What Regulation 1101 actually is

Regulation 1101 is made under Ontario’s Workplace Safety and Insurance Act, 1997. It sets the minimum first aid requirements for every employer covered by WSIB — which is the vast majority of Ontario businesses. The regulation has been on the books for decades, but the practical expectations (training agencies, course content, certificate format) get refreshed periodically as the underlying first aid guidelines evolve.

The regulation covers four things: (1) how many certified first aiders you need, (2) what level of training they must hold, (3) what you must keep on site (kit + postings), and (4) what to do when injuries occur. This guide focuses on the first two — the rest is mostly common sense once the training piece is squared away.

The schedule, in one table

Headcount is measured per shift, per fixed workplace — not by total payroll.

Workers on a shift Minimum qualified first aiders Required certification
1 – 5 1 Emergency First Aid + CPR Level C AED
6+ 1 (minimum, more recommended) Standard First Aid + CPR Level C AED
Multiple shifts 1 per shift Each shift must independently meet the requirement
Multiple buildings 1 per fixed workplace A single first aider can’t cover two locations at once

“Six or more” is the threshold that catches most growing businesses by surprise. The minute your shift hits six workers, Emergency First Aid is no longer enough — you need someone with the full Standard First Aid certificate. The two courses are not interchangeable for compliance purposes.

What “qualified” means in practice

A qualified first aider holds an unexpired certificate from a WSIB-recognized training agency. The four major agencies are:

  • Canadian Red Cross
  • Heart and Stroke Foundation of Canada
  • Lifesaving Society
  • St. John Ambulance

If your worker took an online-only “weekend bootcamp” or a course from an unrecognized provider, it does not satisfy Regulation 1101 — even if the certificate looks similar. WSIB approval requires hands-on practical assessment with a qualified instructor. See our explainer on what “WSIB-approved” actually means for the full breakdown.

Sector overlays — where the rules get stricter

Regulation 1101 is the minimum. Several sectors layer additional requirements on top.

Construction

Construction projects fall under Regulation 213/91 (Construction Projects). On larger projects, more first aiders are required and proximity-to-work-area rules apply. Remote or hazardous sites typically need Standard First Aid regardless of crew size.

Childcare and daycares

Under the Child Care and Early Years Act, 2014 (CCEYA), supervisors and every employee in direct contact with children must hold a valid Standard First Aid + CPR Level C certificate — regardless of how many staff are on shift. See our daycare-specific guide.

Healthcare and clinical settings

Clinical staff typically need BLS (Basic Life Support), not the general CPR Level C, and renewals are annual rather than every three years. Hospitals, long-term care, dental offices, and physiotherapy clinics all follow this pattern.

Mining

Mining workplaces are exempt from Regulation 1101 because they’re covered by their own — Regulation 854 — which is stricter and includes specific mine rescue training requirements.

What must be posted

The three posting requirements

  • WSIB Form 82 — “Notice in Industrial Establishments.” Lists designated first aiders and emergency procedures.
  • Photocopies of current first aid certificates for each designated first aider, posted beside Form 82.
  • Clear identification of the first aid kit location — signage, accessible at all times.

Postings must be in a conspicuous place — typically beside the kit and next to the OHSA workplace poster. If a Ministry of Labour inspector visits and the postings aren’t visible, that’s an immediate finding.

What about remote and hybrid workers?

Regulation 1101 applies to fixed workplaces. Fully remote workers in their own homes are generally not counted toward the workplace’s headcount for first aid purposes. But if your team has a head office where staff come in periodically — even two days a week — the head office still needs first aid coverage based on the number of workers physically present on any given shift.

Hybrid policies create a planning challenge: if your “Tuesday and Thursday in-office” days have 8 people in but your “Monday/Wednesday/Friday” days have 3, you technically need Standard First Aid coverage on the busy days and Emergency First Aid is enough on the others. The simplest fix is to train enough people for the busiest possible shift.

Penalties and inspections

A Ministry of Labour inspection that finds non-compliance can result in:

  • Orders to comply within a specified timeframe
  • Fines under the Occupational Health and Safety Act
  • Increased WSIB premium surcharges
  • Additional follow-up inspections

The bigger exposure is what happens after an injury. If a worker is hurt and the required first aid coverage wasn’t in place, WSIB claim processing can be affected and civil liability exposure widens significantly. For a small business, the cost of compliance — typically under $200 per first aider every three years — is a small fraction of the potential downside.

The fastest way to comply

If your workplace isn’t currently compliant, you have three options, ranked by speed:

  • Send staff to an open class — fastest path for one or two people. Pick a date on the course schedule and send your designated first aider(s).
  • Book a private group session — most cost-effective for 4+ workers. We come to you, train your team at your location, certify everyone the same day. Common for offices, manufacturing floors, daycares, and clinics.
  • Mix it — train some staff at open classes now to get immediate coverage, then schedule a private group session in the next quarter to bring up your second wave.
Note: This article is a plain-language overview. Regulation 1101 is the legal source — review the regulation itself or consult a workplace health and safety advisor for compliance specific to your operation. Sector overlays (construction, mining, healthcare, childcare) may impose additional requirements.

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