The right questions.Open answers.

Because some activities that directly affect building fire safety are currently carried out without uniform professional oversight.

The objective is to ensure that people who inspect, test, assess or attest to certain essential fire-safety elements are competent, accountable and subject to clear professional obligations.

The Ordre des praticiens en sécurité incendie du Québec (OPSI) would have one mission above all: protection of the public.

No. A professional order is neither a trade association, an employers’ group nor an organization intended to defend the economic interests of its members.

On the contrary, membership in an order imposes obligations: competence, ethics, continuing education, professional inspection, discipline and personal accountability.

Under the proposed model, “non-compliance under documented action” and “non-compliance requiring action” apply at the same serious-risk threshold and both are subject to mandatory registry filing. A non-compliance under documented action has credible and documented handling during its correction period; if that handling ceases, becomes insufficient or correction is not verified by the deadline, it becomes a non-compliance requiring action. A non-compliance requiring action is immediately visible to the competent authority.

The code of ethics would expressly prohibit using these statuses to exert commercial pressure, obtain corrective work or increase remuneration.

The Order would exist to protect the public, including from misconduct by its own members.

The current framework relies on several mechanisms that do not all serve the same purpose: rules applying to buildings and equipment, responsibilities of public authorities, qualification requirements, employer oversight and, in some fields, obligations that already fall under a professional order.

For the activities covered by the proposal, oversight is therefore fragmented. It does not necessarily form a single cross-cutting mechanism that provides, for all of these activities, the full set of controls over competence, ethics and the individual accountability of the person performing them.

The initiative must now document precisely what each existing mechanism already covers, where those mechanisms complement one another and where individual professional accountability could or could not add relevant protection.

The objective is not to diminish existing mechanisms, but to assess whether they collectively address the risks that will be documented and, if not, what additional measure would be proportionate.

Because an owner, building manager or member of the public generally does not have the knowledge needed to determine whether a technical inspection was properly performed.

A report may look perfectly professional while containing a significant error, omission or misinterpretation.

Fire safety has a particular characteristic: an error can remain invisible for months or years and be discovered only at the precise moment the system must protect lives.

At that point, it may be too late to repeat the inspection.

That is theoretically possible.

But it would require building almost from scratch a system for admission, competence control, ethics, inspection, discipline and oversight.

Québec already has, through the Professional Code and the Office des professions du Québec, an architecture specifically designed to regulate persons whose professional practice may present risks to the public.

The question is therefore simple: why rebuild a parallel regime if Québec’s professional system is already the instrument designed to perform that function?

Because the age of a situation does not prove that it is the best model for protecting the public.

For a long time, the sector has been able to evolve with much of its control resting on employers, individual experience, technical standards and the good faith of the people working in it.

But that does not answer a fundamental question:

If we were designing today, from scratch, the oversight of activities that can directly affect the protection of building occupants, would we really choose to allow them to be carried out without a professional permit, without a general continuing-education requirement, without professional inspection and without genuine continuity in discipline?

The OPSI project starts from the principle that the answer should be no.

When a professional signs a report, performs an important inspection, carries out a test or produces an attestation within the professional’s competence, the public would know that behind that signature is an identifiable and accountable person.

That person would be subject to admission requirements, a code of ethics, continuing education, professional inspection and a disciplinary regime.

The person’s competence would have to be maintained throughout their career.

If the person changed employers or became self-employed, the professional obligations would continue to follow them.

And where a non-compliance reaches a serious-risk threshold, follow-up would take its actual handling into account: status “non-compliance under documented action” while it is being addressed immediately and seriously within the applicable period; status “non-compliance requiring action” if it is not, if that handling ceases, or if the period expires without verified correction. A second authorized person could verify correction or change the status.

OPSI would therefore add a permanent network of competent, trained, traceable and accountable professionals to Québec’s fire-safety net.

Because when a person exercises professional judgment and an error can contribute to putting lives at risk, the public should be able to rely on more than a business card and the good faith of the person handing it over.

The project primarily targets fire-safety activities that are not already reserved exclusively to another professional order or equivalently regulated through a qualification regime of the Régie du bâtiment du Québec, and that can currently be carried out without genuine personal professional accountability.

In other words, OPSI is not seeking to take over acts already reserved to other professionals or to replace the RBQ. It seeks to intervene where a regulatory gap remains.

This would include certain periodic inspections and tests of fire protection systems, certain activities related to fire safety plans, certain attestations, and the professional classification, verification and follow-up of reporting-exempt non-compliances, non-compliances under documented action and non-compliances requiring action.

The principle is deliberately targeted: regulate acts that can currently be carried out by a person without genuine professional oversight even though poor performance may directly affect public safety.

The proposal preserves other professions’ existing rights and expressly grants engineers and professional technologists the same OPSI authorizations as PSI members under section 9, when they have the necessary competence. The proposed Act itself would confer this authorization.

