Who needs an OHS action plan?
Since October 1, 2025, the prevention and participation mechanisms of Québec’s Act respecting occupational health and safety (LSST) apply in every workplace in Québec. Workplaces with 19 workers or fewer must put two mechanisms in place:
- An occupational health and safety action plan, prepared and applied by the employer and updated at least once a year
- A health and safety liaison officer (ALSS), designated by the workers themselves
Larger workplaces have a prevention program, a health and safety committee and a health and safety representative. In smaller ones, the ALSS plays that role and the action plan replaces the prevention program: a simpler tool, suited to their size.
What the action plan must contain
The action plan is the workplace’s prevention management tool. It is prepared with the participation of the ALSS and the team, and covers:
- The risks identified, their priority level and the measures to eliminate or control them, with an owner and a deadline for each measure
- Monitoring and maintenance measures that keep risks under control over time
- Personal protective equipment and other prevention measures
- Health and safety training and information provided to staff
- The psychological harassment prevention and complaint policy
It can be on paper or in electronic form and may include photos or videos.
The six types of risks to consider
The law requires every workplace, offices included, to consider six types of risks:
- Physical: noise, lighting, temperature
- Ergonomic: poorly adjusted workstations, handling, repetitive movements
- Biological: contact with the public, mould, first aid
- Chemical: cleaning products, solvents, toners
- Psychosocial: overload, conflict, harassment, violence from clients
- Safety: falls, cuts, fires, work-related travel
Psychosocial risks are part of the exercise like any other: an action plan that only covers falls and fire extinguishers is incomplete.
Building your action plan in 5 steps
- Designate the ALSS: workers choose their liaison officer, whom the employer then involves throughout the process.
- Identify risks with the team: individual interviews, a workshop or a walk-through, using a questionnaire and the ITEM method (individual, task, environment, materials).
- Prioritize: for each situation, assess frequency and potential severity, then rank the risks (1 urgent, 2 medium, 3 planned).
- Choose measures following the hierarchy of prevention: eliminate the hazard at the source first, personal protective equipment last. Name an owner and set a deadline for each measure.
- Communicate and follow up: post the plan, present it to every new hire, hold a health and safety check-in at team meetings at least twice a year and review it every year.
Common mistakes
- Filling in a template alone, without consulting the team or the ALSS
- Leaving out psychosocial risks
- Relying mostly on protective equipment instead of eliminating hazards at the source
- Leaving the ALSS’s recommendations without a written reply: the employer has 30 days to respond
- Letting the plan gather dust: it must be updated at least once a year and whenever something changes