Industrial Hygiene

Occupational Noise in Quebec: What the 2023 RROHS Amendments Require From Employers

By the Système Préventis OHS Team | Industrial Hygiene | Occupational Health

Occupational noise-induced hearing loss is silent, irreversible, and entirely preventable. It is also the dominant occupational disease in Quebec, accounting for 86% of all occupational diseases recorded by the Commission des normes, de l'équité, de la santé et de la sécurité du travail (CNESST) in 2021, up from 70% in 2019. Unlike acute injuries, hearing loss develops over years of unprotected exposure. By the time a worker notices it, the damage is permanent. Tinnitus, difficulty understanding speech, and progressive deafness are the predictable outcomes of workplaces that have not controlled noise at the source.

On June 16, 2023, significant amendments to Quebec's Regulation respecting occupational health and safety (RROHS) — sections 130 to 141.5 — came into force, lowering the province's occupational exposure limit (OEL) for noise from 90 dBA to 85 dBA over an eight-hour shift and adopting the stricter 3 dB exchange rate. These changes created new, enforceable occupational noise exposure requirements for every Quebec employer whose workers are exposed to elevated sound levels. CNESST has identified noise as one of the five predominant risks in its 2024–2027 Multi-Year Prevention-Inspection Plan, and inspection activity in high-noise sectors is active. This article explains exactly what the updated RROHS requires, what constitutes compliance, and why the absence of a formally named "hearing conservation program" requirement does not mean employers have no obligations.

Why the 2023 RROHS Noise Amendments Matter for Quebec Employers

Before June 2023, Quebec's noise OEL was 90 dBA for an eight-hour shift — a standard that most of the rest of Canada had already moved away from. The 2023 amendments brought Quebec in line with the more protective 85 dBA standard used by most other provinces and recommended by international occupational health bodies such as the National Institute for Occupational Safety and Health (NIOSH) and the American Conference of Governmental Industrial Hygienists (ACGIH). The change was not merely symbolic: the difference between 90 and 85 dBA represents a threefold reduction in permissible noise dose under the 3 dB exchange rate.

For many Quebec employers — particularly in manufacturing, food processing, printing, mining, and construction — operations that were compliant before June 2023 may now exceed the new threshold. A production floor running at a steady 88 dBA that previously met the 90 dBA standard now exceeds the 85 dBA OEL and triggers a full set of prevention obligations.

📊 Key Numbers: Quebec Noise RROHS 2023

Old OEL (pre-June 2023): 90 dBA over 8 hours
New OEL (from June 16, 2023): 85 dBA over 8 hours (RROHS s. 131)
Exchange rate: 3 dB (meaning: for every 3 dBA increase above 85, maximum exposure time is halved)
Peak sound pressure limit: 140 dBC (instantaneous)
Example: At 88 dBA, maximum unprotected exposure = 4 hours. At 91 dBA = 2 hours. At 94 dBA = 1 hour.
Noise is one of the 5 priority risks in CNESST's 2024–2027 Multi-Year Prevention-Inspection Plan.

What the Quebec RROHS Requires: A Step-by-Step Employer Obligation Framework

Quebec does not use the term "hearing conservation program" in its RROHS. However, sections 130 to 141.5 create a set of obligations that, taken together, amount to a de facto hearing conservation programme that every employer with noisy work situations must implement. The following steps reflect the sequence the RROHS requires.

Step 1 — Identify and Document At-Risk Work Situations (RROHS s. 141.1–2)

The first obligation is identification. Employers must identify all work situations in their establishment that are likely to exceed the noise exposure limit values set out in RROHS section 131. This identification must be completed and documented. The initial assessment was due by June 16, 2024 — one year after the amendments came into force. Reassessment is required every five years, or sooner if work processes, equipment, or layouts change in ways that could affect noise levels.

The assessment must be conducted by a person with training in occupational hygiene or by someone who is proficient in the established methods for assessing workplace noise. Under RROHS section 140, when reasonable means have been implemented and noise levels may still exceed the OEL, the employer must have noise measured by a qualified person. Measurement must follow the methodology set out in the CSA standard Z107.56, Measurement of Noise Exposure. The results must be documented and retained for a minimum of 10 years (RROHS s. 141.5).