Within this scope, the three professions could perform the same acts and would have the same OPSI duties of competence, independence, signature, reporting, disclosure, filing and accountability. This includes inspections and tests, approval of fire safety and evacuation documents, exercise evaluations, professional attestations and non-compliance notices.

Engineers and professional technologists would not have to join OPSI. Their own order would continue to govern their permit, ethics, insurance and discipline, and individual restrictions would still apply. No professional title substitutes for the actual competence needed for the intervention.

The authorization would confer no act the OPSI Act does not authorize a PSI to perform and no general permission for engineering design, sizing, construction supervision or regulated construction work. Distinct engineering acts and trade qualifications would remain governed by their own legislation.

Because the proximity of certain activities is not enough to make two professions one and the same profession.

Fire-safety professionals come from very diverse backgrounds: skilled trades, technical education, apprenticeship, practical experience and training specific to fire-safety systems, codes and standards.

Their body of knowledge, day-to-day practice and professional pathways do not naturally correspond to those of engineers or professional technologists.

Integration would likely require the existing order to create a special regime for admission, recognition of experience, continuing education and professional inspection for this new population.

The question is therefore not whether these professions can work together — they already do — but whether they truly constitute the same profession.

For OPSI, they are distinct and complementary. Integration into an existing order would therefore be considered only exceptionally and as a last resort if creating a distinct order proved genuinely impracticable despite a demonstrated need for oversight and if comparable public protection could be achieved.

Because an overlap in activities does not mean that one profession must necessarily be absorbed into another.

The history of midwifery provides a useful analogy. Physicians could already monitor pregnancies and deliver babies. That did not prevent Québec from recognizing midwives as an autonomous profession with its own field of practice, competencies and professional order.

The fact that two professions may carry out some similar acts therefore does not mean they constitute a single profession.

The same logic may apply to fire safety.

Overlap justifies clearly defining boundaries and interfaces between professions; it does not necessarily require their merger.

Because the RBQ and a professional order do not perform the same function.

The RBQ regulates, among other things, buildings, installations, contractors and certain work.

A professional order regulates the person exercising professional judgment: admission, competence, ethics, continuing education, inspection of practice and discipline.

These two forms of oversight are therefore complementary.

OPSI would not replace the RBQ, just as the RBQ does not currently perform all the functions of a professional order.

The Order would primarily regulate individual members. It could also set proportionate conditions for its members practising through an eligible firm or professional corporation, without becoming a general contractor licensing authority.

A company could employ several fire-safety professionals, but each would remain personally responsible for their own professional acts.

A business licence and a professional permit do not serve the same function.

The company answers for its obligations as a company; the professional answers personally for professional judgment and conduct.

Section 73 would preserve a permanent grandfathered right for eligible existing businesses, with an employed PSI responsible for professional oversight. The single right would follow the business on transfer and could not be multiplied or split. Professional duties, insurance and independence would remain mandatory.

No more than other professional orders that regulate certain reserved activities.

The objective is not to protect a group from competition, but to ensure that certain acts presenting a risk to the public are performed by competent and accountable persons.

The framework could foster competition by allowing more professionals to practise independently and by facilitating the development of specialized practices or micro-practices in certain areas of fire safety. This is not guaranteed, but it is a common situation in professional fields operating in the private sector.

Reserved activities will need to be defined according to risk, while respecting rights already recognized to other professions and trades.

Anyone who meets the admission requirements will be able to enter the profession.

No. The scope of a periodic inspection or test would be determined by the legally applicable requirement for the case concerned, including any direct or indirect reference to a code, standard or other technical document.

Every element that the requirement requires to be verified — presence, condition, accessibility, operation, activation, supervision, monitoring, signalling, transmission, interconnection or another specified element — would form part of the mandate. If it does not meet the applicable requirement, the finding would be a non-compliance and would be treated according to its classification.

Conversely, if the professional incidentally notices a condition that was not part of the required verification, it could be recorded as an “apparent anomaly” where it appears capable of affecting a fire-safety function or of warranting further verification.

An apparent anomaly would not, by itself, be a definitive conclusion of non-compliance. The professional could recommend verification by a legally authorized person, but would not be required to turn every periodic inspection into a design audit, recalculate the system, investigate grandfathered conditions or reconstruct the building’s history.

For example, a defective low-pressure device whose operation was required to be tested would be a non-compliance. The apparent absence of a device or sprinkler whose presence was not part of the required verification could instead be reported as an apparent anomaly.

The principle is simple: what had to be verified falls under the non-compliance regime; what is observed outside that scope may be reported as an apparent anomaly.

This Act concerns the Order, professional duties and the registry’s recordkeeping; it does not reorganize the general responsibilities of municipalities, the RBQ or other authorities. Existing responsibilities remain: sections 16 and 25 of the Fire Safety Act provide for implementation plans and the binding effect of the fire safety cover plan on the authorities concerned; OPSI sees the registry as an additional tool for carrying them out.

The proposal creates no additional general duty to notify the owner after an incidental discovery. An insurer seeking a surcharge specifically attributable to that notice must, however, contact the insured and allow three complete days of grace under section 48; professional communications within a mandate and emergency duties remain applicable.

