Top 10 OH&S Red Flags That Make Inspectors Dig Deeper

OH&S red flags inspectors notice

Red flag 1: Housekeeping and obvious physical hazards

Housekeeping gives an officer an immediate view of how visible hazards are being controlled. Obstructed walkways, blocked exits, poor floor conditions and materials stored around emergency equipment can expose workers and interfere with emergency response. These conditions may lead the officer to examine related inspections, supervision and corrective-action records more closely.

Use routine workplace inspections to identify the condition, assign responsibility and verify the correction. Anything affecting safe access, egress or emergency equipment should be controlled promptly. The Canadian Centre for Occupational Health and Safety housekeeping guidance is useful supporting guidance, but the applicable legislation and site-specific hazards govern the required controls.

Red flag 2: Missing, outdated, or generic documentation

Documents should reflect the work that is actually performed. For provincially regulated Alberta workplaces, section 7 of the OHS Code requires the employer to assess the work site, identify existing and potential hazards, document the results and record the assessment date.

Generic hazard assessments, incomplete training records and repeated inspection forms may prompt an officer to test whether controls have been implemented. A missing document is not automatically proof that the entire system has failed, but a pattern of missing or inaccurate required records can undermine the employer’s evidence of implementation.

Red flag 3: Workers who cannot explain the basics

Worker interviews help an officer compare written requirements with actual work. Questions may cover job hazards, training, reporting routes, emergency actions and the controls workers use. Hesitation by itself is not proof of non-compliance; inconsistent answers combined with observations or records can justify closer examination.

Employers should provide understandable instruction, appropriate supervision and a way for workers to raise concerns. Verify competency through observation, practical demonstrations and follow-up questions. A signed attendance sheet shows participation, but it does not by itself demonstrate that a worker understands or can apply the required controls.

Red flag 4: PPE that exists on paper only

PPE problems are easy to see. An officer may compare the PPE workers are using with the hazard assessment, required controls, equipment condition, fit and the manufacturer’s instructions. Eyewear worn incorrectly, unsuitable hearing protection or a respirator that cannot seal can indicate gaps in selection, training or supervision.

PPE is the last line of defence in the hierarchy of controls. Employers should first consider elimination, substitution and engineering controls under section 9 of Alberta’s OHS Code. Replace PPE when it is damaged, contaminated, unsuitable or beyond the manufacturer’s service-life criteria where those criteria apply.

Red flag 5: Machinery, energy, and lockout/tagout shortcuts

Alberta’s preferred legal terminology is control of hazardous energy. Under sections 212 and 213 of Part 15 of the OHS Code, specified servicing and related work cannot proceed until hazardous energy is isolated or the equipment is otherwise rendered inoperative as permitted, and the worker has tested and confirmed that it is safe.

Removed guards, bypassed interlocks, reaching into equipment after only using a stop control, or relying on an informal tag without effective isolation are serious warning signs. The employer also needs procedures suited to the equipment, personal or group locking arrangements where required, worker competency and verification before equipment returns to service.

Red flag 6: Chemical management and WHMIS gaps

For provincially regulated Alberta workplaces, WHMIS duties are set out in Part 29 of the OHS Code, together with applicable federal supplier requirements. Sections 397 and 398 address worker training and labels. Sections 404 to 407 address safety data sheets and worker access.

The Canada Labour Code applies only to federally regulated workplaces. For Alberta-regulated work, an officer may look for required labels, current safety data sheets that are readily available, effective worker training and safe handling and storage. Secondary containment and segregation must be based on the product hazards, SDS information, applicable fire requirements and the workplace assessment.

Red flag 7: Incident reporting that is suspiciously quiet

A low incident count is not, by itself, evidence of poor reporting. Concern arises when records, worker interviews, first-aid information, complaints or observed conditions do not align. Discouraging reports, failing to investigate recurring events or leaving reported hazards unresolved can indicate weaknesses in supervision and corrective action.

Section 33 of Alberta’s OHS Act specifies reportable serious injuries, illnesses and incidents and identifies investigation and record requirements. Not every near miss is reportable to Alberta OHS, although internal near-miss reporting can help an employer identify hazards before a more serious event occurs.

Red flag 8: Safety committees and reps that exist only on paper

For provincially regulated Alberta employers, section 13 of the OHS Act generally requires a joint health and safety committee when the employer regularly employs 20 or more workers. Section 14 generally requires a health and safety representative for 5 to 19 workers. The Act contains work-site and prime-contractor provisions that must also be considered.

An officer may review committee or representative records, hazard-assessment participation and recommendations. Part 13 of the OHS Code addresses committee structure, terms of reference, meetings and training. Other provinces and federally regulated workplaces use different thresholds and requirements.

Red flag 9: Corrective actions that go nowhere

Inspectors often compare identified hazards with the actions taken afterward. They may ask for an example showing what was found, who was assigned to address it, what control was selected and how completion and effectiveness were verified. Repeated findings can indicate that the original action did not control the hazard.

A corrective-action register is useful evidence, but Alberta legislation does not prescribe one universal register format for every employer. The legal foundation is the applicable hazard-assessment and control duty, including sections 7 to 9 of the OHS Code. Records should be proportionate to the risk and sufficient to show implementation and follow-up.

Red flag 10: Leadership sending mixed messages

Officers compare management and supervisory behaviour with the organization’s stated requirements. Supervisors who bypass controls, tolerate missing PPE or pressure workers to continue unsafe work can undermine otherwise sound procedures. Alberta supervisors and employers have separate statutory duties under sections 3 and 4 of the OHS Act.

Leadership should provide the time, equipment, competent supervision and authority needed to control hazards. Managers should follow the same site rules as workers, respond to concerns and verify that production decisions do not defeat required controls. Consistent behaviour is stronger evidence of implementation than slogans or policy statements alone.

What inspectors can do when red flags pile up

In Alberta, an officer’s authority depends on the conditions observed and the statutory test for the action, not on a set number of red flags. Section 34 of the OHS Act authorizes workplace inspections and access to relevant records, documents, materials and equipment.

An officer may issue an order to ensure compliance under section 38, a stop-work order where the section 39 danger test is met, or a stop-use order for unsafe or non-compliant equipment or substances under section 40. Section 44 addresses administrative penalties. Prosecutions are governed separately by Part 9. Engineering review is required only where the legislation, an order or the circumstances call for a qualified professional assessment.

Why this all matters

These OH&S red flags are practical screening indicators, not offences by themselves. The appropriate response is to confirm the governing jurisdiction, identify the applicable requirement and assess the actual workplace conditions. Busy operations still need the people, time, equipment and authority required to meet legal duties and control hazards.

Use the list to compare documents and records with worker interviews and workplace observations. Prioritize uncontrolled high-consequence hazards, select controls using the hierarchy of controls, assign accountable owners and verify that each action is implemented and effective. This improves inspection readiness, but more importantly it supports safer and more predictable work.

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About the author

John Duplessis, B.Sc., CRSP

President and Principal Health & Safety Consultant

John Duplessis is a Canadian Registered Safety Professional with more than 30 years of occupational health and safety experience in oil and gas, construction, green energy, midstream operations, and industrial project work.

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