On October 1st, significant changes to Quebec health and safety laws came into force – expanding employer legal obligations in Quebec workplaces.
Historically, only employers in certain designated industries had to establish a health and safety committee, appoint a representative, and develop a prevention program. Quebec Bill 59, An Act to modernize the occupational health and safety regime expanded these requirements to all employers with 20 or more workers. And even small employers (with less than 20 workers) have new requirements to develop health and safety action plans and appoint liaison officers.
So, what new legal obligations does Bill 59 establish for Quebec employers?
Quebec Health and Safety Prevention Programs
Employers must prepare and implement a health and safety prevention program at each establishment employing at least 20 workers. Where workers carry on activities of the same nature in multiple establishments, employers may implement a single prevention program for all or part of the establishments (unless the Commission orders otherwise).
The objective of a prevention program is to eliminate risks to health, safety and physical/mental well-being of workers. Programs must address items such as:
- risk identification and analysis
- measures and priorities to eliminate/control identified risks
- employee training
- employee medical exams
- dangerous substances in the workplace
- first aid
- psychological harassment policy.
Employers must prepare and implement a prevention program within 1 year of becoming subject to this requirement, and update their prevention program every year. This means that Quebec employers have until October 1, 2026 to get their prevention program in order.
Quebec Health and Safety Committees and Representatives
Employers must set up a health and safety committee at any establishment employing at least 20 workers. Employers with a single prevention program for multiple establishments can, similarly, set up a single health and safety committee for all of those establishments.
The committee must include worker and employer representatives. The number of workers’ representatives on a health and safety committee must be determined by agreement between the employer and the workers. Where there is no agreement, the new health and safety regime sets out rules describing how to designate worker representatives, as well as other committee procedures.
Establishments with a health and safety committee must also designate at least one health and safety representative (who is a de facto committee member) from among the workers.
Quebec health and safety committees and representatives have wide-ranging duties, including:
- review of workplace accidents and inspections
- health and safety risk identification and analysis
- development of the prevention program.
Employers must cooperate with health and safety committees and representatives, and deem them at work (i.e., pay them) when they are participating in committee/representative duties.
Small Employers – Action Plans & Liaison Officers
Employers with less than 20 workers are subject to somewhat different requirements.
Instead of a prevention program, they must develop an action plan. Action plans must cover many of the same topics as prevention plans (listed above), but exclude issues that are more likely to apply to larger workplaces (e.g., employee medical exams and dangerous substances).
Rather than a health and safety committee and representative, small employers must appoint a health and safety liaison officer. While liaison officers are not involved in workplace accidents and investigations, many of their duties are similar to health and safety committees and representatives, including:
- recommendations regarding health and safety risks
- development of the action plan
- promotion of health and safety communication.
Note: Establishments with less than 20 workers may have to implement a prevention program, establish a committee or appoint a representative if required to do so by the Commission.
Quebec Health and Safety Training
Before Bill 59, Quebec health and safety training requirements were not well defined. Now the Act respecting occupational health and safety includes a detailed training regime for health and safety committees, representatives and liaison officers.
Within 120 days of their designation, committee members and representatives must obtain a training certificate that covers a list of specified topics (e.g., legislative framework, prevention program, roles and responsibilities). Health and safety representatives must receive additional training specific to their role.
Liaison officers have one year after their designation to participate in a training program determined by the Commission. (Note: No further details are available to date.)
Compliance Works makes it easy to stay on top of changes to health and safety legislation across Canada, including Quebec
- See Reminders of upcoming deadlines and amendments to employment legislation.
- Create a report of recent Amendments, which you can find under My Info.
- Read plain language summaries of the upcoming changes in Info Hub.
Start your free 14-day trial and see how easy compliance can be.
Contact us to Request a Demo or email us at info@complianceworks.ca to learn how a subscription to Compliance Works can help your HR team succeed.
