OHS Prevention Program: What Must It Include in Quebec?

You have an occupational health and safety (OHS) prevention program. It includes your safety procedures, a few inspection reports, a list of employee training sessions, and perhaps even an accident register.

But does all of this actually qualify as a prevention program that meets CNESST requirements?

It’s a question many Quebec employers have been asking since the permanent prevention and worker participation framework came into effect.

And for good reason.

An OHS prevention program is more than a collection of safety documents stored in a binder. It should help you understand the risks present in your workplace, determine which measures are needed to address them, and establish how you’ll make sure those measures remain effective.

In Quebec, an OHS prevention program must include several key elements, including risk identification and analysis, preventive measures, action priorities, implementation timelines, and monitoring procedures. It must also address other aspects of workplace prevention, such as personal protective equipment, employee training, and harassment prevention.

Let’s look at what this means in practice.

Which Quebec businesses need an OHS prevention program?

Since October 1, 2025, Quebec’s permanent prevention and worker participation framework generally requires establishments with 20 or more workers to develop and implement an OHS prevention program.

For establishments with 19 workers or fewer, an OHS action plan is generally required instead.

However, certain exceptions apply.

For example, the CNESST may require a prevention program in an establishment with fewer than 20 workers. Employers operating multiple establishments may also choose, under specific conditions, to group them under a multi-establishment prevention program.

Simply operating several locations does not automatically create this obligation. Whether establishments can be grouped depends on factors such as the nature of their activities and the applicable regulatory requirements.

For more information, consult the CNESST’s overview of Quebec’s occupational health and safety modernization.

If you’re unsure which requirements apply to your organization, our article on Bill 27 and OHS compliance in Quebec is a good place to start.

Once you’ve determined that your establishment needs a prevention program, the next question is: where do you begin?

1. Identify the risks present in your workplace

This is where everything starts.

Before deciding what preventive measures to implement, you need to understand what could cause an accident, injury, or health problem among your workers.

In a manufacturing facility, risks might involve machinery, noise, chemicals, or manual handling.

In a warehouse, you might look at forklift traffic, pedestrian movement, and loading operations.

And in an office? Risks exist there too, although they can be less obvious. Poor workstation ergonomics, excessive workloads, organizational tensions, and harassment are all examples.

Following the modernization of Quebec’s OHS framework, psychosocial risks must also be considered.

The important thing is not to simply copy a generic list of hazards from the Internet.

Your prevention program should reflect the risks that actually exist in your establishment.

There are two approaches you can use to identify workplace risks, either separately or together.

The first is to identify risks by category.

This involves reviewing your workplace activities and identifying potential hazards related to:

• Chemical risks

• Biological risks

• Physical risks

• Ergonomic risks

• Psychosocial risks

• Safety risks

The second is the ITEM method, which examines four components of work:

• Individual: Training, experience, skills, and supervision.

• Task: Work activities, procedures, movements, and frequency.

• Environment: Noise, workplace layout, contaminants, and surrounding conditions.

• Material: Tools, machinery, equipment, and vehicles.

This method helps identify hazards associated with actual work activities rather than relying solely on a general checklist.

In practice, both approaches complement each other.

Observing workstations, reviewing incidents and near misses, examining work methods, and consulting employees can all provide valuable information.

Changes to equipment, processes, or work organization may also introduce new risks that need to be assessed.

The CNESST provides a useful hazard identification tool to support this process.

2. Analyze risks to determine your priorities

Identifying a risk is only the beginning.

Your prevention program must also assess the identified risks so you can determine their significance and decide where to intervene first.

Consider this example.

In a manufacturing facility, you identify a machine with an exposed moving component that could injure a worker. In the same workplace, employees report discomfort related to their working posture.

Both situations deserve attention, but they may not require the same level of urgency.

Risk analysis helps you consider factors such as the potential severity of an incident, exposure to the hazard, and the conditions under which the work is performed.

The goal isn’t to create a complicated risk assessment spreadsheet just for the sake of it.

It’s to understand why certain issues require immediate attention and how the others will be addressed.

The CNESST’s prevention approach is built around identifying, analyzing, correcting, and controlling workplace risks.

3. Determine the appropriate preventive measures

Once risks have been analyzed, your program must identify the measures needed to eliminate or control them.

And here’s an important distinction.

The first response to a hazard shouldn’t automatically be to provide training or require workers to wear personal protective equipment.

Whenever possible, eliminating the hazard at its source should be the priority.

For example, if a machine has an exposed moving component, the first step should be to examine whether technical safeguards can eliminate or adequately control the risk.

Training and personal protective equipment may still be necessary, depending on the situation, but they should not automatically replace more effective solutions.

This approach follows the hierarchy of preventive measures promoted by the CNESST.

Your program should therefore describe specific actions rather than simply stating that employees must work safely.

A general instruction such as “be careful around equipment” isn’t a substitute for a preventive measure designed to address an identified hazard.

4. Establish responsibilities and deadlines

This is often where prevention programs become more difficult to put into practice.

A company identifies a risk, recommends a corrective measure, and then moves on to another issue.

Several months later, nothing has changed.

Why?

Sometimes it’s because no one was clearly responsible for implementing the measure. Other times, no deadline was established.

Your prevention program must include action priorities and implementation timelines.

It is also good practice to clearly identify who will be responsible for completing each action and monitoring its progress.

Here’s a simplified example:

This example illustrates how to turn prevention objectives into concrete actions. The final measures must, of course, be adapted to the results of your risk assessment.

