Project notices, permits and registrations

Three weeks before the first excavator arrived at Cottonwood Place, Adaeze Okoro, the Tallgrass project manager, pinned a sheet to the trailer wall titled 'Before we dig'. It listed every notice, permit and registration the project needed, who was responsible for each, the lead time, and a box for the confirmation number. Some were obvious, like the building permit. Others were easy to forget: the locate request for buried utilities, the notice before workers entered a deep excavation, the asbestos notice for the old garage on the lot, the confirmation that every subcontractor was registered for workers' compensation. A missed notice can stop a job, bring a penalty, or, in the case of a locate, kill someone.

This lesson walks through the paperwork that comes before and during construction on Cottonwood Place, and why each piece exists.

Why notices matter

Regulators cannot inspect every site all the time. Notices tell them where high-risk work is happening so they can target their inspections: deep excavations, demolition of buildings with asbestos, work in compressed air, suspended platforms on tall buildings. Utility locates tell the owners of buried cables and pipes where someone is about to dig. Building permits let the municipality check that the design meets the building code and that inspections happen at the right stages. Workers' compensation registration makes sure injured workers will be covered. Each notice is a small step that connects the project to a system designed to catch problems the contractor might miss.

Notices to the Workplace Safety and Health Branch

Unlike some provinces, Manitoba does not require a general notice of project for every construction site. Instead, the Workplace Safety and Health Regulation requires notice to the Branch before particular kinds of high-risk work. Those that matter most on a building project like Cottonwood Place are these.

• Excavations deeper than 1.5 m that workers will enter. The employer must notify the Branch before the work starts, within the time set in Part 26 of the regulation, giving the location, dates, dimensions, the support system to be used and confirmation that underground facilities have been located.
• Suspended work platforms more than 3 m above ground. Notice is required at least 8 hours before the platform is suspended.
• Work in compressed air. At least 30 days' written notice and an engineered work plan.
• Asbestos. Before altering, renovating or demolishing a building with asbestos-containing material that may be released, the owner or employer must notify the director at least 5 days ahead, with an asbestos inventory and control plan (HSE-372 covers this in depth).

At Cottonwood Place, Silva Earthworks filed the excavation notice for the east lane excavation and shared the confirmation with Tallgrass. The scaffold contractor filed the suspended platform notice for the facade work a year later. The asbestos notice for the old garage was filed by the demolition contractor on behalf of Cottonwood Place Developments. Tallgrass's job as prime contractor was to make sure each one was filed before the work began, and the 'Before we dig' sheet was how it checked.

Building permits and municipal requirements

the City of Winnipeg's Planning, Property and Development Department issued the building permit for Cottonwood Place after reviewing the drawings against the National Building Code of Canada as adopted in Manitoba. The permit sets out required inspections at stages such as footings, framing, plumbing rough-in and occupancy. Separate permits covered the demolition of the old garage, the hoarding and sidewalk closure on the street, the tower crane's swing over the street, and connections to water and sewer. Work started before a permit is issued can be stopped by the city, and work covered before an inspection may have to be opened up.

Permits are not only about the finished building. Several protect people during construction: the street use permit requires covered walkways and traffic control (see HSE-373), the demolition permit requires utility disconnection and dust control, and the crane permit sets the hours and conditions for swinging loads over a public street.

Locates before digging

Before any ground disturbance, the excavator must request locates of buried facilities through Click Before You Dig Manitoba, and Manitoba Hydro and the other utility owners mark their lines. Locates have an expiry date and must be renewed if work is delayed, and marks that have been destroyed must be relocated. Hand digging or hydrovac excavation is used to expose lines within the tolerance zone around the marks. Striking a gas line or high-voltage cable can kill workers and the public, so locates are one of the most important notices on the list.

Environmental permits

Construction can also need environmental approvals: a dewatering or groundwater discharge permit if water pumped from an excavation goes to a sewer, approval for disposal of contaminated soil, and erosion and sediment controls required by the city's development agreement. Manitoba Environment and Climate Change regulates the handling of contaminated sites and hazardous waste. At Cottonwood Place, soil testing found petroleum hydrocarbons near the old garage's fuel tank, so the contaminated soil was hauled to a licensed facility with manifests.

