Cones and a flagger are the visible part. British Columbia's OHS Regulation requires a written plan behind them, and it applies sooner than most contractors expect.
Key takeaways
“We put out cones and had someone flagging” describes the visible half of a compliant traffic control setup. The half that gets checked after an incident is the written plan behind it — and in British Columbia, that plan is required far sooner than a lot of short jobs assume.
BC’s OHS Regulation, Part 18, sets the threshold low. A written traffic control plan is required for short-duration work — anything running more than 15 minutes during one daylight period — and separately for long-duration work, defined to include work spanning multiple daylight periods, night work, or mobile work. Fifteen minutes is not a typo and not a generous buffer: a utility locate, a short paving patch, or a quick drainage repair on a shoulder can all cross that line before the crew has finished setting cones, and the plan is supposed to exist before the work does, not be assembled retroactively if someone asks for it.
Section 18.3.2 sets out four required elements, and none of them is satisfied by a diagram alone. The plan must specify the traffic control measures that mitigate the hazards identified in the risk assessment, instructions for implementing those measures, clear statements of roles and responsibilities for implementing the plan, and a schedule for the plan’s implementation and its regular review and updating. That last element matters more than it looks: a plan written for a daytime, dry-pavement setup is not automatically valid once the same job runs into a night shift or a rain event, and the review-and-update requirement is what forces that reassessment rather than leaving the original plan in force by default.
Three figures do most of the work in practice. The distance between the Traffic Control Person Ahead (C-001-1) sign and the first traffic control person must not exceed 150 m, unless that spacing is not practicable. The traffic control person themselves must be positioned at least 25 m from the work zone, again subject to a practicability exception where circumstances or space genuinely don’t allow it. And speed sets a hard limit on the method itself: traffic control persons cannot be used at all where the posted speed limit exceeds 70 km/h — past that threshold, the plan has to rely on other measures (lane closures, barriers, signage-only control) rather than a person standing in the road.
Section 18.3.2’s four required contents rest on a separate, more detailed obligation in 18.3.1: the written risk assessment feeding the plan has to consider work duration and timing, the nature of the work and its hazards, traffic volume, sightlines, vehicle speeds, the work zone’s configuration, environmental conditions, any overlapping activities, and any other reasonably foreseeable hazard — plus the traffic control persons’ own requirements, including escape routes, positioning, supervision levels, and training needs. A plan that specifies the 25 m positioning and the 150 m sign distance but was never actually checked against the site’s sightlines or traffic volume has filled in the numbers without doing the assessment the Regulation actually requires behind them.
The Regulation does not treat “traffic control person” as a task anyone on the crew can be handed for the afternoon. Section 18.6.2 requires completion of a Board-approved traffic control training program, assessed on both knowledge and practical competency. On the equipment side, high-visibility apparel has to meet Class 3 garment criteria under CSA Standard Z96-15, and after dark or in poor visibility, each traffic control person needs a flashlight fitted with a red signalling wand, with the work location itself lit by overhead street lighting or temporary lighting where none exists. None of this is optional dressing on top of the plan — a plan that puts an untrained worker in a vest that doesn’t meet the Class 3 standard has a compliance gap regardless of how correct its 150 m and 25 m figures are.
On a multi-employer road project, the traffic control plan is one more thing that needs a named owner, and BC’s framework points to the same role that carries the Notice of Project obligation: the prime contractor. Where several employers are working the same corridor — a paving crew, a line-painting crew, a utility crew — coordinating one traffic control plan rather than three overlapping ones is squarely a prime-contractor function, and it is worth confirming in writing at the start of the project who is filling that role, for the same reason it matters for the underlying notice and inspection obligations that run alongside it — and for BC contractors, the same prime-contractor role that carries holdback obligations elsewhere on the project.
The Regulation is specific about where the plan has to live, not just that it has to exist: the employer must ensure the traffic control plan is accessible at all times to workers at the work zone. A plan sitting in a project binder at the yard does not meet that bar. Whatever form it takes — laminated card in the flagger’s vest pocket, a copy in the site trailer, a digital version pulled up on a phone — the test is whether a worker standing at the work zone can actually get to it during the shift, not whether one exists somewhere in the company’s files.
A repaving job runs along a 60 km/h arterial road over three days — squarely long-duration work under Part 18, requiring a written plan from day one. The plan specifies traffic control persons at both ends of the active paving zone, each positioned at least 25 m from the work itself, with the C-001-1 sign no more than 150 m ahead of the first one. Because the posted speed is 60 km/h — under the 70 km/h ceiling — using traffic control persons at all is permitted; the plan documents that check explicitly rather than assuming it.
A second scenario on the same corridor, a short section a few kilometres away with an 80 km/h posted limit, changes the answer entirely. Traffic control persons cannot be used there regardless of how the rest of the plan is written — the crew needs a different control method, most likely a full lane closure with barriers and advance signage rather than a person standing in the roadway. A traffic control plan copied from the first section to the second without checking the posted speed would put a worker in a position the Regulation does not permit.
Short-duration work — anything running more than 15 minutes in one daylight period — already requires a written plan. Multi-day work, night work, and mobile work fall under the long-duration category and require one as well.
At least 25 metres, under OHSR 18.8, unless circumstances or space requirements genuinely make that distance impracticable.
No. OHSR 18.6 prohibits using traffic control persons where the speed limit exceeds 70 km/h — a project on a faster road needs a different control method, such as lane closures or barriers.
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