Psychosocial risks: New rules take effect around prevention plans

Quebec’s approach to occupational health and safety has undergone a major transformation, with new rules in force addressing not just physical but psychosocial risks in the workplace.

As of Oct. 6, 2025, the Act to modernize the occupational health and safety regime (commonly known as Bill 27) now explicitly requires employers to document their prevention efforts for psychosocial risks — factors that can erode mental health — such as excessive workload, lack of recognition or unclear roles.

The new framework covers a broad range of organizational, relational and contextual factors that can affect workers’ mental health, dignity and well-being — moving beyond the traditional focus on harassment or violence, and demanding a systemic approach from employers.

“It really shows that the Quebec… government wants employers to focus on the psychological wellness of workers… as much as they would for physical danger,” says Arianne Bouchard, associate at Dentons Canada in Montreal.

New rules around psychosocial risks

The legislative overhaul has been years in the making. Since 2003, employers have been required to prevent or stop psychological harassment; since 2021, they are mandated to protect workers from situations involving physical or psychological violence.

That includes having a prevention program with input from a joint health and safety committee made up of employer and employee representatives.

With the most recent provisions (known as Bill 27), the obligation to prevent psychosocial risks is now explicitly set out in the health and safety legislation.

What are psychosocial risks? The Institut national de santé publique du Québec (INSPQ) defines them as: "Factors that are related to work organization, management practices, employment conditions and social relations and that increase the probability of generating adverse effects on the physical and mental health of exposed individuals."

And they matter because of the potential impact on mental and physical health, says the government agency, along with productivity, absenteeism, turnover, presenteeism, early retirement and workplace accidents.

The main psychosocial risk factors in Quebec workplaces include:

• high workload
• low recognition
• low autonomy at work
• low support from colleagues or supervisors
• lack of communication and information
• psychological harassment.

Organizations with 20 or more workers must now develop, implement and maintain a prevention program that includes the identification and analysis of risks to workers’ health, such as chemical, biological, physical, ergonomic and psychosocial risks.

“Basically, in a prevention program, they need to identify all the risks, and they need to identify the steps that would be taken,” says Bouchard. “Ideally, they want to eliminate the risk; if it's not possible, they want to control the risk; and if it's not possible, they want to mitigate the risk.”

This will also help when it comes to showing that employers made best effort to avoid risks, much like with workplace accidents, she says.

“It's helpful to raise a due diligence defence, basically, to say, ‘OK, yes, that still happened, but we did everything we could so it won't happen, so we are very careful.’”

Identifying workplace risks

However, when it comes to identifying the risks, that’s a challenging endeavour, says Bouchard. While employers may be familiar with the idea of psychological health, such as that related to harassment, that’s more related to a crisis situation, she says.

“Psychosocial risk is much broader than that. It’s saying there are risk factors that are associated with that [factor],” says Bouchard, such as the amount of decision-making autonomy a worker has.

Employers must go beyond checking for physical or biological risks, says Martine Haines, senior director of business transformation and human resources management at Raymond Chabot Grant Thornton in Montreal.

“You also have to be aware about the stress and to be aware about everything around mental health, and also be aware about the violence that can be there in your work environment,” she says, including domestic violence.

Some risks can be easier to detect, such as aggressive customers in a store, says Haines. But for other areas, a diagnosis is probably the best way to analyze the whole environment, such as employee surveys or focus groups to hear about people’s autonomy or workloads.

“This is why they're talking about a prevention program, because it's a little bit more systemic,” she says.

“We have to think about the whole organization. That means that we have to be conscious that it won't be the same if I'm working on the street, like a cop or like a fireman — I'm not doing the same job than my colleagues that are working in an administrative work. So I have to… have in mind all the risks and that they can be different.”

Assessing workload, employee recognition

Unlike physical hazards, psychosocial risks are often subtle and evolving.

“This is challenging because those are not things that we’re used to looking at,” says Haines, with employers considering factors such as workload, decision-making autonomy, and recognition.

