Law 27: Transforming compliance into a continuous improvement process

Law 27: Transforming compliance into a continuous improvement process

Law 27: Transforming compliance into a continuous improvement process

“I didn’t know who to talk to about it.”

A manager overheard this sentence, her office door barely closed. Since the beginning of summer, an employee has been receiving inappropriate remarks from a colleague.

The harassment policy exists. So does the prevention program. On paper, everything is in place.

Twenty years spent entering workplaces as different as factories, hospitals, schools, and offices have allowed me to observe a gap worth examining (to make this observation):  : The difference between a prevention framework that strictly meets the requirements and a workplace that concretely protects its people appears when practices meet the reality on the ground.

The example of a fire drill illustrates this well. An evacuation plan may exist, responsibilities assigned, and exits identified. The real test, however, comes when the alarm actually sounds.

In workplace mental health, the logic is the same. A situation arises, management must intervene, a team looks for guidance. The natural reflex is sometimes to shift responsibility to one person: “That’s Josée’s responsibility in HR.” That reflex is precisely a signal that something needs to be corrected: occupational health and safety is built on shared roles, not a single point of entry.

The framework exists. When it is time to act, who actually knows what to do?

Compliance establishes responsibilities, mechanisms, and preventive measures—an essential foundation. The challenge then becomes developing the capacity to recognize situations, intervene at the right time, and mobilize appropriate mechanisms when reality puts them to the test.

Psychosocial risks take various forms, such as harassment that builds through accumulation, violence that escalates quickly, or a traumatic event whose effects persist long after it is over.

An organization capable to be in action goes beyond simply setting up mechanisms. It knows how to prevent, intervene, and support, depending on what the situation requires.

Act at the right time

To prevent, means taking action upstream.

It is about paying attention to psychosocial factors such as workload, support, recognition, decision-making autonomy, and organizational justice in order to reduce risks and strengthen what protects people.

It also means taking early warning signs seriously, including rising tension, repeated incivilities, and expressed unease, before the situation escalates further.

To intervene , is to be able to act when a situation arises.

The roles are known, the mechanisms accessible. People know who to turn to, so they can act diligently rather than improvising.

To support, is to pay attention to the people involved, and the consequences of what has been experienced.

Support often extends beyond the end of the event: maintaining a presence, facilitating access to resources, and adapting certain working conditions. This also ensures that someone who previously admitted not knowing who to talk to will know exactly who to contact and what their role is in the future.

These three dimensions are interconnected. What an organization learns through intervention and support informs its future prevention efforts. A strong prevention plan strengthens its capacity to act when a problem arises.

Continuous improvement is based on this ability to learn from experience and adjust prevention over time.

An action plan is not a finish line

To guide action, a structured approach remains essential: identify, analyze, correct, and control.

IIdentify means recognizing the risks and risk factors present in the workplace.

Analyze means understanding and prioritizing the situations observed and their potential effects on people’s health, safety and integrity.

Correct means putting measures in place that are adapted to the reality of the workplace and acting on the conditions at the source of the risks.

Control means verifying whether the measures are applied, whether they remain relevant and whether they produce the desired effects.

Then adjust as work evolves. An action plan, like prevention, remains an ongoing process.

Bringing prevention to life

Let’s get back to our fire drill example.

The evacuation plan displayed on the wall shows what should be done. Its actual effectiveness depends on committed leadership, committed teams, clear roles, a structured approach, and the ability to adjust where necessary.

In mental health at work, an approach comes to life through decisions, management practices and responses to signals emerging from work, going beyond the recognition of risks, into the ability to act concretely.

Compliance provides the framework. Continuous improvement develops the ability to bring it to life.

The best prevention strategies go beyond good intentions. They are successful when employees no longer say “I didn’t know who to talk to” because they will know what to look for, what to do, and how to respond.

Daisy Gauthier is an expert in workplace mental health and occupational health and safety. A specialist in work-related psychosocial risks, her career has taken her from fieldwork to consulting, contributing to the evolution of prevention practices in Quebec. Today, with Désia, she supports workplaces as a speaker, trainer, and strategic advisor.

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Do your surveys give you a false sense of PSR prevention?

Do your surveys give you a false sense of PSR prevention?

Psychosocial risks (PSRs) are being measured more often today, but are far less often prevented at the source.

In many organizations, the reflex is now well established.

The climate is deteriorating.
Tensions rise.
Turnover becomes a concern.
Teams talk more about fatigue or overload.

So, a survey is sent out.

A few weeks later, the results come in, along with the charts. Generally, a certain sense of relief sets in; the organization finally feels that it understands what is happening.

The danger is that organizations sometimes confuse consultation with prevention. Gathering perceptions does not mean understanding what, in the work itself, gives rise to PSRs. 

In occupational health and safety (OHS), a much more uncomfortable question needs to be asked:

Does the survey actually make it possible to identify PSRs, or does it mainly measure consequences that are already established enough to become visible?

