What Does “Reasonably Practicable” Mean Under legislative Occupational Health and Safety Requirements? In practical terms, it means an employer must take health and safety measures that are feasible in the circumstances and appropriate when viewed from the perspective of a reasonable person facing similar circumstances. It is not permission to choose the cheapest option, accept an uncontrolled hazard, or avoid a safety measure simply because implementing it is inconvenient.
This concept matters because Occupational Health and Safety legislation repeatedly places responsibilities on employers and other work site parties to protect health and safety as far as reasonably practicable. The employer’s decisions therefore need to reflect the actual hazard, the level of risk, available controls, workplace circumstances, and what a reasonable employer could be expected to do.
The provincial governments across Canada describes reasonably practicable as fulfilling an OHS legislative obligation in a way that is feasible given the circumstances and appropriate from the perspective of a reasonable person in similar circumstances. The concept recognizes that workplace risk cannot always be completely eliminated, but that does not remove the responsibility to identify hazards and take appropriate action.
A useful way to understand the term is to separate “possible” from “reasonable.”
A control might technically be possible, but the circumstances surrounding the work still have to be considered. At the same time, an employer cannot simply decide that a control is unreasonable because it costs money, affects production, takes additional time, or requires operational changes.
The decision needs to make sense when compared with the hazard and the risk being controlled.
For example, an employer operating forklifts around pedestrians cannot simply conclude that installing barriers is inconvenient and rely on workers to “be careful.” Alberta’s OHS Code specifically addresses the separation of pedestrian traffic from powered mobile equipment where reasonably practicable and requires safe work procedures when designated walkways are not reasonably practicable.
The concept becomes especially important when employers select hazard controls.
As an example, Alberta’s OHS Code establishes requirements for hazard assessment, elimination, and control. Where reasonably practicable, employers are required to eliminate or control hazards through engineering controls before moving to lower levels of control in circumstances addressed by the Code.
This means the decision should start with the hazard, not with the control the employer would prefer to use.
Consider a noisy production area. Providing hearing protection may be easier than modifying equipment, installing barriers, isolating machinery, or addressing the source of the noise. However, Alberta’s requirements call for reasonably practicable measures to reduce worker noise exposure. The existence of PPE does not automatically answer whether other controls should have been considered.
The same principle can arise with fall protection, lifting and handling loads, mobile equipment, hazardous energy, chemical exposure, and many other workplace hazards.
What employers don’t necessarily know is that a reasonable decision made today may need to be reconsidered when circumstances change.
New equipment may become available. A work process may change. An incident may expose a weakness in an existing control. Workers may identify a hazard that management had not previously recognized. A manufacturer may change its instructions. Repeated inspection findings may show that an administrative control is not working.
Reasonably practicable should therefore not be treated as a one-time justification for continuing an existing practice.
There is another important issue. Saying “we decided it wasn’t practical” is considerably different from being able to demonstrate how that decision was reached.
A defensible safety-management process should show that the hazard was recognized, appropriate controls were considered, decisions were made by competent people, workers were informed where appropriate, controls were implemented, and their effectiveness was monitored.
Reasonably practicable and due diligence are closely connected, but they should not be treated as interchangeable terms.
Reasonably practicable frequently describes the standard attached to a particular legislative responsibility. Due diligence generally concerns whether reasonable precautions were taken in the circumstances and whether the organization can demonstrate what it actually did to prevent harm.
Canadian guidance describes due diligence as taking reasonable precautions or steps based on the circumstances. WorkSafeBC similarly describes due diligence as taking all reasonable steps to protect workers and emphasizes awareness of obligations, risk assessment, proactive controls, monitoring, and maintaining evidence of implementation.
Documentation becomes important because an employer may eventually need to explain not only what its procedure said, but what happened in the workplace.
Useful evidence may include:
The purpose is not paperwork for its own sake. The records should demonstrate that the safety system operated as intended.
There is no single five-step statutory test that applies to every Canadian OHS situation. However, employers can use the following practical approach when evaluating their decisions.
This approach supports better operational decisions because it connects legislation, hazard assessment, hazard controls, implementation, and verification rather than treating each as a separate safety activity.
One of the most common weaknesses is relying too heavily on written procedures.
A safety manual might require equipment inspections, hazard assessments, worker training, and supervisor monitoring. If inspections are incomplete, assessments have not been updated, workers cannot explain the procedure, or supervisors tolerate deviations, the written program provides limited evidence that the hazard was actually being controlled.
Another problem is starting with the easiest control.
Employers sometimes move directly from identifying a hazard to providing PPE, signage, training, or a safe work procedure without adequately considering whether the hazard could first be eliminated or controlled through stronger measures.
Cost can also become an oversimplified argument. Business cost is a real operational consideration, but “it costs too much” should not become the entire reasonably practicable analysis, particularly where workers face significant risk and effective controls are available.
