Moore Stephens
Human capital

Modernization of the occupational health and safety system – effective date

The interim plan falls within the scope of the modernization of the occupational health and safety regime (learn more about Bill 59 tabled in November 2020).

CNESST interim plan comes into effect

As of April 6, 2022, all organizations in Quebec, in all sectors of activity, depending on the size of their establishments, must implement prevention and participation mechanisms in the workplace, such as :

Your obligations depend on the size of your company and the priority group to which your organization belongs according to CNESST standards.

Calculate the number of workers

The number of workers per establishment must be determined in order to determine your obligations:

  • People to include: Full-time, part-time and casual workers, employment agency workers, workers on the road, students and trainees.
  • Persons to be excluded: Representatives of the employer, i.e. managers, foremen, superintendents, executives, etc.

Steps to follow under the OHSA

If you have more than 20 workers, you must:

  • Appoint a health and safety representative (HSR): the prevention representative must be appointed by the workers. The role of the representative is to carry out workplace inspections, make recommendations to the HSC and record them in writing.
  • Develop a prevention program: identify, record and analyze hazards in the workplace, and take steps to eliminate and control them. The prevention program is compulsory for all members of a prevention mutual group.
  • Set up an OHS committee (CSS) and provide mandatory training for its members. The committee’s role is to help identify risks and make recommendations to the employer. There is also a requirement for at least one meeting per quarter.

If you have fewer than 20 workers, you must :

  • Appoint a health and safety liaison officer: the liaison officer must be designated by the workers. The agent’s role is to facilitate the communication of occupational health and safety information, and to send written recommendations and identified risks to the employer.
  • Drawing up an action plan: a lighter version of the prevention program.

 

Multi-establishment approach / Interim regime (priority groups: 1, 2, 3)

All activities are of a similar nature in all plants (similar tasks and working conditions).

  • A prevention program for each facility;
  • A single health and safety representative (HSR) must be appointed;
  • A single health and safety committee (HSC) must be set up.

Multi-establishment approach
(priority groups: 4, 5, 6)

All activities are of a similar nature in all plants (similar tasks and working conditions).

  • A prevention program for all facilities;
  • A single health and safety representative (HSR) must be appointed;
  • A single health and safety committee (HSC) must be set up.

To find out more about priority groups and the occupational health and safety plan, visit the CNESST website.

Please do not hesitate to contact us if you have any questions. We would be delighted to support you in your compliance, training and prevention activities.

A little more on the modernization of the occupational health and safety regime.

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