Step 2 — Apply the Hierarchy of Controls (RROHS ss. 133–136)

The RROHS is explicit that hearing protectors are a last resort, not the first line of defence. Section 133 requires employers to prioritize elimination or reduction of noise at the source through engineering and technical means. The hierarchy is:

Elimination or substitution: Replace noisy machinery or equipment with quieter alternatives. Include acoustic performance criteria in procurement specifications for new equipment.
Engineering controls at source: Enclose noisy machines, add acoustic barriers, vibration-damping mounts, silencers on air exhausts. Maintain equipment regularly to prevent noise-generating wear.
Engineering controls on propagation: Soundproof rooms or designated high-noise areas. Erect sound-absorbing barriers between noise sources and workers.
Administrative controls: Rotate workers between noisy and quiet tasks to reduce individual dose. Limit time spent in high-noise areas. Move workstations away from noise sources where feasible.
Hearing protectors (last resort): Provided free of charge to workers when exposure exceeds the OEL and only after other means have been applied. Also provided during the implementation period while other controls are being put in place, and during maintenance of noisy machinery.

Under RROHS section 135, when initial control measures are insufficient to achieve compliance, employers must implement additional reasonable means before the next five-year assessment cycle begins. The obligation is not met simply by documenting that the OEL is being exceeded.

Step 3 — Provide Compliant Hearing Protectors (RROHS s. 141.1; CSA Z94.2)

When noise exposure exceeds 85 dBA and hearing protectors are required, they must be provided free of charge and must meet the performance and selection requirements of CSA Z94.2, Hearing Protection Devices — Performance, Selection, Care and Use. Under RROHS section 141.1, the protectors provided must attenuate noise so that the worker is not exposed to values exceeding 85 dBA.

The target attenuation level under CNESST guidance is between 75 and 80 dBA after protection. Levels of 80–85 dBA (protected) and 70–75 dBA (protected) are also considered acceptable. Over-protection — reducing noise below 70 dBA — is not recommended, as it can isolate workers from audible warning signals. Employers must ensure that the noise reduction rating (NRR) or Sound Level Conversion (SLC80) of the selected protector is matched to the specific noise level at each workstation.

Step 4 — Deliver Mandatory Training (RROHS s. 141.3)

When the 85 dBA threshold is exceeded, employers must provide workers with both theoretical and practical training on:

The harmful effects of noise exposure and the risks of noise-induced hearing loss
How to correctly select hearing protectors appropriate to the noise level and work task
How to correctly fit, inspect, maintain, and store hearing protectors
The employer's noise prevention obligations and the worker's right to protection

Theoretical training alone does not satisfy this requirement. Workers must receive hands-on, practical instruction on fitting their specific hearing protectors. Training records must be maintained and available for CNESST inspection.

Step 5 — Post Required Signage (RROHS s. 141.4)

Employers must post hearing protection required signs at the entry to any work area where noise levels exceed the 85 dBA OEL. This is a specific, enforceable obligation — not a recommendation. The signage requirement applies to work zones, not just individual workstations, and must accurately reflect the current noise profile of the area.

Step 6 — Maintain Documentation (RROHS s. 141.5)

RROHS section 141.5 requires employers to maintain and keep current the following records in their prevention programme or, failing that, in a register:

Work situations identified as at risk of exceeding noise exposure limits, with the date of identification
Reasonable measures implemented to reduce noise, with start and end dates for each measure
Noise measurement reports, including the methodology used and the qualifications of the person who conducted the measurement

All of these records must be retained for a minimum of 10 years and made available to the parties concerned, including the CNESST and the establishment's occupational health physician. This documentation is the employer's primary evidence of compliance and due diligence in any CNESST inspection or enforcement proceeding.

Audiometric Testing: What Quebec Employers Are and Are Not Required to Do

One of the most common points of confusion about Quebec's noise obligations is audiometric testing. Quebec's RROHS does not mandate audiometric testing the way some other provinces do — it is not an explicit, stand-alone obligation in the same way that it is in Alberta or British Columbia. However, the broader framework creates strong due diligence reasons to implement audiometric testing, and several pathways under which it effectively becomes necessary.