Workers' compensation registration and coverage

In Manitoba, construction employers must register with the WCB and pay assessments based on their payroll and industry rate. A principal that hires contractors can become liable for a contractor's unpaid assessments if the contractor is not in good standing, so general contractors routinely require a WCB clearance letter from each subcontractor before it starts work and again before final payment. Tallgrass checks clearances at award, monthly while the subcontractor is on site, and at final payment. A subcontractor without valid coverage does not start work.

Registrations, licences and certifications

Some work can only be done by licensed or certified people or companies, and the general contractor needs to see proof before the work starts. On Cottonwood Place the list included the electrical and plumbing contractors' licences and permits, the crane operator's certification, the elevator installer's licence, gas fitters' licences, the boiler and pressure vessel registrations for the temporary heating equipment, and the asbestos abatement contractor's qualifications. Lesson 6 covers individual competence in detail.

Working out the deadlines

Some lead times are counted in calendar days, some in working or business days, and some in hours. Adaeze uses a short script to turn the planned start date into the latest date each notice can go in, skipping weekends where the rule counts business days.

from datetime import date, timedelta

def back(start, n, business):
    d = start
    while n > 0:
        d -= timedelta(days=1)
        if not business or d.weekday() < 5:
            n -= 1
    return d

start = date(2027, 4, 12)   # planned start of excavation (a Monday)
items = [("locate request", 2, True), ("asbestos notice", 10, True),
         ("permit application buffer", 30, False)]
for name, n, business in items:
    kind = "business" if business else "calendar"
    print(f"{name:26s} {n:2d} {kind:8s} days -> file by {back(start, n, business)}")

locate request              2 business days -> file by 2027-04-08
asbestos notice            10 business days -> file by 2027-03-29
permit application buffer  30 calendar days -> file by 2027-03-13

The script does not know about statutory holidays, so Adaeze checks the calendar by hand for any holiday in the window. And because many notices also have a maximum lead time or an expiry, such as locates that expire after a set period, she schedules each one close to its window rather than months early.

Posting and displaying information on site

Some information must be posted where workers can see it. At Cottonwood Place, the site board at the main gate held the Act and regulation access information, the names of the committee members and how to reach them, the minutes of the most recent committee meeting, the emergency contacts and muster point, any improvement or stop work orders (which must now stay posted for at least seven days or until compliance, whichever is longer), and the building permit card. Each subcontractor posted its own safe work procedures and training notices in its work area. Owen checked the board weekly.

A register of everything

The 'Before we dig' sheet grew into a register that ran for the whole project. Each row was a notice, permit, registration or certificate, with the responsible company, the date filed, the confirmation number, the expiry date and the date it was last checked. Adaeze sorted it by expiry date every Monday and highlighted anything expiring in the next two weeks. That register caught an expired crane inspection certificate before the annual inspection lapsed, a subcontractor whose workers' compensation coverage had ended without anyone noticing, and a street use permit that needed renewing when the schedule slipped.

The register also helped at the end of the job. When Cottonwood Place was handed over to Cottonwood Place Developments, the closeout package included the final inspections, the occupancy permit, the environmental disposal records for the contaminated soil and the asbestos clearance records for the old garage. Because each had been tracked from the start, assembling the package took days rather than weeks.

When the paperwork and the site disagree

A notice describes what the contractor intends to do. If the work changes, the notice may no longer be accurate. When the east lane excavation was deepened by a metre (3 ft) to reach better bearing soil, the shoring design had to be revised by the engineer, the excavation notice updated and the locates checked again for the deeper cut. Marco Silva's rule for his crews is that if the work does not match the paperwork, the paperwork is wrong until it is fixed, and the work waits.

The same applies in the other direction. A permit or notice can be correct on paper while the site has moved on: a street use permit for a lane closure that the traffic crew has quietly extended by another lane, or a crane permit for working hours that the schedule now exceeds. Owen's weekly walk includes holding the register up against what he can see, because a permit's conditions only protect people if the site is actually following them.