A challenge to reportability on unchanged facts follows section 31. A competent authority that owns, manages or operates the building withdraws from this decision in favour of the RBQ. An unidentified authority or its refusal to decide also leads to the RBQ. If the RBQ refuses or is itself in that institutional conflict, the Minister responsible for the administration of the Fire Safety Act must decide. The person deciding must not have participated in managing the building or in the disputed assessment. The registry retains the facts and gives effect to the decision without imposing a decision timetable.

Yes, within a legally eligible organization and subject to each profession’s own rules. Engineers remain under OIQ, professional technologists under OTPQ and advocates under the Barreau. OPSI oversees its own members; file-sharing remains limited by each person’s authority, confidentiality and privilege.

The proposal preserves other professions’ existing rights and expressly grants engineers and professional technologists the same OPSI authorizations as PSI members under section 9, when they have the necessary competence. The proposed Act itself would confer this authorization.

Within this scope, the three professions could perform the same acts and would have the same OPSI duties of competence, independence, signature, reporting, disclosure, filing and accountability. This includes inspections and tests, approval of fire safety and evacuation documents, exercise evaluations, professional attestations and non-compliance notices.

Engineers and professional technologists would not have to join OPSI. Their own order would continue to govern their permit, ethics, insurance and discipline, and individual restrictions would still apply. No professional title substitutes for the actual competence needed for the intervention.

The authorization would confer no act the OPSI Act does not authorize a PSI to perform and no general permission for engineering design, sizing, construction supervision or regulated construction work. Distinct engineering acts and trade qualifications would remain governed by their own legislation.

The proposal recognizes that the profession exists before the Order and that the people who perform the targeted activities come from different backgrounds.

At implementation, relevant diplomas in fire prevention and fire safety, the DVS 5312 in Fire Protection Mechanics and the professional qualification for trade 416 would notably constitute recognized pathways toward admission. The trade 416 qualification could be recognized even where the person does not hold the DVS.

Experience, certifications and other relevant education or training could also be recognized.

For fire-alarm technicians, the CFAA-accredited training pathway currently offered by Cégep du Vieux Montréal could notably constitute a recognized pathway. DVS 5296 — Installation and Maintenance of Security Systems — and relevant CCQ qualifications are also existing pathways to consider.

Over the longer term, OPSI wishes to support the creation of a training program specifically designed for the profession and intended to become the normal admission pathway for future generations.

Professional admission may begin once the Order is constituted; it does not depend on platform activation. The minimum 24-month period concerns only the documentary registry and does not cap training pathways.

No.

A single permit would not mean that every member is competent for every system. It instead avoids creating a multitude of sub-permits whose boundaries would be difficult to draw and maintain.

A professional may, for example, be highly competent in preaction systems—at the interface between water-based suppression and detection, releasing and alarm functions—without possessing the competence required for fire-water basins, tanks or fire pumps. Another may specialize in smoke and other combustion-product detectors without having the same detailed command of every auxiliary function triggered by the system.

Creating a permit for every system, subsystem and combination would quickly produce an excessively complex taxonomy. OPSI therefore favours an approach comparable to engineering: one common permit identifies the profession, while competence remains mandate-specific and under the member’s personal responsibility.

This approach also fits with the professional roll already required under Québec’s professional system. Under the framework of the Professional Code, the Regulation respecting the roll of professional orders requires the roll to state, for each member, the sector of practice in which the member principally practises; that sector may be an activity sector, a practice area, or a combination of the two. A single permit would therefore not prevent the member’s principal area of practice from being identified: the permit establishes membership in the profession, while the roll makes the member’s principal practice sector visible. That entry would not, however, constitute a sub-permit or an exhaustive certification of all of the member’s competencies.

Each member would therefore have a duty to decline, limit or obtain appropriate support for a mandate when they do not personally possess the necessary knowledge, experience and competence. The comparison with engineering concerns the permit-and-competence model only and grants no act reserved to engineers.

Because professional competence is not acquired once and for all.

Codes, standards, technologies, products and work methods evolve. A person who had all the necessary knowledge at the beginning of a career should not be able to assume that it will automatically remain sufficient twenty or thirty years later.

OPSI would therefore make it possible to establish continuing-education requirements adapted to practice.

The question would no longer be only “Was the person competent when they started?” but also “Are they still competent today?”

As a general rule, professional oversight would follow the activity, not the employer or diploma. A person performing an activity reserved under section 7 would need OPSI membership, subject to express authorizations and exceptions, whether working for a business, municipality, fire service or independently.

Section 9 would directly authorize competent engineers and professional technologists to perform the same OPSI acts as PSI members, with the same applicable rights and duties, without additional OPSI membership. Other statutory authorizations would remain respected.

A reserved professional act must also be distinguished from the exercise of a public authority. Under section 12(1), the proposal neither grants nor removes the powers of competent authorities. A municipal inspector applying a by-law or requiring corrective action in the exercise of that authority would therefore not become a member for that reason alone.