Reasonably practicable decisions cannot exist only at senior management level.
Employers establish resources, systems, responsibilities, equipment, training, and expectations. Supervisors translate those requirements into daily work by identifying changing conditions, enforcing procedures, correcting unsafe work, and escalating issues requiring additional resources.
Workers contribute through hazard reporting, following established controls, participating in assessments where applicable, using equipment properly, and communicating when conditions change.
Alberta’s OHS framework places responsibilities on multiple work site parties rather than placing workplace safety responsibility on one individual alone.
Although there are many similarities, there are differences that must be observed. Employers working across Western Canada should avoid copying an Alberta interpretation directly into another province without reviewing that jurisdiction’s legislation.
British Columbia’s Workers Compensation Act and OHS Regulation establish their own duties. WorkSafeBC describes due diligence as taking all reasonable steps to protect workers and expects employers to identify risks, develop controls, train workers, monitor implementation, and maintain evidence.
Saskatchewan also uses reasonably practicable concepts within its occupational health and safety framework. Saskatchewan employer duties include providing and maintaining plant, systems of work, and working environments that protect worker health, safety, and welfare as far as reasonably practicable. Saskatchewan also establishes responsibilities for employers, contractors, supervisors, workers, and, in applicable workplaces, prime contractors.
The underlying Canadian safety principle may be similar: identify hazards, understand risk, implement appropriate controls, and verify that they work. The actual legal wording, responsibilities, required documentation, and enforcement framework remain jurisdiction-specific.
Legislative compliance and COR or SECOR performance are related but separate issues.
In Alberta, COR is a voluntary program that evaluates an employer’s health and safety management system against established standards. The program considers areas such as hazard identification, risk control, training, inspections, emergency response, incident investigation, and system administration.
A strong COR or SECOR system can help employers demonstrate that important safety processes exist and are being used. However, certification does not replace the employer’s responsibility to meet applicable legislation, nor does a successful audit establish that every hazard-control decision will automatically satisfy a reasonably practicable standard.
Reasonably practicable decisions affect considerably more than regulatory compliance.
Weak hazard-control decisions can contribute to incidents, WCB claims, operational interruptions, damaged equipment, retraining, investigations, corrective-action costs, and lost productivity. They can also affect contractor prequalification, client confidence, COR or SECOR performance, audit readiness, and the employer’s ability to demonstrate due diligence.
The opposite is also true. When decisions are documented and connected to actual workplace conditions, management has a clearer understanding of risk and supervisors have better direction about what is expected.
This can make safety controls easier to manage operationally because responsibilities, decisions, and follow-up are visible rather than buried in a safety manual.
Situation: A fabrication company had forklifts regularly travelling through an area also used by employees walking between production and shipping. Workers had been instructed to maintain eye contact with operators and wear high-visibility clothing, but several near misses were reported.
Action: The employer reassessed the traffic hazard, reviewed whether pedestrians and equipment could be separated, examined workflow and access points, involved supervisors and workers, and implemented additional physical and administrative controls. The hazard assessment, decisions, worker communication, and subsequent inspections were documented.
Result: The company had stronger evidence explaining how the hazard had been evaluated and controlled. Supervisors also had clearer expectations for managing pedestrian and mobile-equipment interaction, improving accountability, operational consistency, and audit readiness.
Understanding reasonably practicable requirements often requires employers to look beyond individual sections of legislation and examine how hazard assessment, procedures, training, supervision, inspections, investigations, and corrective actions work together.
Calgary Safety Consultants supports employers across Canada, including organizations operating in Alberta, British Columbia, and Saskatchewan, with OH&S program development, safety manual development and review, COR or SECOR consulting, program assessments, internal audits, workplace inspections, hazard assessment support, incident investigations, corrective-action planning, supervisor and leadership training, online OH&S training, and regulatory compliance support.
Related resources and services include:
Customized Safety Manuals Built for Your Workplace
https://calgarysafetyconsultants.ca/customized-safety-manuals/
COR Consulting and Safety Program Support
https://calgarysafetyconsultants.ca/cor-consulting-and-safety-program-support/
Workplace Safety Training & Certification
https://calgarysafetyconsultants.ca/workplace-safety-training-certification/
Workplace Hazard Assessments | JHAs, and Investigations
https://calgarysafetyconsultants.ca/workplace-hazard-assessments-and-inspections/
OHS Regulatory Support When Orders, Inspections, or Complaints Need Action
https://calgarysafetyconsultants.ca/ohs-regulatory-support/
Employers should periodically review whether their existing hazard controls still reflect workplace conditions, current knowledge, available technology, worker experience, incident history, and applicable legislation.
The important question is not simply, “Do we have a safety procedure?”