With this structure, your prevention program becomes something managers can actually use.

5. Determine how preventive measures will be monitored

Installing a machine guard or changing a work procedure is an important step.

But how do you know whether the risk is now properly controlled?

That’s where monitoring and control measures come in.

Your prevention program must establish how you’ll verify that corrective measures remain effective over time.

Depending on the situation, this may involve:

• Workplace inspections

• Supervisory checks

• Preventive maintenance

• Exposure measurements

• Training follow-ups

• Verification of corrective actions

The CNESST specifies that the prevention program must identify the appropriate control measures, the people responsible for them, and the frequency of the required checks.

Let’s return to our forklift traffic example.

After redesigning pedestrian routes, it would be important to verify whether employees are using them, whether signage remains visible, and whether workers understand the new procedures.

A preventive measure doesn’t automatically become effective because it appears in a document.

You need to make sure it works under actual working conditions.

6. Include the other required elements of your prevention program

Risk management is a major part of an OHS prevention program, but it isn’t the only requirement.

Depending on the applicable regulations, your program must also address several elements related to how workplace prevention is organized.

These include:

• Appropriate personal protective equipment and other individual protective measures.

• Occupational health and safety training and information programs.

• Required health examinations, based on workplace risks and applicable regulations.

• An up-to-date list of hazardous substances used and contaminants that may be released.

• The organization of adequate workplace first aid services.

• A policy for preventing and addressing psychological harassment.

• Relevant elements of occupational health programs applicable to the establishment.

These requirements must be adapted to your workplace.

For example, an office with limited chemical exposure won’t have the same documentation needs as a manufacturing facility that handles several hazardous substances.

The objective isn’t to add unnecessary sections to your program. It’s to make sure all applicable requirements have been considered.

For a more detailed overview of the regulatory framework, consult the CNESST’s official information on OHS prevention programs.

7. Include psychosocial risks, not just physical hazards

This is one of the most significant changes in workplace prevention in recent years.

A company may have excellent procedures for machine safety, equipment maintenance, and operational risks, yet have far less structure when it comes to psychosocial hazards.

But these risks must also be part of the prevention process.

Psychosocial hazards can include harassment, workplace violence, exposure to potentially traumatic events, and domestic violence that affects the workplace.

Risk factors related to work organization also need to be considered, such as:

• Excessive workloads

• Limited autonomy

• Lack of recognition

• Insufficient support from colleagues or managers

• Poor organizational justice

Addressing these issues doesn’t simply mean adding a section called “psychological health” at the end of your prevention program.

Just like physical hazards, psychosocial risks must be identified, analyzed, addressed through appropriate preventive measures, and monitored over time.

If this is an area your organization still needs to develop, our article on the role of managers in psychosocial risk prevention provides practical guidance.

You can also read our more detailed article on integrating psychosocial risks into your OHS prevention program.

How often should an OHS prevention program be updated?

A prevention program isn’t something you prepare once and leave untouched for years.

In Quebec, it must be updated at least once a year.

However, certain changes may require an earlier review.

For example, if your company purchases new machinery, modifies a production process, or reorganizes its teams, the risks present in your workplace may change.

The relevant parts of your prevention program should then be reviewed without necessarily waiting for the next annual update.

The CNESST emphasizes that prevention programs must be implemented, monitored, and kept up to date.

Preventive and control measures also require ongoing follow-up.

Inspections, verifications, and adjustments should be carried out according to the established schedule, not postponed until the annual program review.

A practical approach is to conduct a complete review once a year while documenting significant changes as they occur.

How can you tell whether your prevention program is complete?

Before considering your program finished, try a simple exercise.

Choose an important risk in your workplace and follow it through your prevention program.

Ask yourself:

• Has the risk been clearly identified and analyzed?

• Is there a corrective measure in place or planned?

• Who is responsible for implementing it?

• What is the deadline?

• How will its effectiveness be verified?

• How will you ensure the measure remains in place and effective over time?

If you can’t find clear answers to these questions, something may be missing from your prevention process.

This exercise can reveal more than simply counting the number of pages in your document.

An 80-page prevention program can be difficult to apply, while a shorter, well-structured program may serve as a genuinely useful management tool.

Of course, a concise program must still meet all applicable regulatory requirements.

But ultimately, a good prevention program should be understandable and practical for the people responsible for implementing it.

Not sure where to start?

Not every company has a full-time OHS manager.

In many small and medium-sized businesses, workplace health and safety responsibilities fall to an HR manager, an operations supervisor, or someone who already manages several other priorities.

In these situations, it can be difficult to know whether an existing prevention program meets the current requirements or whether important steps have been overlooked.

A good starting point is Santinel’s free OHS self-assessment questionnaire.

For organizations that need additional support, our specialists can help develop or update a prevention program, from identifying workplace risks to implementing and monitoring preventive measures.

Our approach can be adapted to where your organization currently stands.

You don’t necessarily need to start over.

A useful prevention program, not just a compliant document

An OHS prevention program must meet regulatory requirements. But its real value lies in the actions it helps your organization take.

It should make it easier to identify hazards, set priorities, and verify whether the measures in place are genuinely protecting workers.

If you already have a prevention program, take the time to make sure it still reflects your current operations.

And if you’re unsure what’s missing, an outside perspective can help you determine your next steps.

At Santinel, we help businesses turn their OHS obligations into practical prevention measures tailored to their workplace.

Discover our Prevention Program Consulting Services to learn how we can support your organization.