Conversely, if that same person personally performs a periodic inspection reserved under section 8 and signs the professional report, the activity — not the employer — determines professional oversight, subject to authorizations recognized by law.

Yes. During the initial admission regime, a person may be admitted as a transitional member holding the single permit, entered on the roll and subject to limited professional activities. The member may practise independently and sign only expressly authorized acts within their competencies.

The status may be maintained or renewed after reassessment, without an automatic maximum duration. Progression to regular membership depends on demonstrated competencies rather than the mere passage of months or years.

The Order may refuse progression through a reasoned decision while maintaining limited activities where the conditions remain satisfied, subject to applicable remedies. It may also restrict, suspend, decline to renew or withdraw the status in accordance with the law.

The transitional member remains subject to the Professional Code, professional ethics, the syndic, discipline, professional inspection and insurance. The status does not automatically authorize reserved plan approvals or professional attestations.

The minimum 24-month period concerns the full registry, not a maximum duration for admission, training or transitional professional status.

When a reliable official correction shows that a practice limitation applied on the actual date of an act or its signature, the registry identifies potentially affected reports and reassesses their recognition against the rights then in force. The previous information and the source of the correction are preserved.

There is no automatic blanket invalidation: provisional or disputed data are verified first, and the decisions and any necessary notifications are recorded. A suspension that takes effect after a lawfully performed act does not retroactively invalidate it.

They can and should exercise quality control within their organization. But that control has an important limit: it essentially ends with the employment relationship.

An employer may find that an employee performs poorly, train the employee, discipline the employee or dismiss the employee. But if that person changes companies, there is no guarantee that information about professional deficiencies will follow them.

The person may even decide to become self-employed.

A professional order, by contrast, creates continuity in professional accountability. The professional remains subject to the same obligations, inspection mechanism and disciplinary regime regardless of employer.

A company can oversee its staff. The Order oversees the individual’s professional practice throughout the person’s career.

The professional would have obligations that belong personally to them.

This independence does not abolish the reporting relationship. An employer or supervisor may give administrative or organizational directions, supervise the work, request checks or rework, and request a professional review.

If the supervisor is also legally authorized and competent to do so, they may also perform that review, express a different professional conclusion and personally assume responsibility for it.

Each member nevertheless remains personally responsible for the professional acts, opinions and conclusions they make or endorse.

A supervisor therefore may not require a member to sign, authenticate or present as their own a professional conclusion with which the member disagrees.

Independence protects the member’s professional judgment; it does not prevent supervision, quality control or organization of the work.

Review by a supervisor does not override registry conditions. A person may not sign, authenticate, approve or file a professional registry document for a building they own in whole or in part or effectively control. This condition applies to every signatory and filer, whether an OPSI member or not, including for a report, PDSI or professional notice confirming action or correction. Consent does not permit an exception. This is a signature and filing condition under sections 3 and 4 of the registry regulation, with no new OPSI disciplinary jurisdiction over members of another order. Employment alone does not constitute effective control. Each profession’s own ethical duties continue to apply.

A professional governed by another order remains subject to that order’s oversight and discipline. OPSI does not become that person’s disciplinary authority. The proposal already establishes an administrative filing duty and provides for information to be sent to the competent order where professional misconduct is suspected.

An interprofessional harmonization provision is now proposed as a principle so that an unjustified filing failure may be addressed under the order’s disciplinary regime. This wording requires legislative counsel review and adaptation; it does not, on its own, purport to alter another order’s disciplinary jurisdiction.

No. Whether employed by a school service centre, a municipality, a healthcare institution or any other public or private employer, a fire safety practitioner (PSI) has no professional duty to defend the employer’s institutional, financial or reputational interests. When performing professional acts, the professional must give priority to public protection, objectivity and independent judgment.

The PSI continues to owe ordinary employee duties, including loyalty and confidentiality, within the limits of the law. Those duties never authorize changing, minimizing, concealing or delaying a professional finding or conclusion to protect the employer.

The employer retains legitimate powers to organize, supervise and review work and may request further checks or professional review, but cannot dictate a professional conclusion that the PSI does not share. This distinction is based on sections 1, 3, 26, 33 of the proposed Code of Ethics and section 3 of the registry regulation.

Employment alone does not prohibit a PSI from inspecting an employer’s building. A person may not sign, authenticate, approve or file a professional registry document for a building they own in whole or in part or effectively control. This condition applies to every signatory and filer, whether an OPSI member or not, including for a report, PDSI or professional notice confirming action or correction. Consent does not permit an exception. The owner may prepare documents materially and communicate facts; a factual danger report requiring verification remains possible and free. Professional documents intended for the registry must be signed or approved by another legally authorized person and filed by an eligible person. Owners therefore cannot themselves approve their own PDSI for the registry.

No. The registry keeps filed documents, while a separate professional record also contains relevant observations, photographs, tests, notes and supporting reasons. One file preserved by the self-employed professional or an eligible organization is enough. The professional record retention period remains to be set by regulation.

