Québec Premier François Legault announced on April 13th, the reopening of construction sites for residential construction scheduled to be delivered by July 31, 2020. He said he did not want to add a housing crisis to the current public 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 safety and hygiene measures to be implemented by employers on construction sites upon reopening.

Health checks

As of April 20, 2020, employers will have to check the health of workers who return to work daily, by asking them a series of questions. They will require the worker who displays symptoms of COVID-19 (cough, fever, sudden loss of smell), has travelled outside of Canada within 14 days of returning to work or who has been in contact with a person diagnosed with COVID-19, that he remains in segregation at home.

Social distancing on construction sites

Employers will be responsible for ensuring that social distancing regulations are respected when workers arrive on-site, during breaks, meals and when they leave the site. They must coordinate and plan the work so as to respect the standard of 2 meters between workers. When the work will require the cooperation of multiple workers, they must make sure to keep the same work teams for the works which require proximity between workers, until the end of construction of the building.

Cleanliness and hygiene measures

CNESST does not recommend wearing personal protective equipment (gloves, mask, etc.) on construction sites and reiterates that the best measures are hand washing and avoiding touching your face. Thus, employers must provide workers with soap or alcohol-based cleaning solutions (60% or higher), as well as hand dryers, hand towels or rolled-up paper towels.

The Government also requires workers to wash their hands at mid-shift and end of the shift, in addition to washing their hands when arriving and leaving the site. They should also do it before and after lunchtime, at each break and after using the toilet. He also recommends not sharing the tools. If necessary, employers will be required to disinfect the tools and work equipment shared between each use and at the end of the shift.

The presence of toilets on construction sites is mandatory and they must be cleaned twice per shift. When there are 25 or more workers on a site, flush toilets and sinks supplied with clean, temperate water must be made available to workers. For a construction site with fewer than 25 workers, the use of chemical toilets is sufficient.

When a dining room is to be made available to workers, under the Code de sécurité des travaux de la construction [1], employers will have to ensure that the tables, chairs and appliances, as well as accessories, have been cleaned after each use and shift.

Consequences of non-compliance

Failure to comply with the above guidelines could lead to the closure of the construction site until these protective measures are properly implemented. Offending employers could also be fined for non-compliance.

The CNESST is aware of the difficulties facing employers that have to navigate through all these measures and has created a daily verification tool to facilitate the implementation of these guidelines [2].

Finally, the decision to reopen the construction sites will have consequences for other actors in the construction industry since the Ministry of Labor, Employment and Social Solidarity has stressed that they will also have to resume 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] Vous retrouverez la Liste de vérification quotidienne en ligne au https://www.cnesst.gouv.qc.ca/salle-de-presse/Documents/liste-verification-construction-COVID-19.pdf

[3] Pandémie de COVID-19 — Le ministre Jean Boulet confirme l’ajout des chantiers de construction résidentielle à la liste des services et activités prioritaires, en ligne : http://www.fil-information.gouv.qc.ca/Pages/Article.aspx?aiguillage=diffuseurs&listeDiff=349&type=1&idArticle=2804130371.