All regions of Québec have officially moved to the green alert level since June 28, 2021 as part of the provincial government's progressive deconfinement plan. In fact, there are no longer any regions in the red, orange and yellow zones in Québec.
On July 7, 2021, the Minister of Health and Social Services of Québec announced that new, more relaxed sanitary measures will come into effect on July 12, 2021 and will apply to the whole province.
In light of these new relaxed measures, the Commission des normes, de l'équité de la santé et de la sécurité au travail (the "CNESST"), which continues to monitor the evolution of Québec's progressive deconfinement, recently modified the preventive measures applicable in workplaces located in green zones. Such changes to the preventive measures modifies certain previous measures contained in the Guide des normes sanitaires en milieu de travail.
The increased vaccination coverage and the improvement in the epidemiological situation in Québec have allowed the CNESST to implement such changes. However, the CNESST reminds us that it may quickly review the proposed changes depending on the evolution of the situation.
Below is an overview of the preventive measures that have been amended for the green alert level in which workplaces are located.
Green Alert Level
The preventive measures applicable in green zone provide that teleworking is recommended, but that a gradual "in person" return to the workplace is possible.
Certain preventive measures remain mandatory in green zone. Hand sanitation, exclusion of symptomatic persons and compliance with respiratory etiquette are required in all workplaces in Québec.
Certain other preventive measures are optional in green zone. Wearing eye protection is optional, unless otherwise required by the applicable regulatory requirements. In addition, disinfecting shared tools and equipment is also optional.
In green zone, wearing a mask at all times is recommended rather than mandatory, both indoors and outdoors, as long as the mandatory physical distance is maintained OR a physical barrier is installed. In other words, employees will have to maintain a physical distance amongst each other OR be separated by a physical barrier OR wear a mask. The mandatory physical distance is 2 meters when employees are indoors and when they are on the move (for example: in a car, truck, bus, plane or in the elevator). However, the mandatory physical distance is 1 meter when employees are outdoors.
Furthermore, cleaning and disinfection surfaces such as washrooms and lunchrooms as well as frequently touched surfaces during each work shift may be mandatory or optional, depending on the applicable rules. The CNESST specifies that the applicable rules are available and can be consulted in the CNESST COVID-19 toolkit and on the INSPQ website.
The CNESST has indicated that, when a measure is "optional" or "recommended", it is up to the employer to choose the measures it deems necessary to protect its employees against the risks of contamination. Therefore, employers may continue or cease to apply the "optional" or "recommended" measures they deem necessary to ensure the health and safety of their employees.
In order to facilitate the implementation of the amendments, the CNESST has developed a summary table of the adapted preventive measures applicable in the green zone. This document can be consulted by clicking here.
As such, employers must be aware of the amendments made to the preventive measures in order to continue their activities under conditions adapted to the sanitary situation, while protecting the health and safety of their employees.
The authors would like to acknowledge the support and assistance of Félix-Antoine Pelletier, articling student at law
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