Since the modernization of Quebec's occupational health and safety regime (Law 27), all organizations with 1 to 19 workers are legally required to implement an Occupational Health and Safety (OHS) Action Plan.

Contrary to a common misconception, not being required to have a formal prevention program does not mean having no obligations. Law 27 imposes a structured, documented, and demonstrable prevention approach, even for small organizations.

What Is an OHS Action Plan?

Definition: An OHS action plan is a document that identifies workplace hazards and specifies the measures to eliminate or control them, as well as the follow-up actions to be carried out.

It must cover:

  • physical hazards, and
  • psychological hazards, including psychosocial risks (PSRs).

Why Law 27 Changed the Rules for SMEs and Nonprofits

Before the obligations under Law 27, many small organizations:

  • managed OHS informally,
  • reacted mainly after incidents occurred,
  • documented very little.

With the modernization:

  • prevention becomes proactive,
  • hazards must be identified in advance,
  • employers must be able to demonstrate due diligence.

Important: In the event of an inspection or complaint, what matters is documented action, not intent.

What Risks Must Be Included in an OHS Action Plan?

Law 27 - Quebec OHS modernization requires that the OHS action plan cover all hazards present in the workplace, not only traditional physical risks.

According to the CNESST, employers must take responsibility for all of the following types of risks:

Chemical Risks

Examples: inhalation of substances, absorption of chemical products, handling hazardous materials.

Biological Risks

Examples: infectious agents, viruses, bacteria, allergens, exposure to biological fluids.

Physical Risks

Examples: electrical hazards, heat or cold, noise, vibration, falls, environmental conditions.

Ergonomic Risks

Examples: awkward postures, manual handling, repetitive movements, poorly adapted workstations.

Safety-Related Risks

Examples: moving parts, vehicles, machinery, confined spaces, collision or crushing hazards.

Psychosocial Risks

Examples: violence, harassment, traumatic events, deteriorated work climate.

All of these risks must be identified, corrected, and controlled as part of the OHS action plan.

Psychosocial Risks: A Legal Obligation in Force Since October 6, 2025

Since October 6, 2025, all Quebec employers are legally required to identify, correct, and control psychosocial risks within their organization.

Psychosocial risks are now fully recognized as health risks under the Occupational Health and Safety Act (OHSA).

The 5 Psychosocial Risk Factors Recognized by the CNESST

According to the CNESST, the following psychosocial risk factors related to work organization must be assessed:

  • Low decision-making autonomy
  • High workload or work overload
  • Organizational justice
  • Low recognition at work
  • Low workplace support

These factors must be addressed in the same way as physical, ergonomic, or chemical hazards.

Work-Related Psychosocial Risks

In addition to organizational risk factors, the CNESST also identifies work-related psychosocial risks that must be included in the prevention approach:

  • Prevention of workplace harassment
  • Prevention of workplace violence
  • Domestic violence (intimate partner or family violence) when it may impact the workplace
  • Traumatic events experienced in the course of work

These obligations are closely linked to Bill 42 and must be integrated into the OHS action plan.

The 5 Essential Steps of a Compliant OHS Action Plan (1 to 19 Workers)

Identify the risks

Observe real work situations, consult workers, and analyze known problem areas.

Prioritize the risks

Not all risks can be addressed at once. Prioritization must be realistic and justified.

Define concrete measures

Organizational, preventive, or control measures adapted to the organization's reality.

Assign responsibilities

Who does what, within what timeframe, and with what resources.

Ensure follow-up and updates

Verify effectiveness, make adjustments, and update the plan as conditions change.

Prevention is an ongoing process, not a one-time document.

OHS Action Plan vs. OHS Policy: A Common Confusion

  • An OHS policy expresses principles and intentions.
  • An OHS action plan defines concrete actions, responsibilities, and timelines.

Law 27 requires an action plan, not just a policy.

How to Demonstrate Compliance During a CNESST Inspection

An employer must be able to provide:

  • a written OHS action plan,
  • proof of hazard identification,
  • evidence of implemented measures,
  • records of follow-up actions.

What is not documented is extremely difficult to defend, even if actions were taken.

Quick Summary

  • Law 27 requires organizations with 1 to 19 workers to have an OHS action plan
  • All types of risks must be covered
  • Psychosocial risks have been mandatory since October 6, 2025
  • The 5 CNESST psychosocial risk factors must be assessed
  • Demonstrating preventive action is essential

Need Support?

Exact RH can help you implement a Law 27-compliant OHS action plan:

  • Identification of physical and psychosocial risks;
  • OHS action plan development;
  • Manager training;
  • PSR identification tools at www.exact360.ca.

Don't leave compliance to chance.

Contact us: 1-866-950-3357