No. Where the employer properly keeps records and lets the FSP enter professional acts and lawfully access needed material, a duplicate personal archive is not required. The FSP remains accountable for reports they sign.

An eligible firm may create and keep shared records using compliant filing, security, access and continuity arrangements. Each FSP remains personally accountable for acts they perform or approve. Neither the Barreau nor the OPSI automatically becomes custodian of those records.

Yes. A compliant business system or storage provider may preserve digital records with confidentiality, controlled access, recoverable backups and transfer capability. Any fire safety plan legally required to remain on paper at a building is a separate duty.

No. The proposal calls for reasonably secure, recoverable preservation, not a notarial repository, vault or general printing of files. Separate building-specific physical-document duties remain unchanged.

A self-employed FSP would designate an eligible successor who accepts in writing. Upon death, incapacity or retirement, that successor preserves records and lawful access through a secure handover. A fallback mechanism applies if the successor is unavailable.

An organization keeping records must have a continuity plan and an eligible successor or interim custodian. It arranges an inventory, required notices and a protected transfer. Employees need not create a separate personal archive where that arrangement is compliant.

An eligible person or organization that accepts custody and can protect and retrieve records, under conditions to be specified by regulation. Custody is transferred, not mandates or professional authorizations. If none is available, OPSI acts only as a fallback within its statutory powers.

No. The successor protects records and provides lawful access, without re-signing reports or assuming the original authors’ responsibility. An unfinished mandate requires a new lawful acceptance consistent with the client’s choice.

Yes, to the extent needed to answer a complaint, claim, investigation or inspection and subject to confidentiality. This limited access to the employer-held record is separate from “My reports” in the registry; it does not allow unrestricted copying of business files or other clients’ information.

Yes, but by agreement with the client. If the client changes the scope, objectives or terms of performance, section 23 permits a fair and reasonable agreed adjustment. It creates no right to a unilateral increase.

Fees remain proportionate to the services provided. The reference to section 19 preserves information duties regarding scope, cost and schedule. This commercial adjustment does not change statutory registry fees or free disclosure.

No. Section 65 retains the transfer rules and also provides for collaboration during joint or interdependent mandates.

The PSI acts with diligence, good faith, courtesy and respect to foster effective coordination. Collaboration respects each person’s independence and duties, including confidentiality; it does not permit imposing a conclusion or signature.

A person may not sign, authenticate, approve or file a professional registry document for a building they own in whole or in part or effectively control. This condition applies to every signatory and filer, whether an OPSI member or not, including for a report, PDSI or professional notice confirming action or correction. Consent does not permit an exception.

The owner may prepare documents materially and communicate facts; a factual danger report requiring verification remains possible and free. Professional documents intended for the registry must be signed or approved by another legally authorized person and filed by an eligible person. Owners therefore cannot themselves approve their own PDSI for the registry.

This is a signature and filing condition under sections 3 and 4 of the registry regulation, with no new OPSI disciplinary jurisdiction over members of another order. Employment alone does not constitute effective control. Each profession’s own ethical duties continue to apply.

Because a situation presenting sufficiently serious risk should not be able to disappear into a private report.

The proposal distinguishes reporting-exempt non-compliance from non-compliances reaching a serious-risk threshold. For the latter, “non-compliance under documented action” and “non-compliance requiring action” do not describe two different degrees of severity: they are two states of handling of the same serious situation, and both are subject to mandatory registry filing.

A non-compliance is under documented action where the owner or responsible person addresses it immediately and seriously and the authorized person considers the handling credible and documented. This classification does not mean the non-compliance has been corrected. The professional may maintain that classification if, in professional judgment, the handling is real, sufficiently specific and compatible with the deadline. Where the risk requires immediate control, necessary compensatory measures must also be in place.

Where a non-compliance reaches the serious-risk threshold and is subject to immediate, serious, credible and documented handling, it is a non-compliance under documented action: it must be entered in the registry with its correction period, without that classification meaning that it has already been corrected. It does not appear in the authority’s dashboard merely because of that classification.

The same situation becomes a non-compliance requiring action where it is not adequately handled, where that handling ceases or becomes insufficient, or where the applicable period expires without verified correction. It remains subject to mandatory filing and then becomes immediately visible in the competent authority’s dashboard.

Classification must never be used to force non-urgent work or obtain a mandate. Refusal to award the corrective work to the professional who made the finding, selection of another provider or price negotiations are not risk criteria. The code of ethics expressly prohibits such commercial pressure, and the Order may establish regulatory guidelines, grids and examples to frame professional judgment.

The passage of time may nevertheless change the risk without creating an automatic rule. For example, a fire safety plan that has not been reviewed for one year does not necessarily reach the serious-risk threshold solely because of that delay. After a very long period — for example ten years — the same situation could reach the threshold, particularly in a private seniors’ residence or another occupancy involving greater vulnerability, depending on changes that have occurred and the concrete risk. If credible and documented handling is then established, it may be classified as a non-compliance under documented action; without adequate handling, it may be classified as a non-compliance requiring action.

