Ontario head office, Quebec sites: one Loi 27 duty per site

Does Loi 27 apply to our Quebec sites if head office is in Ontario?

The Act asks the employer for a program or plan specific to each establishment. Article 58 asks the employer for a prevention program specific to each establishment that groups at least 20 workers during the year. Article 61.1 asks for an action plan specific to the establishment where no program has to be drawn up. Below 20 workers, a program is still required where a regulation says so or where CNESST, Quebec's workplace health and safety body, requires one.

Article 58.1 lets an employer with workers in more than one establishment where the activities are of the same nature draw up a single program for some or all of them, once it has made sure the functions under articles 78 and 90 can be exercised adequately, and that program must also cover the establishments with fewer than 20 workers. Whether your Quebec sites are of the same nature, and whether a store or a dealer is your establishment or someone else's, is a question for your counsel.

Each Quebec establishment has a program or plan of its own, unless the employer groups establishments of the same nature under article 58.1; counsel can confirm which applies to you. OHA sets out the law in one screen on its Loi 27 page.

What does Loi 27 ask a Quebec establishment to put in writing?

A program aims to eliminate at the source the dangers to workers' health, safety and physical and psychological integrity (art. 59). It has to include, among other things, the identification of the risks that can affect workers' health, including the chemical, biological, physical, ergonomic and psychosocial risks linked to work. It also sets measures and priorities to eliminate each risk or, failing that, control it, favouring the hierarchy of prevention measures set by regulation, with timelines, and measures to check that the identified risks are eliminated or controlled.

The harassment policy is part of the same document. The Act respecting labour standards requires the employer to adopt and make available a policy to prevent and handle psychological harassment, and says that this policy is an integral part of the prevention program or action plan (art. 81.19). Among other things, the policy sets out the methods used to identify, control and eliminate the risks of psychological harassment and the information and training offered, and keeps records for at least two years.

How long does the regulation give a site to draw up its program?

In most cases the regulation gives an employer one year to draw up and apply a program or plan, counted from the moment it becomes subject to the obligation under the Act; some changes of regime must be made without delay (art. 4). That regulation, on prevention and participation mechanisms in establishments, came into force on 1 October 2025, according to CNESST's release of that day.

When a given site became subject depends on the site, so this post does not give you one date; CNESST or your counsel can confirm it. After that the rhythm is yearly: the employer updates its program or plan every year (art. 5). For a program, the employer also sends CNESST, every three years from the day it is applied, its action priorities, the progress of the planned measures and the follow-up of those in place. CNESST's program page said on 27 October 2026 that the form for this is not yet available.

Where does workload enter a Quebec site's program?

CNESST says that a high workload is a risk factor that can be present in any workplace, and that the employer must take it into account in its program or action plan. It defines workload as the quantity and complexity of the tasks to be done in a given context, and notes that it has a subjective side: each worker can perceive the load differently.

Workload is one factor among several. CNESST names decision latitude, workload, organizational justice, recognition at work, support at work and different forms of violence, and asks that they be considered together rather than one by one. INSPQ, Quebec's public health institute, lists workload among the six psychosocial factors of its grid for identifying psychosocial risks at work.

From Toronto, the hard part is that the register of risks describes a week you do not see. The people who see it are the managers on site: where real work only advances after hours, which decisions are reopened, who is the bottleneck. Our post on how to spot psychosocial hazards in a team shows where to look. The check below takes about a minute; it uses five of the ten statements in OHA's capacity self-portrait, one for each load.

Can one plan serve both Ontario and Quebec?

The documents are not the same. Ontario's page for employers describes policies and programs on workplace violence and workplace harassment. In Quebec, the harassment policy sits inside a wider program or plan that also identifies psychosocial risks, sets measures against them and is updated every year. Whether your Ontario documents can be adapted for a Quebec establishment is a question for your counsel.

What can be shared is the way of working. A head office can ask the same questions in both provinces: what is consuming the managers' week, which load dominates, what was changed and what moved. The Quebec program remains the establishment's own.

Why measure the load before choosing the measure?

Because the program asks for measures against identified risks, and a measure chosen before the load is read is a guess. The Act asks for measures to eliminate each risk or, failing that, control it (art. 59), and CNESST says workload is perceived differently from one worker to the next. A reading of the team's load, taken the same way twice, is designed to help show which load to act on first and whether the action moved it.

OHA's Five Loads (decisional, cognitive, emotional, relational and administrative) are built to read that load. The CNESST and INSPQ factors stay the reference for the law; the Five Loads sit beside them, as a way to see which kind of demand dominates in a given team.

Two readings 90 days apart also give a head office something to bring to the person who owns each Quebec establishment's program: what was measured, what was changed and what moved. That informs the follow-up the program calls for; whether an establishment complies is a matter for CNESST and your counsel.