“The employer needs to monitor the workload of their people… if it’s always [bad], it can put an employer at risk while it has never been looked at from a health and safety perspective,” she says, citing the need to evaluate the capacity of people around the volume of demand, as an example.

When it comes to workload, the employer needs to monitor levels to make sure they’re acceptable, says Bouchard.

“It's possible that there are some periods with a [heavy] workload, but if it's always like that, it can put an employer at risk [and] that has never been looked at from a health and safety perspective.”

Similarly, looking at how much recognition is given to employees is a factor, she says: “It's considered a risk in the same sense like chemical risk, for example, and so it is a challenge for sure for employers to be able to identify.”

Assessing employee recognition is a new frontier in OHS, whereas before it was more about the employees’ experience, says Bouchard.

“It’s no longer just that, it’s also a legal obligation,” she says. “That can become problematic if there is no recognition at all.”

Unlike harassment, which should never happen in the workplace, factors such as employee recognition or a person’s workload have varying degrees, and the government is not requiring “specific levels,” says Bouchard.

“Workloads, they can be up and down but if the workload is always to the top, it can [mean] people are burnt out.”

Mitigating psychosocial risks

When it comes to mitigation, employers are required to outline the steps they are taking to reduce if not eliminate risks.

For employee recognition, that could mean regular feedback processes or check-ins.

“Until now, [recognition] was more [about] the employees’ experience,” says Bouchard. “It was something that, yes, it's a nice to have if you want to… be recognized as a good workplace and you want to be able to attract people and to retain employees as well.

“But now, it's no longer just that — it's also a legal obligation.”

With the prevention program, it’s about outlining the best means to eliminate or diminish psychosocial risks, says Haines, adding the government hasn’t been prescriptive about the requirements.

“There's no obligation about ‘You should do exactly these things, these steps,’ so, it's kind of flexible — but it has to be done.”

Other mitigation efforts can include training managers to better delegate work or review processes to avoid heavy workloads, and employers can identify different approaches for different groups of employees or locations.

“You can identify in your program or in your plan that this might be a challenge or a particular area of risk for a category of worker and not necessarily the others,” Bouchard says.

According to a report from the Université du Québec à Rimouski, there are several ways that employers can work to prevent psychosocial risks, such as:

• Involve senior management and staff in creating, communicating, and regularly reviewing policies that prioritize psychological health.
• Foster open, transparent communication and actively identify and address risks to psychological health.
• Provide clear reporting mechanisms, act promptly on incidents, and offer support and training for staff.
• Foster a culture of recognition and provide both formal and informal acknowledgment of staff contributions.
• Regularly consult with staff about workload, methods, and priorities.
• Provide training on workload and time management.
• Offer teams more autonomy, encourage skill development, and allow flexible scheduling.
• Implement policies on the right to disconnect and promote a healthy digital culture.
• Facilitate recovery through breaks and support for emotionally challenging tasks.
• Enforce zero-tolerance policies for workplace violence, domestic/family violence, and psychological harassment.

Employee participation in prevention programs

A cornerstone of the new regime is employee involvement. Employers can no longer develop prevention programs in isolation.

“Another big portion… is really focusing on employees’ participation and giving an active role to the employees’ representative either through the committee or the health and safety representative and everything that is related to the prevention of [risks] in the workplace,” Bouchard says.

For companies with 20 or more employees, a joint health and safety committee—comprising both employer and employee representatives—is mandatory. Smaller organizations must have at least one employee representative involved in the action plan, Haines explains.

Training is also required: health and safety representatives and committee members must complete basic training, available online from the CNESST, to ensure everyone understands their roles and the nature of psychosocial risks, Haines says.

In the end, the changes and requirements are meant to help employees, says Bouchard

“Most employers, in my experience, want their employees to be healthy and to feel safe and this is a goal. So, I think that this is something that we should support.”