Prevention program or action plan: what the CNESST expects from a Québec construction company (2026)

Action plan due October 1, 2026, prevention program at 20 workers, job-site rules: who owes what in Québec construction, and where to start.

Since October 1, 2025, a Québec construction company with five, ten or fifteen workers has an obligation it did not have before: a health and safety action plan (plan d'action) — written, applied and updated every year. The CNESST gave employers one year to put it in place. For a company that already existed on that date, the deadline therefore falls on October 1, 2026.

The topic is poorly understood for a simple reason: in construction, prevention has two levels. There is what the law asks of your company, and what it asks on each job site — and neither the thresholds nor the people responsible are the same. This guide untangles the two, then shows where to start without spending a month on it.

Two levels: your company, and your job sites

The Act defines an establishment by excluding construction sites… while specifying that the word includes “a construction firm”. The CNESST says it plainly: a construction company is considered an establishment, and the employer must apply the mechanisms that exist for establishments. On top of that, when the company acts as principal contractor (maître d'œuvre) of a large enough site, come the mechanisms specific to construction sites.

First level: your company

Everything starts from one number: how many workers the establishment groups during the year.

Three situations move a small company from the action plan to the prevention program, even with 19 workers or fewer: a contractual obligation toward its prevention mutual group (mutuelle de prévention) — check this if you belong to one —, a grouping of several establishments, or a direct requirement from the CNESST.

Who counts as a worker

• Counted: full-time, part-time and casual workers, agency or loaned workers, trainees under contract — and, the point that matters in construction, those who work “on the road or in another workplace”. Your crews on job sites therefore count toward the company's headcount.
• Not counted: the employer's representatives. The CNESST gives as examples the manager, the foreman, the superintendent and the supervisor.
• An employer who hires no workers has none of these mechanisms to put in place.

The CNESST offers a worker-count calculator; the link is in the sources. And if your headcount drops below 20 during the year, the prevention program must be maintained until December 31 of the following year.

The liaison officer, in two sentences

In an establishment of 19 workers or fewer, the workers designate one of their own as health and safety liaison officer; that person must take a training course. They collaborate on the action plan and can send you written recommendations, notably on hazard identification: you have 30 days to reply.

What an action plan contains

The list is in the Act (section 61.2), and it is shorter than people fear. An action plan provides in particular for:

• the identification of risks — chemical, biological, physical, ergonomic, psychosocial, and those affecting safety — including those that particularly affect workers aged 16 and under;
• the measures and priorities for action to eliminate those risks or, failing that, control them, with timelines — favouring elimination at the source over protective equipment;
• supervision and maintenance measures: who checks that the measure still holds, and how often;
• the best-suited personal protective equipment;
• worker training and information — the CNESST gives as an example a health and safety meeting at the start of the shift;
• the psychological harassment prevention and complaint-handling policy, which the Act respecting labour standards already requires.

The prevention program of an establishment with 20 workers or more builds on that base and adds, among other things, the analysis of risks, the list of hazardous materials and first aid. It also leads, every three years, to a filing with the CNESST — priorities for action, progress, follow-up — on a form that, at the date of this article, is not yet available.

Second level: the job site

Here the person responsible is no longer “the employer” but the principal contractor: the owner, or the person responsible for carrying out all of the work. It is often the general contractor; it can be the client. The contract should say so in black and white, because everything below rests on that person.

The threshold is read at the peak: the number of workers present simultaneously, at some point during the work, as forecast before starting. A copy of the program goes to the health and safety representative and to ASP Construction; above certain size or risk thresholds, the principal contractor also files it with the CNESST before the work begins (the criteria are on the page cited in the sources).

If you are a subcontractor

• On a site where a prevention program applies, the principal contractor must obtain from each employer a written undertaking to have it complied with (section 202).
• The CNESST specifies that subcontractors, on arrival, submit to the principal contractor their methods and prevention measures specific to the work they will carry out.
• In case of incompatibility, the principal contractor's program takes precedence over your company's action plan or program (section 203).

In other words: your action plan does not exempt you from the site's program, and the site's program does not exempt you from yours. The first covers your people, wherever they work; the second covers a place, for everyone who passes through it.

Where to start: five steps

What follows is a method, not the text of a law: the order in which a small company can go about getting to an action plan that is actually useful.

1. Count your workers, without foremen or superintendents. The number decides the tool; also check what your prevention mutual group requires, if you have one.
2. Have the liaison officer designated by your workers, and register them for their training.
3. Identify the risks with your crew, not on their behalf. The CNESST makes it the first step of the prevention approach, asks that it be done in writing and that it cover work done elsewhere than in the establishment — so, on your sites. Start from your types of work: a roof, an interior demolition and an excavation do not expose people to the same things.
4. For each risk: a measure, a person responsible, a deadline — and someone who checks that the measure still holds six months later. Eliminate at the source first; protective equipment comes last.
5. Write it, date it, review it every year. A three-page action plan that the crew knows and applies beats an eighty-page binder nobody has opened.

Where you are not alone

• The CNESST offers support for drawing up an action plan or a prevention program: prevention advisors, psychological health advisors, inspectors.
• ASP Construction, the industry's joint sector-based association, publishes tools and gives training — including one on running toolbox talks.
• The CNESST guide “Entreprises et chantiers de construction — principaux risques” (in French) reviews the six families of risks, trade by trade.

Where BatiCore helps — and where it stops

BatiCore does not write your action plan, does not score your sites and certifies no compliance: those remain your actions. What it does is make the first step — identifying the risks and recalling them — workable day to day:

• for each site, you tick the risks present across the six families, and add what is specific to the place;
• the morning briefing, on the crew's phones, uses those risks instead of a generic list, and keeps the date, the points covered and the signatures;
• a hazard identification grid in PDF, per site, that you can attach to your action plan or your prevention program — it does not replace it;
• the incident register and the per-site threshold reminder, in the Compliance module.

Per-site risks and the briefing are part of the Job Sites module (Business plan and up). What BatiCore covers on the CNESST, RBQ and CCQ side is described on the Québec compliance page.

The BatiCore team

We build BatiCore, management software for Québec construction contractors — estimates, job sites, CCQ payroll, compliance. Our articles cite dated public sources; when a fact comes from a regulator or a competitor, we say which one and when. Spotted an error? Write to us, we fix it.