All businesses in Quebec must now comply with the new occupational health and safety (OHS) requirements resulting from the modernization of the province’s OHS system. These obligations vary based on the number of workers and the establishment’s risk level and now include the management of psychosocial risks. Failure to comply directly exposes employers to penalties and increased liability in the event of an accident.
A new year means new resolutions and when it comes to occupational health and safety, OHS obligations now fully apply to all Quebec businesses.
Why is OHS compliance mandatory for employers today?
Occupational Health and Safety (OHS) compliance is no longer optional for businesses in Quebec. It is now:
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Mandatory, with clearly defined requirements
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Regulated and verifiable during inspections
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Evolving, particularly with the integration of psychosocial risks (PSR)
At the beginning of the year, the goal is not just to meet legal requirements, but to ensure that your prevention mechanisms are in place, adapted to your organization’s reality, and truly effective.
For leaders and managers, it’s also a way to reduce legal risks and start the year with confidence through full, controlled compliance.
What are the new obligations based on the number of employees?
The new OHS requirements are first determined by the number of workers in your establishment.
OHS Obligations for small businesses in Quebec (19 employees or fewer)
Businesses with 19 employees or fewer must now:
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Develop and implement an Occupational Health and Safety (OHS) action plan
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Appoint an OHS Liaison Officer (ALO)
For business owners and managers, these measures primarily serve to demonstrate good faith and proactive risk management in the event of an inspection or incident.
Obligations for businesses in Quebec with 20 employees or more
Companies with 20 or more employees must:
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Implement a Prevention Program
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Establish an Occupational Health and Safety Committee (OHS Committee)
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Appoint an Occupational Health and Safety Representative (OHS Representative)
These OHS obligations require documented management that is regularly updated and easily verifiable by the CNESST.
How to correctly calculate the number of workers for OHS compliance?
Calculating the number of workers is a key step and often misunderstood, which can lead to unintentional non-compliance.
Include individuals who work 21 days or more, such as:
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Full-time or part-time employees
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Temporary, casual, or agency workers
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Travelling or off-site workers
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Temporary foreign workers, interns, students, or volunteers under contract
Underestimating the actual number of workers is one of the most common OHS compliance errors.
Who should be excluded from the calculation?
Employer representatives are not included in the count, such as:
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Managers
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Supervisors
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Foremen
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Superintendents
This distinction is crucial to avoid false compliance.
What should an OHS action plan include in Quebec (19 employees or fewer)?
An OHS action plan must include the following:
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Identification and analysis of risks, including psychosocial risks
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Preventive measures and action priorities to eliminate or control identified risks
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Monitoring, evaluation, and follow-up measures
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Identification of personal protective equipment (PPE)
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OHS training and information for workers
An incomplete or poorly implemented action plan may be considered non-compliant during an inspection.
What is the role of the OHS liaison officer (ALO)?
The OHS liaison officer (ALO) plays a central role in communication and prevention.
Their responsibilities include:
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Facilitating OHS communication between the employer and workers
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Collaborating in the development and implementation of the action plan
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Making written recommendations on risk identification
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Filing a complaint with the CNESST if necessary
What is a compliant OHS prevention program (20 employees or more)?
The prevention program is more structured and must include:
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Identification and analysis of risks (including psychosocial risks)
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Preventive measures and action priorities
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Risk monitoring and evaluation
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Identification of personal protective equipment (PPE)
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Training programs
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Health examinations
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List of hazardous materials
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First aid services
How to set up an occupational health and safety committee (OHS committee)?
Establishing an OHS committee depends on the establishment’s risk level, which is determined using the first three digits of the NAICS code.
How to determine your company’s risk level?
There are two options:
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Consult Appendix 1 of the regulation on prevention mechanisms
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Use the CNESST online tool with your establishment’s address
What are the main functions of the OHS committee?
The OHS committee must:
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Determine training programs
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Select appropriate personal protective equipment (PPE)
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Participate in risk identification and analysis
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Maintain records of workplace accidents and occupational diseases
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Investigate accidents and make recommendations
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Receive and address complaints and suggestions
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Analyze inspection reports and statistical data
What is the role of the OHS representative (OHSR)?
The OHS representative plays a key role in workplace prevention. Their responsibilities include:
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Inspecting the workplace
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Investigating accidents
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Identifying sources of danger
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Making recommendations (including on psychosocial risks)
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Assisting workers and inspectors
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Participating during right-to-refuse situations
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Actively collaborating on the prevention program
How can Santinel help you achieve your OHS resolutions?
In occupational health and safety, the real challenge isn’t doing everything yourself, it’s being able to demonstrate that the right decisions have been made. As a leader or manager, you are legally responsible for OHS compliance. Santinel helps you turn this obligation into a clear, structured, and well-managed process.
Are you ready to take charge of your new obligations?
Ask yourself the right questions:
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Are you prepared to manage the new requirements?
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Do you know how to identify and analyze risks?
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Do you have the right tools to manage psychosocial risks?
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Is your OHS committee truly effective?
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Can you properly support your OHS representative or liaison officer?
With our turnkey OHS packages, we help you:
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Structure your action plan or prevention program
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Effectively manage risks, including psychosocial risks
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Support your liaison officer, representative, and OHS committee
Less administration, more prevention and full compliance.
