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February, 2 p.m., boardroom of a metal parts plant in the Montérégie region. The director of operations sets down his coffee and scans the agenda: Line B output, revised delivery schedule, call with the lawyer. That last item wasn’t there eighteen months earlier, when he had signed the renewal contract for the employee assistance program and told himself the psychological health file was taken care of. He didn’t yet know that a CNESST (Quebec’s workplace health and safety commission) claim, a union grievance, and a long-term absence were about to pile up on the same shop floor, or that the total bill would exceed $121,000.
What the bill contains that nobody budgeted for
An EAP covers psychotherapy sessions. What it doesn’t cover is the salary of an employee off work for twenty-two weeks, or that of the temp worker hastily trained to replace him on a CNC press. The Commission des normes, de l’équité, de la santé et de la sécurité du travail puts the average cost of an accepted psychological injury at more than $55,000 in direct compensation — a figure published in its annual statistical reports. But compensation is only the visible part.
Legal fees tied to the union grievance filed at the same time came to roughly $18,000 in preliminary arbitration costs for this plant alone, before any hearing on the merits. The productivity loss on the affected line — measurable slowdowns, handling errors, increased supervision — was estimated internally at the equivalent of three weeks of normal output. None of those line items appear in the EAP provider’s annual report. They show up in the financial statements, buried in overhead, with no visible link to the decision made eighteen months earlier to go no further than offering access to a listening service.
Quebec’s Law 27 (workplace psychosocial risks) — more precisely, the amendments to the Act respecting occupational health and safety in force since 2023 — requires employers to identify psychosocial risk factors at the source and to eliminate or control them. An employee assistance program does neither. It receives people after the damage is done. Using an EAP to meet a prevention obligation is like treating a roof leak with towels: the service itself is real, but the structural problem remains untouched.
What should have been in place before anything happened
A psychosocial risk prevention approach that meets Law 27 rests on a few concrete elements: an assessment of the risk factors specific to the organisation — quantitative overload, low decision-making latitude, lack of social support from the immediate supervisor, role ambiguity — an action plan with measurable steps, and a way to demonstrate that those steps were carried out. This is not an annual satisfaction survey slipped into an HR newsletter. It is a reading of the work as it is actually done, not as it is supposed to be done.
The objection you often hear at this point is a fair one: a 120-person SME doesn’t have the internal resources of a large corporation, and asking an already stretched OHS coordinator to also lead a psychosocial program can feel like an unfunded mandate. That’s true. It’s also why the law doesn’t require an entire department — just a proportionate, documented process, revisited at reasonable intervals. A risk assessment done once, with a follow-through action plan, costs a fraction of the $121,000 described above — and it can be presented to the CNESST as evidence that the obligation has been met.
What changes in practice for a director of operations or an OHS coordinator is having a document you can show: the factors identified, the areas targeted, the measures chosen, the dates. Not a report gathering dust in a filing cabinet, but an artefact that proves you looked, you acted, and you can do it again. Psychosocial prevention doesn’t make organisations immune to every incident, but it fundamentally changes what an employer can say when the CNESST comes knocking or when an arbitrator asks the question.
CSS Consult supports Quebec SMEs through this kind of assessment and action planning — the kind of process that produces verifiable evidence, not brochures. The one thing worth carrying away from this article is this: if you cannot show how you identified psychosocial risks within your teams, you cannot prove you prevented them. And in an arbitration room or in front of an inspector, good intentions don’t count — the document does. So here is the question worth asking before the next management meeting: if the CNESST knocked on your door tomorrow morning, what would you pull out of the filing cabinet?
What gets measured gets prevented. What gets proven remains.