An authorized person other than the person on the initial mandate may verify correction or change the status. The right to do so follows the authorization to identify the non-compliance; it is not reserved to OPSI members.

Professional agreement would be required only to challenge, on unchanged facts, whether the finding was mandatorily reportable non-compliance; without agreement, the competent authority would decide. Documented developments, such as credible action, compensatory measures or verified correction, could update the status without that agreement while preserving the earlier finding. See section 31.

The new assessment identifies whether it arises from changed circumstances, a disagreement between professionals or both. The reason, explanation, dates and earlier conclusions are preserved. A disagreement is not automatically misconduct and is not decided by the registry; disciplinary responsibility remains with the relevant professional order.

A separate closure remains possible when a requirement has legally ceased to apply, under section 11 of the registry regulation and section 17 of the non-compliance regulation. The verifiable basis and validation are retained; this closure does not certify that corrective work was completed.

No.

The proposed regime distinguishes reporting-exempt non-compliances from non-compliances reaching the serious-risk threshold.

A reporting-exempt non-compliance remains recorded in the professional report when it falls within the mandate. It is not filed in the registry merely because it exists and does not automatically engage the competent authority.

Where a non-compliance reaches the serious-risk threshold but is subject to immediate, serious and credible handling, it carries status “non-compliance under documented action”: it is entered in the registry with its correction period but does not appear in the authority’s dashboard merely because of that status.

The same situation carries status “non-compliance requiring action” where it is not adequately handled, where that handling ceases or becomes insufficient, or where the period associated with a non-compliance under documented action expires without verified correction. It then becomes immediately visible in the competent authority’s dashboard.

The mechanism therefore remains proportionate to risk while taking actual handling into account, without treating the two classifications as artificially separate levels of severity.

When a new inspection finds that a non-compliant condition still exists despite an earlier correction notice, the authorized professional issues a new finding under the applicable rules. That finding has its own date, classification and author.

The previous file and correction notice remain preserved in the registry history. The previous file need not be reopened or its status retroactively changed.

If the earlier verification or correction notice was flawed, the responsible professional’s conduct may be examined separately through existing professional accountability mechanisms. OPSI does not compel corrective work.

The proposal distinguishes a notice made available with a dashboard flag, explicit “Flag seen” confirmation, actual opening of the notice and explicit “Acknowledged” confirmation. Filing alone proves receipt by the registry. Supplementary notifications, delivery failures and reminders are part of operating the future registry; they create no new intervention duty for an authority.

During an outage, a fallback telephone contact directory must remain available independently of the system. A professional contacting in good faith an authority reasonably believed competent does not, for that reason alone, commit an OPSI disciplinary breach if a different authority later proves responsible. The call is documented and the filing completed as soon as possible. Existing emergency duties remain in force.

Yes. A competent PSI member, engineer or professional technologist who incidentally observes a sufficiently established reportable danger, or has serious and objectively grounded reasons to believe that one exists, must report it within the limits of professional competence, even without a contract or professional report.

If the facts support sufficient legal classification, the professional may file a formal notice; otherwise, a separate report clearly marked "requiring verification" is made without presenting unverified facts as confirmed non-compliance. An uncorroborated rumour alone does not trigger the duty.

The filing, its supplements, follow-up and administrative closure are entirely free. It creates no paid-report obligation, mandate, general inspection or right of entry. The 24-hour maximum begins when the knowledge becomes sufficiently substantiated; emergency services or the competent authority must be contacted first in an immediate danger.

A new assessment of reportable non-compliance would complete the ‘Reason for the new assessment’ metadata: changed circumstances, disagreement between professionals or both. The professional would explain the new elements or disagreement, the conclusions concerned and the scope of the checks under section 12 of the registry regulation.

The registry would retain successive conclusions and their dates. The metadata would not make the registry an adjudicator, create a new status or suspend the notice. Initial filings, automatic expiry conversions and purely clerical corrections would remain identified as such.

Professional agreement would be required only to challenge, on unchanged facts, whether the finding was mandatorily reportable non-compliance; without agreement, the challenge would follow the decision process under section 31. Documented developments, such as credible action, compensatory measures or verified correction, could update the status without that agreement while preserving the earlier finding.

A challenge to reportability on unchanged facts follows section 31. A competent authority that owns, manages or operates the building withdraws from this decision in favour of the RBQ. An unidentified authority or its refusal to decide also leads to the RBQ. If the RBQ refuses or is itself in that institutional conflict, the Minister responsible for the administration of the Fire Safety Act must decide. The person deciding must not have participated in managing the building or in the disputed assessment. The registry retains the facts and gives effect to the decision without imposing a decision timetable.

No. The registry would automatically calculate complete days since the same notice was opened and also retain the initial finding date. Reclassification, a renewed commitment, a new deadline or a different professional would not reset the clock. The competent authority would see this information within its lawful access scope under section 13.

