Psychosocial Risks in the Workplace: What Are Employers’ Obligations in Québec?

Psychosocial Risks: What Are We Talking About? 

The AOHS doesn't define PSRs, but the Institut national de santé publique du Québec (INSPQ) links them to factors related to work organization, management practices, employment conditions, and social relations. 

Depending on the setting, job functions, and circumstances, such factors may take the form of issues related to recognition, autonomy, support, communication, workload, or workplace relationships, although their existence, intensity, or effects cannot be assumed outright in any given organization. 

The AOHS further specifies that PSRs also include risks related to sexual violence. 

Depending on the context, such factors can affect psychological health, involvement and performance. If not properly addressed, their impact can quickly lead to tangible issues: absenteeism, turnover, tensions, incidents, complaints and, in some cases, claims related to psychological injuries. 

Psychosocial Risks: A Lever for Prevention and Organizational Performance 

Managing PSRs isn't just about prevention; it's also a way to manage risks. 

A proactive approach often helps reduce absenteeism and replacement costs, limit turnover, improve the work environment, and prevent sensitive issues (complaints, investigations, disputes). When well structured, a PSR strategy becomes an organizational asset and helps strengthen the organization’s overall performance. 

Customize the Approach to Your Specific Context 

PSRs are strongly influenced by the context: types of activities, peak periods, schedules, customer interactions, autonomy, supervision, working alongside third parties, etc. 

A credible approach relies on precisely identifying the risk factors specific to the organization, followed by realistic control measures that are monitored over time. 

Key Takeaway: Integrating Psychosocial Risks into Prevention and Participation Measures 

The new law does more than simply “recognize” psychosocial risks; it requires that they be addressed within the core prevention framework. Two elements are now central: 

Prevention Measures: Prevention Program or Action Plan 

Depending on the company's size, an employer must implement a prevention program (20 or more employees) or an action plan (fewer than 20 employees). 

While the format may vary, the goal remains the same: to eliminate PSR factors at the source whenever possible, or, otherwise, to manage them through a continuous process that is periodically updated (including during the annual review). 

Specifically, this means prioritizing issues, implementing appropriate measures (work organization, supervision, communications, training, mechanisms for reporting and addressing relational issues), and verifying their effectiveness. 

Participation Mechanisms: Health and Safety Representative (HSR) and Health and Safety Committee (HSC) 

The HSR and the HSC (when required) strengthen the credibility of the process: they help identify early warning signs, structure discussions, and support continuous improvement. 

As of October 1, 2025, an HSC must be implemented when a workplace has at least 20 workers for 21 days or more per year (and it must continue until December 31 of that year, even if the workforce falls below this threshold). 

Practically speaking, a solid PSR strategy is built around a continuous cycle: 

• Identify and document risky situations; 
• Analyze and prioritize the factors involved; 
• Implement targeted measures (with responsible parties and deadlines); 
• Evaluate, adjust, and incorporate updates into the existing prevention process. 

Risks of Non-Compliance: A Strategic Issue 

Failure to properly address psychosocial risks can lead to interventions and sanctions by the CNESST, as well as increasing the risk of investigations, complaints, and litigation (particularly regarding harassment or discrimination). 

Beyond the human and operational impacts, a lack of a clear, documented PSR management approach that is integrated into prevention and participation measures weakens the employer’s position when a sensitive issue arises and reduces their ability to act quickly, comprehensively and in a way that can be defended. 

PSRs are no longer a peripheral matter: they now form the foundation of prevention. 

Therefore, the right question is not simply: “Do we have a policy?” but rather: “Can we show that we have a consistent, documented approach that is integrated into our prevention and participation measures and that is truly adapted to our operational reality?” 

In many organizations, targeted support helps clarify applicable obligations, structure the framework (methodology, documentation, CSS/RSS roles), and prioritize tangible measures that are both practical on the ground and justifiable in the event of a dispute. 

A Labour and Employment Law Team to Support You with Psychosocial Risks 

Would you like to better understand your obligations, structure your prevention measures or adapt your approach to your organization's reality? 

Our labour and employment law professionals assist employers in clarifying the applicable obligations, structuring prevention procedures, and implementing measures tailored to their work environment and organizational challenges. 

For matters relating to psychosocial risks, contact Fatme Saleh and Eve Tremblay for guidance tailored to your organization’s specific needs and operational realities.