Future employer, did you know that new occupational health and safety requirements are now in effect? Here is an overview of the new obligations introduced in October 2025.
Since October 6, 2025, all establishments with more than 20 employees must:
- Develop a prevention program (service offered by GSC);
- Implement an action plan;
- Form a health and safety committee (HSC);
- Appoint a health and safety representative (HSR).
To help you better understand these new obligations, here are the details of the four points mentioned above.
1.1 Prevention program required when the establishment [1] has more than 20 workers:
This program is a prevention tool provided for by the Occupational Health and Safety Act (OHSA). It is a written, structured document that brings together all of the company's activities, procedures, and work instructions.
The employer remains primarily responsible, but implementation must be carried out in collaboration with the health and safety committee (HSC) and the health and safety representative (HSR).
The objective and content of the Prevention Program:
59. The purpose of a prevention program is to eliminate at the source any hazards to the health, safety, and physical and mental integrity of workers.
In addition to the health program referred to in Article 113 and any other elements prescribed by regulation, it must contain:
1° programs to adapt the establishment to the standards prescribed by regulations concerning the layout of workplaces, work organization, equipment, materials, contaminants, hazardous substances, processes, and collective protective measures and equipment;
2° measures to monitor workplace quality and preventive maintenance measures;
3° the health and safety standards specific to the establishment;
4° the procedures for implementing other rules relating to occupational health and safety in the establishment, which must include at least the content of the regulations applicable to the establishment;
5° identifying personal protective equipment and devices that, while complying with regulations, are best suited to meet the needs of workers at the establishment;
6° training and information programs on occupational health and safety.
2.1 Is an action plan required when the establishment has fewer than 20 workers?
The action plan has a variable duration, depending on the projects it includes. It must be reviewed and updated regularly to ensure its effectiveness. Its implementation is the responsibility of the employer and must be carried out by the liaison officer.
Here is what the action plan should contain:
- Written document;
- Structure the steps to be taken and plan the necessary resources;
- Prioritization of activities to be implemented;
- Communicate prevention measures and responsibilities to managers and workers;
- Proposed activities to improve OSH performance indicators;
- Mobilization of staff and focus on established priorities.
3.1 Composition of a health and safety committee
Special features
68. A health and safety committee may be formed in an establishment with more than twenty workers belonging to a category identified for this purpose by regulation.
69. A health and safety committee is formed on written notice to the employer by an accredited association or, if there is none, by at least ten percent of the workers or, in the case of an establishment with fewer than forty workers, by at least four of them, or on similar notice given by the employer to an accredited association or, if there is none, to all the workers. A copy of the notice must be sent to the Commission.
When it deems it appropriate, the Commission may require the formation of a health and safety committee, regardless of the number of workers in the establishment.
70. The number of members of a committee is determined by regulation, taking into account the category to which the institution belongs.
CSS designation:
71. At least half of the committee members represent the workers and are appointed in accordance with section 72. The other members of the committee shall be appointed by the employer.
72. The worker representatives on the committee are appointed from among the workers at the establishment.
They are appointed by the accredited association when it represents all workers in the establishment.
When several accredited associations represent all the workers in the establishment, they may, by agreement, designate the workers' representatives. If they cannot agree, the designation of representatives shall be determined in accordance with the terms and conditions set out in the regulations.
In other cases, the appointment of representatives shall be determined in accordance with the procedures laid down by regulation.
How meetings work
74. The Health and Safety Committee shall meet at least once every three months, subject to the regulations.
Meetings are held during regular working hours, unless otherwise decided by the committee.
If the committee fails to establish its own operating rules, it must apply those established by regulation.
CSS functions
78. The duties of the health and safety committee are:
1° to select, in accordance with Article 118, the physician responsible for health services in the institution.
2. to approve the health program developed by the responsible physician pursuant to Article 112;
3° establish, within the prevention program, training and information programs on occupational health and safety;
4° to choose the means and personal protective equipment which, while complying with regulations, are best suited to the needs of the workers in the establishment;
5° to review the other elements of the prevention program and make recommendations to the employer;
6° to participate in identifying and assessing risks related to workstations and the work performed by workers, as well as in identifying contaminants and hazardous materials present in workstations for the purposes of section 52;
7° to keep records of workplace accidents, occupational illnesses, and events that could have caused them;
8° to provide the Commission with the information it requires and an annual activity report in accordance with the regulations;
9° to receive copies of accident reports and investigate events that caused or could have caused a workplace accident or occupational illness, and submit appropriate recommendations to the employer and the Commission;
10° to receive suggestions and complaints from workers, the accredited association, and the employer relating to occupational health and safety, to take them into consideration, to keep them on file, and to respond to them;
11° to receive and review reports of inspections carried out in the establishment;
12° to receive and review statistical information produced by the responsible physician, Santé Québec, the Nunavik Regional Board of Health and Social Services, or the Cree Board of Health and Social Services of James Bay, as applicable, and the Commission;
13° to perform any other task that the employer and the workers or their accredited association entrust to him under an agreement.