In prevention, there is a major difference between:

  • Observing effects such as an increase in distress in certain teams;
    and
  • Understanding the source of what produces them in the work.

This distinction completely changes an organization’s actual ability to prevent PSRs.

What a survey can do and its limits

Let’s be clear: a survey can be useful. It can:

  • Open discussions;
  • Make certain perceptions visible;
  • Document certain concerns;
  • Inform organizational reflection.

Many tools that have not been scientifically validated have significant methodological limitations when it comes to properly identifying PSRs and their psychosocial risk factors (PSRFs).

In many cases:

  • The dimensions assessed are not based on recognized OHS frameworks or on models validated for PSR prevention;
  • The PSRFs influencing PSRs remain poorly documented;
  • The tools do not always allow for a sufficiently reliable interpretation of the realities observed;
  • The results may be influenced by the context, emotions at the time, or certain recent events.

As with any measure based on human perceptions, some biases remain possible. Questionnaires based on validated models nevertheless seek to better control these effects in order to obtain data that are more stable, reliable, and representative of workplace realities.

When an organization wants to measure air quality, noise levels, or exposure to a contaminant, it does not rely on general impressions or improvised tools. It uses recognized methods, reliable tools, and interpretable data.

Since PSRs can also directly affect OHS, identifying them must meet the same level of methodological rigor.

When measuring does not mean preventing

The problem is not asking questions. The problem is believing that a general perception survey can, on its own, identify PSRs within an OHS prevention approach.

PSRs generally do not begin when they show up in a survey; they often take shape gradually:

  • Under certain repeated constraints;
  • In ways of working that become established;
  • In silent build-ups;
  • In overload that has become normal;
  • In a lack of support that persists;
  • In tensions that eventually become tolerated in day-to-day work.

These realities cannot be understood from a point-in-time snapshot.

Why this distinction is becoming essential

Even today, many workplaces reduce PSRs to a survey exercise. As if taking a snapshot of the discomfort was enough, on its own, to understand its causes in the work.

In OHS, simply identifying a risk has never been enough to address it.

With Law 27, organizations are expected to integrate PSRs into a genuine prevention process: identify, analyze, correct, control, and monitor the work-related factors that influence psychological health. These factors include work organization, management practices, employment conditions, as well as social relations at work.

It is not only about gathering perceptions, but about developing an organizational capacity to prevent harm to health, safety, and physical and psychological integrity. This is a genuine paradigm shift in OHS when it comes to PSRs because the gap between these two realities is much greater than it may appear.

Organizations must be able, in particular, to:

  • Identify the factors influencing PSRs;
  • Analyze their organizational realities;
  • Prioritize actions;
  • Implement appropriate prevention and control measures;
  • Monitor how risks evolve over time;
  • Evaluate and adjust their actions as workplace realities evolve.

This shift transforms the very understanding of PSR prevention in OHS:

  • From an approach focused mainly on visible consequences;
    To
  • An approach focused on understanding PSRFs, prevention at the source, and the continuous adjustment of working conditions.

What organizations now need to develop

Many organizations already have surveys, indicators, and internal data.

Organizations now need tools capable of producing reliable, comparable, and interpretable data over time in order to support a more accurate understanding of workplace realities.

Beyond the visible results, the challenge is also to better identify the factors influencing PSRs in order to guide prevention actions in a coherent, structured, and sustainable way.

Two Approaches That Do Not Pursue the Same Objective

Survey

Primarily measures perceptions
Point-in-time snapshot
Questions whose validity varies depending on the tools used
Results difficult to interpret
Primarily observes visible effects
May limit understanding of the factors influencing PSRs

Validated Questionnaire

Seeks to identify the factors influencing PSRs
Tracks change over time
Scientifically recognized dimensions
Reliable and comparable data
Supports risk identification and targeted prevention
Structured OHS prevention process

 

A survey can help inform organizational reflection and form part of a broader prevention process. However, on its own, it does not adequately identify PSRs within a structured OHS prevention approach.

Where the approach really changes how PSRs are understood

Some approaches specifically seek to move beyond the logic of a point-in-time survey by relying on scientifically validated questionnaires integrated into a structured PSR prevention process.

These approaches make it possible to:

  • Identify the factors that truly influence PSRs;
  • Monitor how workplace realities evolve over time;
  • Take a more strategic view of organizational trends;
  • Provide more consistent direction for prevention actions.

This methodology therefore makes it possible to obtain reliable, comparable, and interpretable data over time in order to support more consistent, strategic, and sustainable management of PSRs.

In OHS, the quality of data collection directly influences the quality of the decisions that follow.

The challenge is to stop waiting for the consequences to become observable before taking action on the workplace realities that produce them.

Prevention is most meaningful when it makes it possible to intervene early, collectively, and concretely in order to act sustainably on the factors influencing PSRs.

An important question for organizations

Does your organization rely on a perception survey or on a structured process using scientifically validated questionnaires to identify, analyze, and prevent PSRs?

Content written by Daisy Gauthier, expert and workplace partner in OHS and PSR prevention.

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