OFA provides comments to the Ministry of Labour, Training, and Skills Development (MLTSD) on the First Aid Modernization Consultation. OFA supports the transfer of workplace first aid responsibilities from the Workplace Safety and Insurance Board (WSIB) to MLTSD. OFA believes this is a reasonable change and follows from earlier actions that transferred prevention related activities under WSIB to the authority of MLTSD. It is important to note within the context of any increase in first aid training requirements, that the nature of agricultural production often places employers and workers far away from service providers creating additional barriers to accessing training. Furthermore, rural internet service is often slow and reliability and may also create a barrier to easily accessing online training opportunities. Agriculture is also increasingly employing a multinational workforce with challenging language and literacy issues. OFA requests that MLTSD considers these challenges when drafting a new OHSA first aid regulation. OFA requests that MLTSD take a flexible approach to implementing a new first aid regulation under OHSA and allow sufficient time for workplaces to adapt to any new requirements. We believe MLTSD must invest in a strong communications campaign to alert employers of any new requirements following these modernization efforts.