What does Quebec's occupational health and safety law require for worker training?

Which training duties does the Act itself set?

Section 51(9) is the general duty. The employer must adequately inform the worker of the risks related to their work. It must also ensure the training, instruction and supervision appropriate for the worker to have the skill and knowledge to do the work safely.

Section 10(1) states the same duty from the worker's side. A worker has the right to training, information and advisory services in occupational health and safety, particularly in relation to their own work and workplace.

The Act does not say how the training is delivered, how long it lasts, or how it is documented. Those details come from regulations, from CNESST guidance, or from the employer's own prevention program.

Which regulations add specific training requirements?

Three instruments turn the general duty into named requirements.

Hazardous products. Section 62.5 of the Act requires a training and information program on hazardous products, with minimum content set by regulation. The Regulation respecting information on hazardous products fills that in. Section 29 requires the program to reach every person exposed, or likely to be exposed, to a hazardous product. It must be adapted to the workers, the workplace and the products present. Section 30 lists the content, starting with the meaning of labels, signs and safety data sheets, then training on the hazard information.

Forklifts. Section 256.3 of the Regulation respecting occupational health and safety reserves forklift operation to a trained operator. The training covers basic forklift concepts, the workplace and its effect on driving, driving itself, and safety rules. A practical component under the supervision of an instructor is added.

Confined spaces. Section 298 of the same regulation restricts confined space work to workers aged 18 or more who have the required knowledge, training or experience. Section 297 defines the qualified person who identifies, assesses and controls the hazards by reference to knowledge, training or experience.

Does the law require a training register or a retention period?

As read on the access date, neither the Act nor the Regulation respecting occupational health and safety sets a general retention period for training records. Neither one requires a training register as such. Section 62.5 adds a duty to make sure, at the intervals and in the cases a regulation sets, that the training a worker received still provides the required knowledge.

What the law leaves open is the form of the proof. The duty in s. 51(9) is a duty of result, and the employer is the party who has to show it was met. The dates, the content covered and the names of the people trained are the elements a record would need to carry for that purpose.

Who is responsible for training agency and contractor workers?

Section 51.1 extends the employer's obligations to a person who uses the services of a worker for the purposes of their establishment without being that worker's employer. The duties of s. 51, including the training duty in s. 51(9), follow the work, not the payroll.

How does EmbayLMS handle this?

EmbayLMS records every completion with a date and keeps it when the learner's account is deactivated, so the proof outlives staff turnover. Training that has to recur, such as hazardous products refreshers, is assigned on an interval, expires on schedule and is reassigned without an administrator's intervention. The history exports by course, by person or by period, which is the form a CNESST inspection request tends to take.

This page summarizes statutory provisions in general terms as they read on the access date given for each source. It is not legal advice, and it does not state what the law requires of your organization. Consult a lawyer about your own obligations before you rely on it.