Differentiation between an action plan and a prevention program

A little reminder, as you have surely heard on many occasions, since April 6, 2022, all establishments that do not already have prevention mechanisms must implement the interim prevention and participation mechanism plan.

What is the interim regime? It is a regime that prepares employers, who were not obliged to apply the prevention program, to put in place a prevention program and/or an action plan as well as certain participation mechanisms. These measures are palliative to OHSA and will be permanent.

For more information on the modification of the OHSA and the interim regime, you can download our ebook.

Let’s start at the beginning, we believe that the action plan is the basis of the prevention program. To make it even simpler, let’s make an analogy: it is ideal to have a recipe to make a cake. The action plan is the recipe, and the prevention program is the cake. Thus, we believe that the action plan must be developed first for the prevention program to take place. To properly manage everyone’s tasks resulting from the prevention program, our team believes that the prevention program should always be accompanied by an action plan.

Now that you know the difference, what does the action plan consist of?

The action plan is a document that brings together the identification of risks and the various tasks to be carried out in your workplace to make it safe. The risks present as well as the steps to be taken to control them will be determined. Corrective action can then be taken. The action plan includes elements such as

• Prioritization according to the level of risk;
• Legal requirements and/or good practices;
• Corrective and control measures to be put in place;

• The people responsible;
• Dates and indicators.

Measurable objectives can also be defined to monitor the progress of the action plan. Overall, this is the structure to be implemented to achieve optimal risk management.

To see an example of a confined space hazard and how we address it in an action plan, click here.

Please note that in the regulations, the action plan will only become mandatory for establishments with 20 workers or less following the adoption of the Regulation on prevention mechanisms. However, in order to optimize the management of OHS prevention, MEDIAL provides an OHS Action Plan for all of its clients.

Let’s move on to the prevention program!

As mentioned previously, the prevention program is the cake, which corresponds to all the elements listed in the action plan. It is therefore the result of the execution of the tasks listed in the action plan to achieve effective OHS management.

It includes, among other things, the roles, and responsibilities of everyone as well as the work policies and procedures to be applied to correct and/or control the risks.

These two prevention mechanisms go hand in hand, since the tasks to be carried out, as indicated in the prevention program, come from and/or are found more clearly in the action plan. They are presented in the form of means of control. This approach will ensure the sustainability of the prevention program and will facilitate the follow-ups to be carried out by the various prevention stakeholders (OHS committee, OHS representative, liaison officer, managers, etc.).

The prevention program will become mandatory only for establishments with 20 workers or more following the adoption of the Regulation respecting prevention mechanisms.

By implementing your action plan with MEDIAL+ today, you will

• Meet your new risk identification and analysis obligations;
• Get ahead of the curve, as this is a time-consuming process;

• Benefit from the advantages of accident prevention;
• Benefit from the support of the occupational health and safety committee, since the HSC assists the employer in the identification, analysis and implementation of the action plan.

Be equipped and facilitate your work!

*It is important to mention that the content presented in this article corresponds to the interpretation of MEDIAL and its team of preventionists for section 59 and section 61.1 of the OHSA.

According to the CNESST, the interim plan will remain in effect until the legislative and regulatory provisions on facility-specific prevention mechanisms come into effect. Changes will be made to the content of prevention programs and action plans by October 6, 2025.

We therefore undertake to update this article in accordance with the CNESST’s announcements concerning the prevention program and action plan.