CSS display:
80. The employer must post the names of the members of the health and safety committee in as many places in the establishment that are visible and easily accessible to workers as is reasonably necessary to ensure that they are informed.
4.1 How to appoint a Health and Safety Representative (HSR) [2]
Establishments required to form a health and safety committee (HSC) must also appoint a health and safety representative (HSR). The HSR is a member of the HSC. They actively participate in meetings, make recommendations, and may be given additional mandates by the committee.
In addition, the CNESST may, if it deems it necessary, require the appointment of a health and safety representative in an establishment that does not have a health and safety committee, in order to ensure the protection of the health, safety, and physical or mental integrity of workers.
Designation of the RSS
Anyone working at the establishment can become a health and safety representative, whether they are full-time, part-time, casual, or seasonal employees.
Functions of the RSS
210. The health and safety representative's duties are:
1. to inspect workplaces;
2° to receive copies of accident reports and investigate events that caused or could have caused an accident;
3° identify situations that may pose a danger to construction workers;
4° to make any recommendations it deems appropriate, including those concerning psychosocial risks related to work, to the site committee or, failing that, to construction workers or their representative association, to the employer and to the health and safety coordinator or project manager;
5. to assist construction workers in exercising the rights granted to them by this Act and the regulations;
6° to accompany the inspector during inspection visits;
7° to intervene in cases where the worker exercises his or her right of refusal;
8° to file a complaint with the Commission
Common errors
- Turning up at a construction site and thinking it unnecessary to wear personal protective equipment, on the pretext that inspectors never visit the site.
- Developing a prevention program without complying with the requirements of the OHSA.
- Failure to present the prevention program to all site stakeholders, including workers, supervisors, foremen, COSS, RSS and the site committee.
- Wait for a visit from a CNESST inspector before implementing a prevention program.
In conclusion
You are now in compliance with CNESST standards. However, stay tuned, as new requirements may be introduced in the near future.
Please feel free to contact our occupational health and safety expert, Geneviève Grondin, at 514-814-5928, for assistance with your occupational health and safety compliance efforts.
Schedule a meeting with Geneviève Grondin today to ensure the safety of your worksites through a compliant and effective prevention program!
FAQ: New occupational health and safety requirements (LSST)
Who is affected by the new requirements in force since October 6, 2025?
These obligations apply to all establishments with more than 20 employees.
What are the four new essential obligations for employers?
The employer must:
- Develop a prevention program
- Implement an action plan
- Form a health and safety committee (HSC)
- Appoint a health and safety representative (HSR)
What is a prevention program?
It is a written and structured document, required by the Occupational Health and Safety Act (OHSA). It brings together all of the company's procedures, instructions, and activities aimed at ensuring safety on a daily basis.
What is the specific objective of this program?
It must include measures to bring the facility into compliance with regulatory standards, particularly with regard to the layout of the premises, work organization, equipment, and the management of hazardous materials and contaminants.
Is it possible to get help in developing this prevention program?
Yes. Although the employer is responsible for this, it is strongly recommended that you seek assistance. The GSC Group offers this specific service to help you build a compliant and comprehensive program. Contact Geneviève Grondin at 514-814-5928 for more information.
Schedule a meeting with Geneviève Grondin today to ensure the safety of your worksites through a compliant and effective prevention program!
[1]"establishment": all facilities and equipment grouped together on the same site and organized under the authority of the same person or related persons, for the purpose of producing or distributing goods or services, with the exception of a construction site; this term includes, in particular, a school, a construction company, and premises made available by the employer to the worker for accommodation, food, or recreation, with the exception, however, of private premises used for residential purposes; (Chapter 1 – Definitions of the Occupational Health and Safety Act)
[2] Health and safety representative in an establishment | Commission des normes de l’équité de la santé et de la sécurité du travail – CNESST (Commission on Standards, Equity, Health and Safety at Work)