Québec employers face significant new obligations with overhaul of provincial health and safety regime

At a glance

• On 1 October 2025, Québec implemented Order in Council 1154-2025, introducing permanent provisions of Bill 59 to modernise occupational health and safety.
• Employers with 20+ workers must adopt a comprehensive prevention programme; smaller establishments must maintain an action plan.
• Health and safety committees, representatives, or liaison officers are now mandatory, with training and participation requirements.
• Employers must maintain a register of contaminants and hazardous substances and submit updates to the Commission des normes, de l'équité, de la santé et de la sécurité du travail (CNESST) every three years.
• The reform marks a major shift towards proactive risk management and structured compliance obligations for all Québec employers.

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On 1 October 2025, Québec reached a milestone in occupational health and safety reform with the coming into force of Order in Council 1154-2025, implementing certain permanent provisions of Bill 59: 'An Act to modernise the occupational health and safety regime' (Act). The resulting amendments to the Act respecting occupational health and safety complete a significant overhaul of Québec’s health and safety framework.

The new regime introduces obligations for employers, requiring a proactive and structured approach to workplace risk management. Below is a non-exhaustive overview of the principal requirements now in effect and their implications for organisations operating in Québec.

Key amendments and employer obligations

Prevention programme or action plan

Employers with 20 or more workers must implement a prevention programme. This programme must, among other items, identify and analyse all risks that may impact the health of the establishment’s workers, whether chemical, biological, physical, ergonomic, or psychosocial, and set out measures to eliminate or, where elimination is not feasible, control risks in accordance with the hierarchy of preventive measures established by regulation.

The programme must also include an implementation schedule, monitoring and follow-up procedures, and an inventory of hazardous substances and contaminants. Employers are responsible for providing appropriate personal protective equipment, delivering training and information, and maintaining adequate first aid services.

For establishments with fewer than 20 workers, employers must develop and maintain an action plan aimed at eliminating, at the source, dangers to the health, safety, and physical and mental well-being of workers. The plan must, among other items, identify risks, set preventive measures and priorities, and include supervision and maintenance procedures.

Both the prevention programme and the action plan must be reviewed and updated annually. In addition, employers must submit an update to CNESST every three years, reporting on the progress of action priorities, the measures implemented, and the follow-up completed to eliminate, or control identified risks.

The CNESST may, if it considers it advisable for protecting workers’ health or ensuring their safety and physical or mental well-being, require an employer to implement a prevention plan regardless of the number of workers.

Multi-establishment programme

Employers operating multiple establishments engaged in similar activities may implement a single, unified prevention programme covering all or part of those establishments. This consolidated programme must address all activities carried out within the covered establishments and remain in effect for a minimum of three years. The CNESST may, however, require separate programmes for specific establishments if deemed necessary.

Committees, representatives, and liaison officers

Employers must establish a health and safety committee in any establishment that has 20 or more workers for at least twenty-one days during the year. Committees must meet at least quarterly during regular working hours and actively participate in preparing, updating, and monitoring the prevention programme. Their expanded responsibilities include identifying risks and contaminants, reviewing recommendations from health and safety representatives, and consulting occupational health providers when necessary. Members must complete CNESST-approved training within prescribed timelines and may take time off without loss of pay to attend.

In establishments with fewer than 20 workers, employees must designate a liaison officer to facilitate communication and cooperate in implementing the action plan. Liaison officers must complete CNESST-approved training within one year of designation and are entitled to time off without loss of pay. Registration, travel and accommodation expenses are borne by the CNESST. The liaison officers may submit written recommendations to the employer regarding risk identification and must receive a response within thirty days; failure to respond allows the officer to file a complaint with the CNESST.

Where a committee exists, at least one health and safety representative must be designated from among the workers. This representative becomes a committee member and participates in inspections, investigations, and risk analysis. Representatives must complete mandatory training and can take time off without loss of pay to fulfil their duties. Their functions include making recommendations, cooperating in prevention measures, and informing the committee of investigation results. The time allocated to these duties is determined by agreement or, failing that, by regulation.

Contaminants and hazardous materials register

Employers must maintain a register of contaminants and hazardous substances present in the establishment. This register must identify contaminants and hazardous substances in accordance with regulatory requirements, be kept current, and be communicated to workers, the health and safety committee, the certified association, and the Public Health Director. It must also be transmitted to the CNESST in the manner prescribed by regulation and may include a list of workers exposed to these substances.

Implications for employers

The deadline for complying with the obligations outlined in this bulletin was not extended, as previously anticipated. Employers should therefore review their current practices and ensure immediate alignment with the new requirements to ensure compliance with these new health and safety obligations.

For more information or inquiries regarding Québec’s new occupational health and safety obligations for employers, please contact one of our DLA Piper (Canada) LLP Quebec employment and labour lawyers.