First, under Quebec's Bill 59 (LMRSST) and the updated Bill 59 regime's prevention programme requirements (in force since October 2025), employers' prevention programmes must identify and address all health risks to workers, including noise-induced hearing loss. Audiometric testing is the only reliable means of detecting whether noise controls are actually preventing hearing loss in individual workers. Second, where the CNESST or an occupational health physician has reason to believe a worker has been affected by occupational noise, testing can be ordered. Third, many employers' collective agreements and industry standards require it as a baseline health surveillance measure.

ℹ Audiometric Testing: Best Practice Framework (CSA Z107.6 / Z1007)

Baseline test: Conducted within 6 months of a worker first being exposed to noise above 85 dBA Lex. Establishes the individual's hearing threshold before exposure begins or progresses.
Follow-up tests: Conducted at regular intervals (at least every 2 years for workers with stable exposure; annually for higher exposures). Compared against the baseline to detect threshold shift.
Standard: CSA Z107.6, Audiometric Testing for Use in Hearing Loss Prevention Programs, specifies equipment, facility, and technician requirements.
If a Standard Threshold Shift (STS) is detected, the employer must review noise controls, reassess the worker's exposure, and refer the worker to an occupational health professional.
Records: Audiometric records are medical records and must be handled with confidentiality. Retained for the duration of employment plus a minimum period per provincial requirements.
Note: Testing does not replace engineering controls. It is a monitoring tool to verify that controls are effective.

What CNESST Inspectors Look For in Noise-Related Inspections

CNESST has designated noise as a priority inspection risk in its 2024–2027 Multi-Year Prevention-Inspection Plan. Inspectors visiting high-noise workplaces will typically assess the following. Understanding this list is also the fastest way to audit your own programme's gaps.

Noise identification records: Has the employer identified and documented work situations likely to exceed 85 dBA? Is the identification current (within the last 5 years)?
Measurement reports: Has noise been measured by a qualified person? Do measurement reports exist and are they retained? Are measurement methods consistent with CSA Z107.56?
Control measures implemented: Has the employer moved through the hierarchy of controls? Are engineering controls documented? If hearing protectors are the primary control, can the employer demonstrate that other means were considered and implemented where feasible?
Hearing protector compliance: Are protectors provided free of charge? Do they meet CSA Z94.2? Is the selection matched to the actual noise level at each workstation? Do protectors achieve the 85 dBA (or lower) protected exposure target?
Training records: Has both theoretical and practical training been provided? Are training records dated and retained? Have workers been retrained when equipment changed or new workers were assigned to noisy areas?
Signage: Are hearing protection required signs posted at every entry point to areas exceeding 85 dBA?
Documentation in prevention programme: Is the noise risk and the measures taken documented in the establishment's prevention programme or register? Are records retained for at least 10 years?

How Système Préventis Supports Occupational Noise Compliance

Meeting Quebec's occupational noise exposure requirements is not a one-time event. It is an ongoing programme of identification, measurement, control implementation, training, health surveillance, and documentation that must be maintained and renewed on a five-year cycle. Système Préventis provides an integrated occupational health and safety platform that brings the occupational health and prevention programme components of noise compliance into a single, audit-ready system.

Occupational Health Module: Audiometric Testing and Exposure Records

The Système Préventis occupational health management module stores audiometric testing records linked to individual worker profiles. Baseline and follow-up test results are tracked over time, enabling comparison of hearing thresholds across testing cycles and early identification of workers experiencing standard threshold shifts. Exposure history is maintained alongside health records, creating the documented link between noise exposure and health surveillance that any serious hearing loss prevention programme requires. These records are retained with the confidentiality and access controls appropriate for medical data.

Prevention Programme Module: Noise Risk Documentation

Under RROHS section 141.5, noise risk documentation must be maintained in the prevention programme or a dedicated register. The Système Préventis prevention programme module stores identified at-risk work situations, links them to noise measurement reports, documents the control measures implemented with start and end dates, and maintains version history showing how the programme has evolved across assessment cycles. This is exactly the documentation trail that CNESST inspectors request when auditing noise compliance.

Training Management: Theoretical and Practical Training Records

The training management module schedules, records, and tracks completion of both the theoretical and practical noise and hearing protection training required under RROHS section 141.3. Training is linked to specific work areas and noise exposure levels, ensuring that workers assigned to areas exceeding the OEL have current, documented training on their specific hearing protectors. Expiry tracking and automated retraining alerts prevent the silent compliance gaps that arise when workers transfer between departments or when equipment changes alter noise profiles.