The registry provides the record. The authority determines its response within existing powers. Displayed age creates no new duty to intervene or automatic penalty; the existing expiry-conversion mechanism still applies.

To ensure traceability of certain important professional acts and provide a structured follow-up channel for the most serious situations.

The registry would make it possible to know that a document was produced, by which professional, on what date, for which building and what category of document it is.

Non-compliance-under-documented-action notices would preserve their deadline and status; at the deadline, a non-compliance-under-documented-action notice not closed by an authorized person would automatically become non-compliances requiring action and be sent to the competent authority’s dashboard. Non-compliance-requiring-action notices would be visible immediately.

The registry would allow another authorized person to take over follow-up or verify correction without extending the original engagement. Only a challenge to reportability on unchanged facts would follow the professional-agreement or authority-decision procedure in section 31.

It would also preserve continuity where a building changes owner, manager or service provider.

The registry is not intended to become a warehouse where everyone files every document relating to a building. It would be limited to the documents and information determined by the regulatory framework.

The registry also provides personal access to “My reports” for documents a professional signed or approved, even after changing employer, subject to strict purpose and confidentiality restrictions.

The registry is legally established by the Act, but full documentary filing is activated region by region only after at least 24 months following the first board taking office. Until then, only an administrative monthly-declaration pre-registry is envisaged.

The same applicable technical standard may produce several separate reports. The proposal allows that separation where it improves clarity and follow-up for distinct systems, subsystems, equipment, areas, frequencies or interventions.

For example, NFPA 25 may result in one report for the sprinkler system and another report for the fire pump. Both reports remain tied to NFPA 25, but each has its own filing, unique number and history in the registry.

An inspection directly required under CAN/ULC-S536 and an inspection directly required under NFPA 25 each have their own report and filing. A standard incorporated by reference in the directly required standard may, however, be addressed in the same report under section 49.

For example, where a waterflow detector check in an NFPA 25 inspection uses the operating time specified by NFPA 72, that technical reference may remain in the NFPA 25 report: it does not, by itself, create a separate NFPA 72 report. The applicable edition and chain of references must still be verified for the building; a directly imposed standalone requirement retains its own report.

Yes. Every covered professional document, even one only delivered to a client, must show its EDF_ identifier in the header or footer of each page, including appendices and fire safety plans. A EDF_ identifier only on the cover or in metadata is insufficient.

It must be added before final signing. A linking sheet or record preserves an original or previously signed document that should not be altered. An urgent notice cannot be refused simply because an EDF_ identifier or triage key is missing.

The EDF_ identifier-on-every-page rule begins for documents newly produced after the region’s legal activation, not during transitional declarations.

Yes. One report can be filed in a single operation and linked to the EDF_ identifiers of all the buildings it covers, for example where one fire pump supplies two buildings. Each building retains its own EDF_ identifier; no permanent grouping is created.

The registry retains one official signed document and one filing identifier, linked to the records of the buildings concerned. Each consultation is limited to information legally accessible for the relevant building and user: where needed, other portions are redacted without altering the signed original. The EDF_ identifiers remain identifiable in the header or footer of each page of the official report, and corrections retain their links unless a change is expressly declared and recorded in the history. The “one report = one applicable technical standard” rule remains: a CAN/ULC-S536 report cannot be combined with an NFPA 25 report. Non-compliance notices are routed to the competent authorities for the buildings actually affected. A situation described in a common report may lead to separate notices with different classifications where circumstances specific to each building justify that distinction.

During the pre-registry stage, a report covering several buildings counts as one billable declaration and one fee, initially $10 and then at the applicable annual rate. After activation, one filing may be associated with multiple authorized EDF_ identifiers without double billing.

Every covered verification, inspection or testing report must be filed in the registry no later than seven calendar days after the intervention actually ends, including a stand-alone intervention. The period does not begin when the report is drafted, signed, approved or invoiced; those steps do not extend it.

Where results, information or documents from external sources needed for the final report remain outstanding, the professional must file a signed or authenticated preliminary report within the same seven days. It identifies established findings, outstanding external elements and matters requiring confirmation. The final report, linked to the retained preliminary report, is filed as soon as the necessary information is received and processed, without unjustified delay.

Serious non-compliances classified as “requiring action” or “under documented action” are reported separately as soon as possible and no later than 24 hours after identification and classification, without waiting for the full report. If they can only be established after an external result is received, the period starts when they can actually be identified and classified. See sections 28 and 29 of the Act and sections 7 and 9 of the registry regulation.

Even where a third party or software performs the actual filing, the responsible professional validates the final PDF and its essential metadata. Validation is linked to the exact file version and does not require a second signature where the existing signature already provides that assurance. If a documentary defect affects several reports, affected versions can be linked to one incident and corrected separately without deleting the originals.

