WHMIS in Quebec: What CNESST Requires of Employers

At the federal level, the Hazardous Products Act and the Hazardous Products Regulations (HPR) apply to suppliers, whose SDS and label must be in both official languages (HPR, s. 6.2(1)).

In a Quebec establishment, the Act respecting occupational health and safety (LSST) and the Hazardous Products Information Regulation (RIPD) set the employer's duties. CNESST inspects and prosecutes.

CNESST inspectors can investigate and run tests (LSST, s. 180), issue a correction notice (avis de correction) with a deadline (LSST, s. 182) and, where there is danger, order work suspended or a site closed and apply seals (LSST, s. 186). CNESST may bring a penal prosecution (LSST, s. 242).

Section 236 sets the fines for any contravention; section 237, for a person who directly and seriously endangers a worker. Each distinguishes a first offence, a repeat offence and a further repeat offence, and a natural person from a legal person. The amounts are indexed every January 1 (LSST, s. 237.1).

2026 ranges for a legal person (CNESST, Cadre d'émission des constats d'infraction, mars 2026):

• Section 236: $2,115 to $4,226 (first offence), $4,226 to $8,451 (repeat), $8,451 to $16,904 (further repeat).
• Section 237: $21,127 to $84,519 (first offence), $42,261 to $211,299 (repeat), $84,519 to $422,596 (further repeat).

An employer may not allow a hazardous product to be used, handled or stored without a compliant label and SDS, or before the exposed worker has received the required training and information. The one exception: storing the product while the employer diligently takes the steps to obtain them (LSST, s. 62.1).

The employer sends a copy of each SDS to the health and safety committee or the health and safety representative, keeps it and makes it readily accessible to every worker at the workplace. It consults the committee, or the workers, on the best way to give access (LSST, s. 62.6).

It writes a workplace SDS when the supplier does not provide the required SDS or when it manufactures the product on site (RIPD, s. 17), without having to complete headings 12 to 15 (RIPD, s. 18). The SDS may be electronic if it stays easily legible and rapidly available on paper to any worker likely to be exposed (RIPD, s. 20). A lost or illegible SDS is replaced immediately (RIPD, s. 22).

Significant new data is new hazard data that changes the product's classification or the means of protection (RIPD, s. 1). The employer notifies the workers and the committee or representative as soon as possible, and updates the SDS within 90 days (RIPD, s. 23).

The label, sign and SDS must be in French. A translation may accompany the French text, but may not prevail over it or be more accessible (LSST, s. 62.4). The Charte de la langue française applies the same rule to inscriptions on a product, its wrapping and its directions for use (Charte, s. 51).

A supplier label that complies with federal law is enough (RIPD, s. 4). The employer prepares a workplace label in cases including a missing supplier label, a bulk product, decanting and a product made on site; it gives the product name, precautionary statements and a statement that the SDS is available (RIPD, ss. 6 to 8).

An illegible label is replaced immediately (RIPD, s. 10) and updated within 180 days of significant new data (RIPD, s. 11). A portable container filled from a labelled container, used by one worker and emptied in the same shift, may carry just the product name (RIPD, ss. 12 and 13). Piping, reaction vessels and conveyors must be clearly identified (RIPD, s. 14).

Training documents for staff must be available in French. The employer may write exclusively in another language to a worker who asks for it (Charte, s. 41).

The employer applies a training and information program set by the health and safety committee or, without a committee, by the employer in consultation; it is part of the prevention program where one is required (LSST, s. 62.5).

The program is adapted to the workers, the workplace and the products, and includes ways to check understanding (RIPD, s. 29). It is updated annually or as soon as the situation requires (RIPD, s. 31). Training is required for every new worker, a new task, a new hazardous product and when significant new data changes a label or SDS (RIPD, s. 32).

Workers are entitled to appropriate training and supervision (LSST, ss. 9 and 10). The employer informs them of the risks of their work and gives them the list of hazardous materials used in the establishment (LSST, s. 51, pars. 9 and 13). CNESST does not deliver, accredit or certify WHMIS training: there is no official certificate.

Quebec follows the 90-day rule, as do Ontario, Alberta, Manitoba, New Brunswick and Prince Edward Island. Elsewhere, the employer must actively seek an updated SDS every three years.

Quebec also requires French (LSST, s. 62.4). For an employer with sites in Quebec and elsewhere, the simplest approach is one system built to the strictest rule: one bilingual SDS library, SDSs replaced as soon as significant new data is known, and training delivered in French in Quebec.

Compare WHMIS rules in every province