Developing a prevention program
Developed by the employer, with input from workers, the prevention program is the main prevention tool provided for in the Loi sur la santé et la sécurité du travail. It is one of the most effective ways to:
- make workplaces safe and eliminate hazards at the source
- structure and organize the prevention process
- identify hazards in the workplace
- prioritize prevention actions
- choose preventive measures and controls appropriate to the workplace
- energize the occupational health and safety committee and encourage worker participation
- meet legal or contractual obligations
The prevention program is a prevention action plan that is specific to each establishment and aims to eliminate or control workplace hazards through concrete measures.
All employers are encouraged to implement a prevention program, regardless of their sector of economic activity. It is a mobilization tool for workers to take charge of health and safety in their workplaces.
Employers who are members of a prevention mutual (in French only) or who belong to priority groups 1, 2 or 3 are required to establish a prevention program. When a construction site (in French only) employs 10 or more construction workers at the same time, a prevention program must be established.
The prevention program allows the employer to implement their prevention process in 3 steps.
The prevention process is based on continuous improvement.
The 3 steps must be completed several times and can be completed at different times. The prevention process is ongoing and requires regular follow-up depending on the results to ensure that the improvements and efforts made are maintained.
Identify - Establish ways to identify hazards in the workplace
The first step is to identify hazards based on:
- periodic inspections
- the Register of Accidents, Incidents and First Aid
- comments, complaints and suggestions made by workers, foremen or the health and safety committee
- the experience of other companies in the sector or other members of the prevention mutual
- risk analysis
Correct - Take action to correct these situations and eliminate hazards
The hazardous situations identified must then be corrected by eliminating the hazards.
If the hazard cannot be eliminated at the source, it must at least be controlled and workers must be protected until a permanent solution is put in place.
To do this, the employer must:
- choose the best solution based on their constraints
- set target completion dates and frequencies
- appoint a responsible person
- make the necessary improvements
- assess the results
- make further changes, if necessary
Control - Implement controls to prevent hazards from recurring
The employer must ensure the corrective measures put in place remain in place and remain effective by implementing controls.
Minimum program content
The prevention program must contain:
- the main sources of hazards in the establishment or work site
- the measures to be taken to eliminate or, if this is not possible, to reduce and control the hazards
- the measures to be taken to ensure that corrective measures are sustainable and effective so that hazards are eliminated or controlled permanently
- the timeframe for implementing the corrective measures and the names of the people responsible
In all cases, the Règlement sur le programme de prévention and any regulations relevant to the situation must be complied with at a minimum.
The prevention program is unique to each company. There is no model, since each company is at a different level when it comes to occupational health and safety management.
The CNESST provides a few templates, such as:
- a prevention sheet and bar chart in the Guide de prévention en milieu de travail (in French only)
- a hazard identification, correction and control table in the Outil d’identification des risques (in French only)
Submission of the program
For companies that belong to priority groups 1, 2 or 3, the employer must submit the prevention program within one year of the date of the start of its activities and then at the time of its annual update to:
- the certified association
- the industry association
- the CNESST
- the health and safety committee, if any
- the physician in charge
- the prevention representative
For construction sites, the prevention program must be submitted to the CNESST at least 10 days before the start of work.
- When activities on a construction site are expected to occupy at least 25 workers at the same time.
- When it involves the construction of one or more buildings on a site occupying 10,000 metres or more in total area.
- When a construction site presents a high risk of accidents.
Implementing the prevention program
Once a prevention program has been developed, it must be implemented and integrated into routine operations. It must also be adapted over time to changes in the workplace.