Insights
Do You Need a Formal Safety Program?
Alberta's OHS Act sets a real worker-count threshold for a written safety program - and it's not the same number as SECOR's, even though they sit close together. Getting the three actual thresholds straight matters if you're deciding what you can legally skip.
Published 5 Sep 2026 · The On-Track Team
6 min readKey Takeaways
- A written health and safety program is only required by Section 16 of the OHS Act once an employer regularly employs 20 or more workers.
- A Joint Health and Safety Committee is required at 20+ workers; a Health and Safety Representative at 5-19 workers.
- SECOR's 10-or-fewer-workers eligibility is a WCB/PIR program number, not an OHS Act or Code threshold - the two are unrelated.
- Every employer, at any size, still carries real minimum duties: hazard assessment, WHMIS, an emergency response plan, and a violence and harassment prevention plan.
- Alberta Labour publishes small-business-specific guidance, including a Toolkit for Small Business aimed at employers with 10 or fewer workers.
1. The 20-worker program threshold
Section 16 of the OHS Act (SA 2020, c O-2.2) requires an employer that regularly employs 20 or more workers - or is directed to by an OHS Director - to establish and implement a written health and safety program. A multi-site employer aggregates workers across every site toward that count, so five sites of six workers each clears the threshold even though no single site does.
2. What every employer must do anyway
Being under 20 workers doesn't mean no obligations - it means the obligations aren't packaged into one named “program” document. The general duty under Section 3 of the OHS Act applies to every employer, at any size: hazard identification, assessment and control; an emergency response plan; WHMIS training; and, since a March 2025 amendment, a written violence and harassment prevention plan, which applies to every Alberta employer with no worker-count exemption at all.
Below 20 workers is not the same as below the law
3. Committee vs. representative
A Joint Health and Safety Committee is required at 20 or more regularly employed workers, under Section 13. Between 5 and 19 workers, Section 14 requires a Health and Safety Representative instead - a lighter structure than a full committee. An employer in that 5-to-19 band can choose to run a full committee voluntarily, but it isn't required until 20.
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See custom safety manual options4. Three numbers, three sources
It's easy to blur these together because they cluster in a similar range, but they come from entirely different places. The OHS Act's 5-worker line (a representative) and 20-worker line (a program and committee) are legal thresholds set by the Act itself. SECOR's 10-or-fewer-workers eligibility is a completely separate number, set by WCB Alberta's Partnerships in Injury Reduction program and the certifying partners - it has no statutory link to either OHS Act threshold. A company can sit below the SECOR line and still be well above the OHS Act's 20-worker program threshold if it has multiple small sites, or vice versa.
5. Frequently asked
Does a 3-person company legally need a written safety program?
Not a formal "health and safety program" document under Section 16 - that specific requirement only applies once an employer regularly employs 20 or more workers. But a 3-person company still isn't exempt from safety obligations: the general duty under Section 3 of the OHS Act, hazard identification and assessment, an emergency response plan, WHMIS training, and - since March 2025 - a violence and harassment prevention plan all apply to every employer regardless of size.
At what worker count do I need a Joint Health and Safety Committee?
20 or more regularly employed workers, under Section 13 of the OHS Act - the same threshold that triggers the formal written program requirement. Multi-site employers aggregate their worker count across all sites toward that number.
What about a Health and Safety Representative instead of a full committee?
Employers with 5 to 19 workers need a Health and Safety Representative under Section 14 of the OHS Act - a lighter requirement than a full committee. An employer in that 5-to-19 range can choose to set up a full Joint Health and Safety Committee instead if they prefer, but it isn't required until 20 workers.
Is SECOR's 10-or-fewer-workers rule the same as the OHS Act's thresholds?
No, and this is a common point of confusion. SECOR's 10-worker eligibility line is set by WCB Alberta's Partnerships in Injury Reduction program and the certifying partners - not by the OHS Act or Code. It has no legal connection to the Act's own 5-worker representative threshold or 20-worker program/committee threshold. Three separate numbers, three separate sources, that just happen to sit in a similar range.
Where can a small employer get official guidance on what's actually required?
Alberta Labour publishes small-business-specific resources: an OHS Starter Kit, a Toolkit for Small Business aimed at employers with 10 or fewer workers, and a bulletin (LI055) on participation in health and safety for small business, all available through the OHS Resource Portal at open.alberta.ca.