The Act to modernize the occupational health and safety regime (Bill 59), adopted in 2021, has significantly changed employer obligations in Quebec. Since October 1, 2025, these new requirements are fully in effect for establishments with fewer than 20 workers.
What Has Changed?
Before the reform, only businesses in certain high-risk sectors were required to develop a formal prevention program. Now, all establishments, regardless of size or sector, must implement prevention mechanisms.
For businesses with fewer than 20 employees, the obligation takes the form of an occupational health and safety action plan. This plan must:
- Identify workplace hazards and risks
- Propose corrective measures with deadlines
- Assign a responsible person for each measure
- Be updated annually
The 6 Risk Categories to Assess
The CNESST requires risk identification across six categories:
- Physical risks — noise, vibration, temperature, lighting, falls
- Chemical risks — hazardous products, ventilation, WHMIS
- Biological risks — mold, infectious agents, hygiene
- Ergonomic risks — posture, manual handling, repetitive work
- Psychosocial risks — harassment, burnout, workplace violence
- Safety risks — evacuation, first aid, lone worker
The Liaison Officer: A New Requirement
Businesses with fewer than 20 employees must also designate an OHS liaison officer. This person serves as the contact between the employer and the CNESST. They must complete recognized training within one year of their designation.
What Are the Penalties?
Non-compliance can result in fines from $1,000 for basic offences (OHS Act s. 236) to over $60,000 per violation for serious offences (s. 237) in a first offence against a corporation. Repeat offences double the maximum (up to $150,000), and subsequent repeats triple it (up to $300,000 for a corporation). Amounts are indexed annually. The CNESST can also issue correction notices with strict deadlines.
How to Get Compliant Quickly
PlanSST was created specifically to help Quebec SMBs meet these new requirements. Our online tool guides you through:
- Risk identification with an industry-specific questionnaire
- Automatic action plan generation
- PDF export structured to section 61.2 of the AOHS
- Liaison officer management
In less than 30 minutes, you can have a complete action plan ready for inspection.
Your sector's questionnaire is free and the plan appears on screen; the PDF export and the four other documents cost $129, once → See what is included
The template is free
Download the OHS action plan template: the six hazard categories of the CNESST framework, as a PDF, to fill in by hand.
Get free templateOr, without filling anything in by hand: answer your sector's questionnaire and watch your plan write itself on screen (free, 30 min)
Founder of PlanSST
Product Manager with 6+ years of experience in SaaS solutions. Founded PlanSST to help Quebec SMBs comply with new OHS requirements.