Protocols and measures to be followed when resuming construction work

On April 13, Quebec Premier François Legault announced the resumption of residential construction for projects to be delivered no later than July 31, 2020. He said he did not want to add a housing crisis to the current health crisis. To ensure the protection of workers, the government has established, in collaboration with the Institut national de la santé publique and the Commission des normes, de l’équité, de la santé et de la sécurité au travail (CNESST), additional health and safety measures that employers will have to implement on worksites when they reopen.

Health check

From April 20, 2020, employers will have to check the health of their returning workers on a daily basis, by asking them a series of questions. Employers must require workers who show symptoms of COVID-19 (cough, fever, sudden loss of sense of smell), who have travelled outside Canada in the 14 days prior to returning to work, or who have been in contact with a person suffering from COVID-19 to remain in home isolation.

Social distance on construction sites

Employers are responsible for ensuring that social distancing standards are met when workers arrive on site, during breaks, meals and when leaving the site. They will have to coordinate and plan the work so as to respect the 2-metre standard between workers. When the work will require the collaboration of several workers, they must make sure to keep the same work teams for jobs requiring proximity between workers, until the building is completed.

Cleanliness and hygiene measures

The CNESST does not recommend the wearing of personal protective equipment (gloves, mask, etc.) on construction sites, and reiterates that the best measures remain washing hands and avoiding touching the face. Thus, employers will have to provide workers with soap or other alcohol-based cleaning substances (60% or more), as well as a hand dryer, roll-up towels or paper towels.

The government also requires workers to wash their hands mid-shift and at the end of the shift, in addition to washing their hands on entering and leaving the worksite. They must do so before and after lunchtime, at every break and when using the toilet. He also recommends not sharing tools. Where necessary, employers will be required to disinfect shared tools and work equipment between uses and at the end of the shift.

Toilets are mandatory on construction sites and must be cleaned 2 times per shift. Where there are 25 or more workers on a site, flush toilets and washbasins supplied with clean, tempered water must be provided. For a site with fewer than 25 workers, a chemical toilet will suffice.

When a dining room is required to be made available to workers under the Construction Safety Code [1] employers must ensure that tables, chairs, fixtures and fittings have been cleaned after each use and shift.

Consequences of non-compliance

Failure to comply with the above guidelines could lead to closure of the construction site until these protective measures are properly implemented. Offending employers could also be issued with statements of offence.

The CNESST is aware of the difficulty of navigating all these measures, and has set up a daily verification tool for employers to help them implement these directives [2].

Finally, the decision to reopen the sites will have consequences for other players in the construction industry, since the Ministry of Labour, Employment and Social Solidarity has stressed that they will also have to restart their activities. This includes surveyors, building inspectors, transport services and building materials supply chains [3].

By Catherine Demers


[1] RLRQ, c. S2.1, r.4, art. 3.2.9.

[2 ] The Daily Checklist is available online at https://www.cnesst.gouv.qc.ca/salle-de-presse/Documents/liste-verification-construction-COVID-19.pdf.

[3] COVID-19 pandemic – Minister Jean Boulet confirms the addition of residential construction sites to the list of priority services and activities, online: http: //www.fil-information.gouv.qc.ca/Pages/Article.aspx?aiguillage=diffuseurs&listeDiff=349&type=1&idArticle=2804130371.

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