. For example, some committees documented a broken window as an OHS issue requiring follow-up, while others did not consider it an OHS concern for tracking purposes.

As the Senior Building Officers at RDCs, ADRDTs are accountable for OHS and co-chair the local workplace OHS committees. They are supported in their roles by the regional OHS advisors. We found the roles and responsibilities of the regional OHS advisors are outlined in the 2024 AAFC OHS Policy and the OHS Roles and Responsibilities Chart prepared by the National OHS Program team in Corporate Management Branch. While the Regional OHS Advisor roles and responsibilities were documented, interviews with the ADRDTs in Science and Technology Branch expressed that they remain unclear about the support regional OHS advisors are expected to provide to RDCs.

Some RDCs have created Site Safety Coordinator positions to support the local implementation of OHS tasks and supplement the support they receive from regional OHS advisors. These tasks typically include providing OHS orientation training, monitoring training records, following up on investigations and inspections, and assisting with OHS documentation.

Why this matters

Effective collaboration and coordination between the ADRDTs and Workplace OHS Committees at RDCs and the regional OHS advisors from the National OHS Program team are essential to successful OHS implementation. This includes addressing the identified gaps in health and safety issue documentation and tracking, by providing ADRDTs and Workplace OHS Committees at RDCs with additional OHS guidance and support. This will facilitate consistent practices in documenting, monitoring, and resolving health and safety issues in a timely manner.

Recommendation 3

The Director General, Human Resources Branch should:

• ensure there is clear guidance to enable workplace OHS committees to consistently document, track and resolve identified OHS-related hazards in a timely manner
• clearly define the roles and responsibilities related to OHS support at research and development centres and ensure clear accountability for addressing gaps in OHS support is assigned, in collaboration with the Assistant Deputy Ministers, Science and Technology Branch

2.3 Training and awareness

We assessed whether mandatory OHS training requirements are well-documented and effectively communicated. Additionally, we examined whether Corporate Management Branch and Science and Technology Branch employees, students and Workplace OHS Committee members completed the mandatory training and if tools are in place to monitor its timely completion.

We confirmed that mandatory OHS training requirements are well-documented and effectively communicated. However, Corporate Management Branch and Science and Technology Branch employees, students and Workplace OHS Committee members have not consistently completed the required training.

What the audit found

We observed that AAFC's mandatory OHS training requirements for new employees, including students, are well-documented and widely available. The required courses, which are to be completed within 10 days of starting with the department, are included in the onboarding process available through the department's AgriSource intranet site. The Canada School of Public Service delivers online OHS training and AAFC tracks training completion in the departmental mandatory training tracker, AgriCampus, which has been accessible to all employees since February 2023.

To verify whether training was completed, we reviewed the Corporate Management Branch and Science and Technology Branch training records for employees and students who began their positions at AAFC between April 1, 2022, and November 6, 2024, and had been employed for more than 10 days. We found that approximately one in five (22% or 166/771) non EX-employees and one in four (28% or 138/500) students had not completed the mandatory OHS training.

We also reviewed the training records of a judgmental sample of 24 Workplace OHS Committee members as of November 2024 to determine the effectiveness of the training control. While this review cannot translate into an overall compliance result, we found that 75% had not completed the three mandatory training courses required for their role. Specifically, 50% (12/24) had completed two of the three required courses, while 25% (6/24) had completed only one. As such, Workplace OHS Committee member training was not being consistently completed in line with the mandatory training requirements.

Why this matters

Mandatory OHS training provides employees and students with information on workplace safety policies, potential hazards, and their rights and responsibilities under OHS regulations. They need to complete this training quickly upon starting in their role as it promotes a safe work environment which reduces the risk of workplace injuries and ensures compliance with legal and departmental requirements. Workplace OHS Committee training is required as it ensures members have the knowledge and skills needed to effectively perform their duties and support a safe and healthy work environment.

While the audit observed that training requirements were well-documented and communicated, the completion rate could be improved. Sharing training completion rates at relevant senior governance committees reinforces management accountability, demonstrates due diligence and helps promote a strong health and safety culture. Recommendation 1 above addresses the need to monitor mandatory training completion.

3.0 Conclusion

Overall, the audit concluded that AAFC has OHS procedures and practices in place for the areas assessed to support compliance with the Canada Labour Code Part II and related regulations. However, there were opportunities for improvement related to:

• OHS information shared with senior management and departmental senior governance committees
• Monitoring the National OHS Risk Assessment
• Guidance and support for workplace OHS
• Mandatory 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

The objective of the audit was to provide assurance that AAFC has OHS procedures and practices in place to support compliance with the Canada Labour Code Part II and related regulations.

Audit scope

The audit assessed AAFC's compliance with Canada Labour Code Part II, the Canada OHS Regulations, and other relevant legislative requirements for the areas being assessed.

The audit testing on the workplace-level OHS implementation focussed on RDC worksites due to their higher risk.

The audit scope did not include assessing the following, as they will be considered for future audits:

• real property, except for consideration of the Workplace OHS Committee role for inspection
• vehicle maintenance
• workplace harassment and violence
• ergonomics

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:

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 regulatory documents, guidelines, committee minutes and other documents
• interviews with AAFC management and employees involved in National OHS Program and Research and Development Centre OHS management
• site visits to four RDCs

Annex B: Management response and action plan