Ontario HR Compliance · CLC Part II (occupational health & safety)
Health and Safety Committees and Representatives: Headcount Thresholds (CLC Part II)
Federal employers structure health and safety participation by headcount — a representative under 20 employees, a workplace committee at 20 or more, and an additional policy committee once the employer reaches 300 employees across Canada.
CLC Part II sets three tiers of health and safety participation, keyed to headcount:
- Fewer than 20 employees at a workplace: a health and safety representative, rather than a full committee.
- 20 or more employees at a workplace: a workplace health and safety committee, with at least 2 members, at least half of whom must be non-managerial employees.
- 300 or more employees across Canada: an additional policy health and safety committee, which handles organization-wide issues on top of the workplace-level committees.
The only specific statutory exemption from the workplace-committee requirement is for employees working on a ship or aircraft; the Minister can exempt other low-risk workplaces on a case-by-case basis.
For an employer with 20 to 200 employees, the workplace committee is the threshold that matters — it applies as soon as a single location reaches 20 employees. The policy committee doesn’t come into play until the organization reaches 300 employees nationally, which sits above this range.
This is general information, not legal advice; confirm current requirements at the Labour Program’s committee pages before relying on them.
Source: Government of Canada — Workplace health and safety committees ·
Also: Government of Canada — Health and safety committees report
Last reviewed .
Confidence: Verified
Related notes
- The Internal Responsibility System and the General Duty (CLC Part II) — CLC Part II replaces the Ontario OHSA for federal employers and rests on the internal responsibility system — shared employer and employee responsibility for health and safety, anchored by the employer's general duty to protect every employee and a fixed hierarchy for preventing hazards.
- The Hazard Prevention Program (CLC Part II) — Federal employers must develop, implement, and monitor a hazard prevention program sized to their workplace and its hazards, built in consultation with the health and safety committee or representative — and a workplace-specific version where the general program doesn't cover a hazard unique to that location.
- Work Refusals and the Internal Complaint Resolution Process (CLC Part II) — Federal employees can refuse dangerous work, and Part II routes health and safety problems through an internal resolution process before any outside escalation, with reprisal against an employee for exercising these rights prohibited.
- Federal Pay Equity Act: Applicability and the 10-Employee Threshold — The federal Pay Equity Act applies to all federally regulated employers, public and private, with 10 or more employees, and requires them to proactively identify and close gender-based pay gaps rather than wait for a complaint — a different statute from Ontario's Pay Equity Act, with different mechanics.
- Employment Equity Act: The 100-Employee Threshold and Annual Report — Federally regulated private-sector employers and Crown corporations with 100 or more employees must analyze their workforce against four designated groups, maintain an employment equity plan, and file an annual report by June 1 — an obligation that doesn't apply at all below 100 employees.