A new year often comes with new resolutions, and in occupational health and safety (OHS), 2025 is the year of compliance. Since last fall, all prevention and participation mechanisms stemming from the modernization of the OHS system have officially come into force.
All Québec businesses must now apply these new requirements, based on their reality and the number of workers in their establishment.
But are you truly ready? And more importantly, are you compliant?
In this article, discover a clear overview of the key steps to take to start the year on solid OHS foundations.
Why should OHS be one of your resolutions this year?
OHS compliance is no longer optional. It is now:
- Mandatory
- Strictly regulated
- Evolving, particularly with the integration of psychosocial risks (PSR)
Starting the year off right means ensuring your prevention mechanisms are structured, effective, and adapted to your organization.
What are the new requirements based on the number of employees?
OHS obligations are first determined by the number of workers in your establishment.
Obligations for businesses with 19 employees or fewer
Businesses with 19 employees or fewer must now:
- Develop and implement an OHS action plan
- Appoint a health and safety liaison officer (HSLO)
Obligations for businesses with 20 employees or more
Businesses with 20 employees or more must:
- Implement a prevention program
- Establish a health and safety committee (HSC)
- Appoint a health and safety representative (HSR)
Who must be included in the worker count?
Determining the number of workers is a key step, and one that is often misunderstood.
Which workers must be included?
The following workers must be counted if they have worked 21 days or more:
- Employees (full-time or part-time)
- Temporary, casual, or agency workers
- Off-site or mobile workers
- Temporary foreign workers, interns, students, or volunteers with a contract
Who must be excluded?
Excluded from the count are:
- Employer representatives (managers, supervisors, forepersons, superintendents)
What must an OHS action plan include (19 employees or fewer)?
The action plan must include:
- Identification and analysis of risks (including psychosocial risks)
- Priority prevention measures to eliminate or control identified risks
- Monitoring, evaluation, and follow-up measures
- Identification of personal protective equipment (PPE)
- OHS training and information
What is the role of the health and safety liaison officer (HSLO)?
The HSLO plays a key communication and prevention role:
- Facilitate OHS communication between the employer and workers
- Collaborate in developing and implementing the action plan
- Submit written recommendations regarding risk identification
- File a complaint with the CNESST, if necessary
What must a prevention program include (20 employees or more)?
The prevention program is more structured and must include:
- Identification and analysis of risks (including PSR)
- Prevention measures and action priorities
- Risk monitoring and evaluation
- Identification of PPE
- Training programs
- Medical examinations
- List of hazardous substances
- First aid services
How do you establish a health and safety committee (HSC)?
The establishment of an HSC depends on the risk level of the establishment, determined using the first three digits of the NAICS code.
How can you determine your company’s risk level?
Two options are available:
- Consult Appendix 1 of the regulation respecting prevention mechanisms
- Use the CNESST online tool with the establishment’s address
What are the main responsibilities of the health and safety committee?
The HSC must notably:
- Determine training programs
- Select appropriate PPE
- Participate in risk identification and analysis
- Maintain records of workplace accidents and occupational diseases
- Investigate accidents and make recommendations
- Receive and address complaints and suggestions
- Review inspection reports and statistical data
What is the role of the health and safety representative (HSR)?
The HSR is a central prevention stakeholder and is responsible for:
- Inspecting workplaces
- Investigating accidents
- Identifying sources of danger
- Making recommendations, including on psychosocial risks
- Assisting workers and accompanying inspectors
- Intervening in work refusal situations
- Actively collaborating in the prevention program
Why are psychosocial risks (PSR) a major challenge?
Psychosocial risks are one of the most significant additions of the reform—and also one of the most complex to manage.
Workload, recognition, organizational climate, support from colleagues and management, and decision-making autonomy all require appropriate tools and a structured methodology.
Need an update on psychosocial risks? Learn about the main changes and implications introduced by Bill 42.
How can Santinel help you achieve your OHS resolutions?
Are you ready to take on your new OHS obligations?
Ask yourself the right questions:
- Are you able to manage the new requirements?
- Can you identify and analyze your risks?
- Do you have the tools to manage psychosocial risks?
- Is your health and safety committee truly effective?
- Can you adequately support your HSR or HSLO?
Santinel is here to support you
New obligations mean new responsibilities, but you don’t have to manage them alone.
With our turnkey OHS packages, we support you every step of the way to meet regulatory requirements efficiently and confidently.
No matter your company’s risk level, our multidisciplinary team works with you to:
- Structure your action plan or prevention program
- Effectively manage risks, including psychosocial risks
- Support your HSLO, HSR, and health and safety committee
Less administrative burden for you, more prevention for your teams, and compliance you can trust.