A better question is, “If we had to explain why we chose this control today, could we demonstrate that we identified the hazard, understood the risk, considered appropriate alternatives, implemented the control, and verified that it was working?”
That is where reasonably practicable decisions, effective safety management, and due diligence begin to come together.
If your current hazard assessments, safety procedures, or management system do not clearly demonstrate that process, Calgary Safety Consultants can help identify the gaps and develop practical improvements suited to your workplace and jurisdiction.
Government of Alberta. Occupational Health and Safety Act – General Obligations.
https://search-ohs-laws.alberta.ca/legislation/occupational-health-and-safety-act/part-1-general-obligations/
Government of Alberta. Legal Terms 101: “Reasonably Practicable.”
https://open.alberta.ca/publications/ohs-legal-terms-101-reasonably-practicable
Government of Alberta. Occupational Health and Safety Legislation.
https://www.alberta.ca/ohs-legislation
Government of Alberta. Occupational Health and Safety Code – Hazard Assessment, Elimination and Control.
https://search-ohs-laws.alberta.ca/legislation/occupational-health-and-safety-code/part-2-hazard-assessment-elimination-and-control/
Government of Alberta. Occupational Health and Safety Code – Powered Mobile Equipment.
https://search-ohs-laws.alberta.ca/legislation/occupational-health-and-safety-code/part-19-powered-mobile-equipment/
Government of Alberta. Occupational Health and Safety Code – Noise.
https://search-ohs-laws.alberta.ca/legislation/occupational-health-and-safety-code/part-16-noise/
Government of Alberta. Partnerships in Injury Reduction.
https://www.alberta.ca/partnerships-injury-reduction
Government of Alberta. Obligations of Work Site Parties.
https://www.alberta.ca/obligations-work-site-parties
Canadian Centre for Occupational Health and Safety. Health and Safety Legislation in Canada – Due Diligence.
https://www.ccohs.ca/oshanswers/legisl/legislation/diligence.html
WorkSafeBC. Due Diligence.
https://www.worksafebc.com/en/health-safety/create-manage/enhancing-culture-performance/due-diligence
WorkSafeBC. Workers Compensation Act – Part 2, Occupational Health and Safety.
https://www.worksafebc.com/en/law-policy/occupational-health-safety/searchable-ohs-regulation/workers-compensation-act/part-2-occupational-health-and-safety
Government of Saskatchewan. Duties of Employers.
https://www.saskatchewan.ca/business/safety-in-the-workplace/rights-and-responsibilities-in-the-workplace/duties-of-employers
Government of Saskatchewan. Duties of Prime Contractors.
https://www.saskatchewan.ca/business/safety-in-the-workplace/rights-and-responsibilities-in-the-workplace/duties-of-prime-contractors
Government of Saskatchewan. The Occupational Health and Safety Regulations, 2020.
https://publications.saskatchewan.ca/#/products/111283
Reasonably practicable means taking workplace health and safety measures that are feasible and appropriate considering the circumstances. Employers should consider the hazard, level of risk, available controls, and what a reasonable employer could be expected to do in a similar situation.
No. Cost may be one consideration, but it should not automatically determine which hazard control is selected. Employers should assess the risk and consider available controls, including whether stronger controls can reasonably be implemented.
Employers should maintain records showing that hazards were identified, risks were assessed, appropriate controls were considered, and corrective actions were implemented. Hazard assessments, inspections, training records, procedures, incident investigations, supervisor follow-up, and corrective-action records can all help demonstrate due diligence.
Supervisors help put safety requirements into practice by monitoring work, identifying changing conditions, correcting problems, and escalating hazards that require additional controls. Workers contribute by reporting hazards, following established procedures, participating in assessments where appropriate, and communicating when controls are not working as intended.
A written procedure is important, but documentation alone does not demonstrate that a hazard is being effectively controlled. Employers should also be able to show that workers were trained, supervisors monitored the work, inspections occurred, deficiencies were corrected, and the procedure was being followed in practice.
No. Alberta, British Columbia, and Saskatchewan each have their own occupational health and safety legislation, regulatory terminology, employer duties, and enforcement frameworks. Employers operating in more than one province should review the requirements of each jurisdiction rather than assuming an Alberta process automatically meets requirements elsewhere.
No. COR and SECOR can provide evidence that an employer has developed and implemented important safety-management processes, but certification does not replace compliance with applicable legislation. Employers still need to evaluate hazards, implement appropriate controls, maintain records, and demonstrate due diligence based on their actual workplace conditions.
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Calgary Safety Consultants provides practical occupational health and safety consulting, safety training, COR support, safety program development, and regulatory compliance support for employers across Alberta, British Columbia, and Saskatchewan.
We help organizations strengthen worker training, improve documentation, manage workplace hazards, prepare for audits, and build safety systems that support compliance, productivity, and operational due diligence.
