Québec’s workplace safety landscape is undergoing a seismic shift, and employers are at the epicenter. Starting October 1, 2025, a sweeping overhaul of provincial health and safety regulations will demand a fundamentally new approach to risk management. But here’s where it gets controversial: while the reforms aim to protect workers, some argue they place an undue burden on businesses, particularly smaller ones. And this is the part most people miss: the new rules aren’t just about compliance; they’re about fostering a culture of proactive safety, a shift that could redefine Québec’s work environment for generations.
Order in Council 1154-2025, which enacts key provisions of Bill 59, marks a turning point. It’s not just an update—it’s a complete transformation of how employers must address occupational health and safety. Let’s break it down in a way that’s easy to grasp, even if you’re new to the topic.
What’s Changing?
1. Prevention Programs and Action Plans:
Employers with 20 or more workers must now adopt a comprehensive prevention program. This isn’t just paperwork—it’s a living document that identifies, analyzes, and mitigates risks, from chemical hazards to psychosocial stressors. Think of it as a safety blueprint tailored to your workplace. Smaller businesses aren’t off the hook; those with fewer than 20 workers must maintain an action plan focused on eliminating risks at their source. Both require annual updates and triennial reports to the Commission des normes, de l’équité, de la santé et de la sécurité du travail (CNESST).
2. Mandatory Committees, Representatives, and Liaison Officers:
Here’s where collaboration takes center stage. Larger workplaces must establish health and safety committees, while smaller ones must designate liaison officers. These roles aren’t just ceremonial—they come with training requirements, paid time off for duties, and a mandate to actively participate in safety initiatives. For example, liaison officers can submit recommendations to employers and escalate unresolved issues to the CNESST. This shared responsibility is a game-changer, but it also raises questions: Will smaller businesses have the resources to meet these demands?
3. Contaminants and Hazardous Materials Register:
Every employer must now maintain a detailed register of all contaminants and hazardous substances in their workplace. This isn’t just about ticking boxes—it’s about transparency. Workers, committees, and even public health officials must have access to this information. The CNESST will also receive updates, ensuring accountability. But here’s a thought-provoking question: Could this level of transparency lead to increased scrutiny or even legal risks for employers?
4. Multi-Establishment Programs:
For employers with multiple locations, there’s good news: a single prevention program can cover all sites engaged in similar activities—provided it’s comprehensive. However, the CNESST reserves the right to demand separate programs for specific locations if needed. This flexibility is a win for efficiency, but it also underscores the need for careful planning.
Why This Matters
These reforms aren’t just about avoiding fines—they’re about saving lives and preventing injuries. Québec’s shift to proactive risk management aligns with global best practices, but it’s also a bold move that could set a precedent for other provinces. However, the devil is in the details. Smaller businesses, in particular, may struggle with the administrative burden, and the training requirements could strain already tight budgets. Is this a fair trade-off for safer workplaces, or does it place too much on the shoulders of employers?
What Employers Need to Do Now
The clock is ticking. With no extensions granted, employers must immediately review their practices and align them with the new requirements. This includes training staff, updating policies, and ensuring compliance with reporting obligations. Ignoring these changes isn’t an option—the CNESST has the authority to enforce them, and the consequences of non-compliance could be severe.
Final Thoughts
Québec’s new health and safety regime is a bold step forward, but it’s also a lightning rod for debate. While the focus on prevention is commendable, the practical challenges for businesses—especially smaller ones—cannot be overlooked. Do these reforms strike the right balance between worker protection and business viability? We’d love to hear your thoughts. Share your perspective in the comments—let’s start a conversation that could shape the future of workplace safety in Québec.