The decision to bring maintenance in-house is a strategy question. Everything in this guide is the compliance sequence that starts the moment you hire the first person to do it.
Key takeaways
STEP 01 OF 10
Not every trade belongs in-house. Decide, before recruiting starts, which trades stay contracted regardless of headcount growth — usually the ones called rarely, or the ones carrying licensing complexity (elevating devices, fire suppression) that doesn't justify direct employment at your building count.
Write the line down as a rule, not a case-by-case judgment call. A rule survives staff turnover on the decision-making side; an informal understanding doesn't.
Revisit the line annually rather than treating it as permanent. A trade that was rarely called two years ago may now justify direct employment once the portfolio has grown enough to keep that role busy.
STEP 02 OF 10
Ontario's expanded compulsory coverage rule states plainly: "You have 10 calendar days from the day you hire your first employee to register with us" (wsib.ca, updated 2026-03-24). This applies to "people who own or run a business in construction, with or without employees" — a maintenance operation performing construction-activity-type work on buildings falls inside that scope.
This is the one clock in this whole guide with zero flexibility built in. Put it on the calendar the day an offer is accepted, not the day the new hire starts — the ten days runs from the hire, and a maintenance operation standing itself up usually has this as its very first compliance action.
STEP 03 OF 10
Ontario names 23 compulsory trades, including "plumber, electrician, steamfitter." To work in one, a person must hold "a valid: Certificate of Qualification, or Provisional Certificate of Qualification, or Registered Training Agreement," and "all compulsory trades have certifying exams. Journeypersons in compulsory trades must renew their Certificate of Qualification each year" (skilledtradesontario.ca).
Write the licence requirement into the job posting itself, not just the offer letter. A candidate without a current C of Q for a compulsory trade can't legally start the work regardless of how the interview went.
A handful of exemptions exist — OYAP and pre-apprenticeship participants, permanent industrial-plant employees for some work, and holders of equivalent Québec certificates in seven named trades — but none of them apply broadly to a general maintenance hire, so treat the licence requirement as the default rather than looking for the exception first.
STEP 04 OF 10
CCOHS's jurisdictional table sets the JHSC requirement at 20 or more workers in nearly every Canadian jurisdiction — federal, Alberta, BC, Manitoba, New Brunswick, Newfoundland and Labrador, Nova Scotia, Ontario, PEI, Yukon — with one outlier: Saskatchewan requires a committee "when 10 workers or more" (ccohs.ca, fact sheet last revised 2024-08-30).
Ontario tiers the committee size on top of the threshold: "20 to 49 — You are required to have a JHSC. The committee must have at least two (2) members. 50 plus — at least four (4) members" (ontario.ca). Know which tier your growth plan is heading toward before you're already there.
STEP 05 OF 10
Ontario's OHSA draws a distinction between a constructor and an employer, and the notice-of-project and reporting obligations attach differently to each role (O.Reg 213/91). Decide, in writing, who at your organisation holds each role before the first job starts, rather than discovering the answer during an incident.
This matters more, not less, the smaller the operation — a five-person maintenance team without a dedicated safety coordinator still needs someone named as the accountable contact.
Name a backup for that contact too. A maintenance operation with a single accountable person is one vacation or one sick day away from having no one who knows the escalation process when it's needed.
STEP 06 OF 10
Standing up an in-house team doesn't eliminate contracted trades entirely — the make-or-buy line from step one still leaves some work going to outside vendors. Apply the same WSIB clearance-verification habit described in building a vendor panel you can rely on to whatever stays contracted, rather than assuming an in-house team makes vendor compliance someone else's ongoing concern.
A newly-registered business itself needs a clearance certificate too where it contracts work back out. WSIB notes that new registrants typically pay an initial $250 advance payment applied as an account credit — budget for it as a startup cost, not an unexpected line item.