Industrial Hygiene Integration

For organizations with an industrial hygiene programme, Système Préventis's industrial hygiene module connects noise measurement data from qualified hygienist assessments directly to the prevention programme record. Measurement reports, instrument calibration logs, and assessor qualifications are stored and accessible for CNESST inspection. This integration supports the five-year assessment cycle required under the RROHS and ensures that measurement records are never separated from the prevention measures they inform. The complete documentation chain — exposure identification, measurement, controls, training, health surveillance — directly supports the employer's due diligence position under the Loi sur la santé et la sécurité du travail (LSST).

Quebec's 2023 RROHS noise amendments created a set of enforceable obligations — noise identification and documentation, a hierarchy of controls applied in sequence, compliant hearing protectors provided free of charge, mandatory theoretical and practical training, posted signage in all areas exceeding 85 dBA, and 10-year retention of records — that amount to a full hearing conservation programme even though Quebec's RROHS does not use that term. With noise ranked as one of the CNESST's five priority inspection risks, and hearing disorders representing 86% of occupational diseases in the province, employers in high-noise sectors who have not yet assessed their exposure situations, implemented controls, and documented their programme are at significant enforcement risk. Système Préventis provides the occupational health, prevention programme, and training management tools to build and maintain that programme — and to demonstrate it to CNESST inspectors when they arrive.

Frequently Asked Questions

What is the occupational noise exposure limit in Quebec as of 2023?

As of June 16, 2023, Quebec's occupational exposure limit (OEL) for noise is 85 dBA over an eight-hour shift, with a 3 dB exchange rate. This means that for every 3 dBA increase above 85, the maximum permissible unprotected exposure time is halved. The peak sound pressure limit is 140 dBC. This replaced the previous OEL of 90 dBA, bringing Quebec in line with most other Canadian provinces and international best practice standards.

Does Quebec require a formal hearing conservation program under the RROHS?

Quebec's RROHS does not use the term "hearing conservation program." However, sections 130 to 141.5, as amended in 2023, impose a set of obligations — noise identification and documentation, hierarchy of controls, free hearing protectors meeting CSA Z94.2, mandatory theoretical and practical training, signage in areas exceeding 85 dBA, and 10-year record retention — that collectively constitute the functional equivalent of a formal hearing conservation programme. Compliance requires implementing all of these elements, not just providing hearing protectors.

How often must noise levels be assessed under Quebec's RROHS?

Under RROHS section 141.1, employers must identify at-risk work situations and repeat the assessment every five years. The initial assessment following the June 2023 amendments was due by June 16, 2024. Reassessment must also occur before the five-year cycle ends if work processes, equipment, or facility layouts change in ways that could materially affect noise levels. Noise measurement, where required, must be conducted by a qualified person using the methodology of CSA Z107.56. All assessment records must be retained for at least 10 years.

What hearing protectors must employers provide under Quebec's noise regulations?

Employers must provide hearing protectors free of charge whenever workers are exposed to noise exceeding 85 dBA. The protectors must meet the requirements of CSA Z94.2 and must attenuate noise so that the worker's protected exposure does not exceed 85 dBA. CNESST guidance targets a protected exposure level of 75–80 dBA. Over-protection below 70 dBA is not recommended, as it may prevent workers from hearing warning signals. Employers must also provide protectors during the period required to implement other noise reduction measures and during maintenance of noisy equipment.

Is audiometric testing required for noise-exposed workers in Quebec?

Quebec's RROHS does not contain an explicit, stand-alone requirement for audiometric testing equivalent to those in Alberta or British Columbia. However, audiometric testing is strongly supported by Quebec's broader occupational health framework, particularly under the Bill 59 prevention programme obligations requiring health risk management, and it is the only means of determining whether noise controls are preventing hearing damage in individual workers. CNESST can order testing where it has reason to believe a worker may be affected by occupational noise. CSA standards Z107.6 and Z1007 provide the specifications and programme management framework for audiometric testing in Canadian workplaces.

Sources

Système Préventis | A QuadShift Company | May 2026

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