Effective October 1, 2025, Quebec has extended the reach of occupational health and safety (OH&S) “prevention plan” requirements to additional employers, by granting assent (effectiveness) to the last provisions of 2021’s “Act to modernize the occupational health and safety regime (Bill 59)” by amending the “Act respecting occupational health and safety” (OHS Act) and a related Occupational Health and Safety Commission (CNNEST) regulation (Regulation respecting prevention and participation mechanisms in an establishment).
Which requirements are expanding?
Most provisions of Bill 59 came into force on October 6, 2021, but critical provisions were reserved and have only now come into force. These newly-effective provisions provide the following:
- Establishing requirements based on numbers of workers
Most of the new provisions apply to employers at each individual establishment with at least 20 workers.
- Requiring prevention programs
Effective October 1, the OHS Act (s. 59) defines this as follows:
“The object of a prevention program is to eliminate, at the source, risks to the health, safety and physical and mental well-being of workers. “Such a program must take into account the occupational health programs referred to in section 107, the regulations applicable to the establishment and, where applicable, the recommendations from the health and safety committee and must set out, in particular,
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- the identification and analysis of the risks that may affect the health of the establishment’s workers, including the chemical, biological, physical, ergonomic and psychosocial risks related to the work, and the risks that may affect the workers’ safety;
- the measures and priorities for action to eliminate or, failing that, to control the identified risks, giving precedence to the hierarchy of preventive measures established by regulation as well as the scheduling to accomplish the measures and priorities;
- the supervision, evaluation, maintenance and follow-up measures to ensure that the identified risks are eliminated or controlled;
- the identification of the individual protective means and equipment which are both in compliance with the regulations and best adapted to meet the needs of the establishment’s workers;
- the occupational health and safety training and information programs;
- the pre-employment medical checkups and medical examinations during employment required by regulation;
- the establishment and updating of a list of the dangerous substances used in the establishment and the contaminants that may be emitted there; and
- the maintaining of an adequate first aid service to respond to emergencies.”
Initial prevention programs must be prepared within 1 year (by October 1, 2026), and updated annually thereafter.
- Requiring action plans
Effective October 1, employers that are not required to establish a prevention program -- i.e., where all establishments have fewer than 20 workers -- must establish an action plan designed to “eliminate, at the source, dangers to the health, safety and physical and mental well-being of workers.” Each action plan must set out at least the following:
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- the identification of the risks that may affect the health of the establishment’s workers, including the chemical, biological, physical, ergonomic and psychosocial risks related to the work, as well as the risks that may affect the workers’ safety;
- the measures and priorities for action to eliminate or, failing that, to control the identified risks, giving precedence to the hierarchy of preventive measures established by regulation as well as the scheduling to accomplish the measures and priorities;
- the supervision and maintenance measures to ensure that the identified risks are eliminated or controlled;
- the identification of the individual protective means and equipment that, in addition to being in compliance with the regulations, are those best adapted to meet the needs of the establishment’s workers; and
- the occupational health and safety training and information.
Initial action plans must be prepared within 1 year (by October 1, 2026), and updated annually thereafter.
- Requiring health and safety committees
Health and safety committees are required at each establishment with at least 20 workers. However, effective October 1, CNNEST can require such a committee at an establishment with fewer than 20 workers. In addition, CNNEST’s new regulation provides details about the makeup and operation of these committees.
- Requiring health and safety representatives and liaison officers
Employers subject to prevention program requirements (i.e., at least 20 workers at any establishment) must designate a health and safety representative from among the workers. Employers subject to action plan requirements (i.e., fewer than 20 workers) must designate a health and safety liaison officer from among the workers. These workers must participate in specified health and safety activities.
What happens now?
Now that these health and safety provisions are effective, employers in Quebec must evaluate their requirements and prepare to comply no later than October 1, 2026. These new provisions should also serve as reminders for employers in other Canadian provinces and US states to review their workplace health and safety programs.
Self-Assessment Checklist
Does the organization operate any workplaces in Quebec?
- If so, has the organization evaluated workplace hazards faced by workers?
- If so, has the organization established health and safety protection measures to address those hazards?
- If so, is the organization prepared to comply with newly-effective health and safety requirements?
If the organization does not operate any workplaces in Quebec, has it evaluated occupational hazards in each workplace and taken appropriate steps to protect workers (including compliance with appropriate federal and/or state/provincial worker protection requirements)?
Where Can I Go For More Information?
- Quebec CNNST (Occupational Health and Safety Commission)
- Bill 59 (2021)
- Royal Assents, 3 September 2025 –
About the Author
Jon Elliott is President of Touchstone Environmental and has been a major contributor to STP’s product range for over 30 years.
Mr. Elliott has a diverse educational background. In addition to his Juris Doctor (University of California, Boalt Hall School of Law, 1981), he holds a Master of Public Policy (Goldman School of Public Policy [GSPP], UC Berkeley, 1980), and a Bachelor of Science in Mechanical Engineering (Princeton University, 1977).
Mr. Elliott is active in professional and community organizations. In addition, he is a past chairman of the Board of Directors of the GSPP Alumni Association, and past member of the Executive Committee of the State Bar of California's Environmental Law Section (including past chair of its Legislative Committee).
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