STEP 07 OF 10
A Certificate of Qualification renews every year for a journeyperson in a compulsory trade — this is a recurring line item, not a cost that's paid once at hiring and forgotten. Build it into the maintenance operation's annual budget the same way you'd budget for equipment depreciation.
Track the renewal date per employee the same way the vendor panel tracks a clearance expiry — a lapsed C of Q on an in-house electrician is the same legal exposure as an unlicensed contractor.
STEP 08 OF 10
A register tracking each employee's compulsory-trade status, JHSC certification (if applicable), and any site-specific orientation is far easier to build with two employees than to retrofit once six people are on payroll with no consistent record. See a competency and training register for the full system.
Start the register the day the first offer is accepted, using the compulsory-trade licence check from step three as its first entry.
A register built early also makes the JHSC threshold check in step four mechanical rather than a manual headcount exercise — the same system that tracks credentials can just as easily flag when the roster crosses 20 workers.
STEP 09 OF 10
OHSA s.43 gives every worker the right to refuse unsafe work; the employer or supervisor "must investigate the situation immediately, in the presence of the worker" and a worker-side JHSC member or representative. A small maintenance team needs to know who fills that role before the first refusal happens, not while it's happening.
This is a process to write down calmly in advance, not a decision to invent under pressure the first time a worker exercises the right.
STEP 10 OF 10
Don't wait for an annual review to notice the team has crossed 20 workers (or 10, in Saskatchewan). Check the threshold at every hire past the mid-teens, so the committee is in place before the trigger, not scrambled together after an inspector asks about it.
A maintenance operation that grows in bursts — several hires in one quarter to support a new building acquisition — is exactly the pattern that crosses a threshold unnoticed. Build the check into the hiring process itself.
Registering with WSIB after the ten-day clock has already run. The rule states ten calendar days from the first hire, with no stated grace period. Treat it as the very first task on the maintenance-operation standup checklist, not something to get to once the team is settled.
Assuming an apprentice doesn't need to be tracked in the compulsory-trade register. An apprentice working toward a compulsory trade still operates under a Registered Training Agreement with its own conditions — track it with the same discipline as a full Certificate of Qualification, not as an informal understanding.
Building a safety programme only after headcount crosses the JHSC threshold. The threshold is a trigger for a formal committee, not the starting line for thinking about safety. A team of twelve without a JHSC still needs the hazard-assessment and reporting discipline described in this guide's H&S companion piece.
Treating the make-or-buy line as fixed forever. A decision made at five employees may not fit a team of twenty. Revisit which trades stay contracted at the same cadence as the annual vendor-panel refresh, not as a one-time founding decision.
Scenario. An Ontario maintenance operation hires its 20th worker in month seven. At 19 workers, with more than five employed, the team needed a health and safety representative under s.8(1) but no formal committee. The moment the 20th worker starts, the team crosses into JHSC territory at the 20-49 tier — a committee with at least two members, at least half of them worker-side. If the same operation later grows past 50, the minimum committee size doubles to at least four. Each of those thresholds is a headcount-triggered legal requirement, not a discretionary staffing decision.
Run the same operation's registration clock alongside it: the WSIB ten-day window opened the day the first employee was hired, in month one — six months before the JHSC threshold was even a live question. The two clocks don't share a start date, and a plan that only tracks one of them will be compliant on one front and exposed on the other.
Yes — the ten-day registration clock runs from the first employee hired, and an apprentice is an employee. Registration timing doesn't depend on the worker's certification stage.
Compulsory-trade licensing follows the person, not the building — a licensed electrician can work across every building in the portfolio on one current Certificate of Qualification. Track the licence at the employee level, not per building.
From the day the first employee is hired, not the day they begin work or the day payroll is set up. If those dates differ, use the hire date as the trigger to stay on the safe side.
Yes. OHSA's constructor/employer distinction and the work-refusal process both require someone accountable, regardless of whether the team is large enough to require a formal committee.
A 30-minute call is enough to map the registration and licensing steps for your headcount plan.