If the registry and electronic fallback mechanisms are unavailable, a “requiring action” non-compliance destined for a competent authority is reported by telephone as soon as possible, without waiting 24 hours. A message on official voicemail is sufficient; the call is recorded and registry filing is completed once service is restored. For a non-compliance “under documented action”, a documented outage does not automatically require a call: filing resumes as soon as possible. Separate emergency rules remain in force (section 27 of the registry regulation).

The described filing deadlines begin only after the region’s legal activation date. Before that, a monthly administrative declaration provides only an accounting of eligible reports, with no mandatory PDFs or EDF_ identifiers.

Yes. For the legally applicable retention period, the authorized professional may retrieve reports they personally signed or approved, their versions and relevant rectifications. The “My reports” function is linked to the professional’s own identity, not the former employer’s account. It supports reviewing their acts, answering a complaint and cooperating with a professional inspection.

This access does not authorize browsing former clients’ entire files, later work by other professionals or unrelated commercial records. All access and exports are logged and remain subject to professional secrecy and confidentiality; commercial prospecting is not permitted.

The registry’s “My reports” feature is distinct from lawful, restricted and secure access to working records held by a former employer or firm; it does not replace notes, photographs, test results or other evidence.

No. The proposed OPSI Act governs professional approval of fire safety plans that are otherwise required, but it does not require building owners or those responsible for buildings to keep a paper copy. On-site availability, format and retention of plans remain governed by applicable building requirements and competent authorities, where such requirements exist. The professional registry does not change those external obligations.

A distinct transitional fee expressly authorized in the proposed Act would support secure registry development. It would be payable once per eligible report without inventing a documentary filing. Its legality and tax characterization require review. This fee would initially be $10 and would remain so during the year of the first registry activation; indexation to Québec’s all-items CPI would begin only on the following 1 January.

The initial $10 rate and indexation method are provisions of the proposed regulation made by the Minister responsible for the administration of the Fire Safety Act. The proposed Act would empower the Minister responsible for the administration of the Fire Safety Act to prescribe them after consultation with the Order.

It states only the responsible professional, period, eligible report categories and counts, a deduplication reference, amounts billed, collected and due, and adjustments. It does not request complete PDFs, plans or notices, and the pre-registry assigns no EDF_ identifier.

No. The proposal excludes general retrospective reconstruction. Paying the establishment fee cannot create a second fee solely because of possible later technical integration; documents produced after activation follow the ordinary regime.

No. Under the proposal, an official filing uses only the secure Web interface, the REST API or an official electronic fallback mechanism. Email, post, fax and physical delivery are not official filing channels. The receipt confirmation and timestamp establish filing. An urgent telephone call to an authority may remain permitted or mandatory. Where a filing is legally required, it must subsequently be regularized electronically. See section 13 of the proposed Act and sections 27 to 29 of the regulation.

Yes. Each legally specified independent professional document must have one complete principal PDF containing its pages, plans, tables and documentary appendices. A preliminary and a final report each have their own linked PDF version of the same intervention. Authorized photographs, videos, audio recordings and other technical evidence may be kept separately as DPJ_ exhibits without mandatory PDF conversion or per-file fees. Each exhibit is identified, timestamped where its capture date is known, linked to the related DEP_ and available EDF_ codes, protected and logged. Notices and factual reports received through structured electronic fields need no artificial PDF. See sections 21 and 23 of the registry regulation.

Before a premium increase specifically attributable to a notice originating in an incidental discovery, the insurer would have to reach the insured or authorized representative by telephone, explain the notice and contemplated increase, and allow three complete days, meaning 72 hours from that conversation. An unanswered call or voicemail would not start the period. Written confirmation would state its expiry. Section 48 proposes this protection.

No such increase could apply during that period or retroactively for it. At expiry the insurer would check the status: if the non-compliance is validly being addressed or the notice is closed, no increase attributable to the notice could apply. A new increase after a return to the status requiring action would require a new call and grace period.

The grace concerns the premium increase. Reporting, correction deadlines and urgent safety measures would continue to apply. The insurer would receive only the minimal incidental-origin indication, with no report or professional identity.

Section 24 proposes two limited routes: a central labour organization with written delegation from the legally representative affiliated association, or a legally authorized independent worker association affiliated with no central labour organization.

An affiliated association would have to delegate exercise of this power to its central organization. It would have no parallel autonomous account, and local branches or delegates would gain no access solely through their position. An eligible independent association could receive its own institutional account under the same controls.

Legal representation and workers’ current presence in the building would have to be established, and users individually designated. Only the existence, nature and deadline of a notice requiring action could be consulted. No report, plan, history, professional identity or worker personal information would be disclosed. Access would end when its conditions no longer held. The registry would remain non-public.

No. The code EDF_ is the building’s unique and permanent number in the OPSI registry. Each competent authority must assign its own administrative triage key to every building for which it is responsible. The key is unique within that authority’s records and is linked to the code EDF_. If two authorities have jurisdiction over the same building, each retains its own key.

Each authority sets its key according to its own processes; it may be changed in the registry only upon that authority’s written, dated and reasoned request. The former value and changes remain in the audit log. A temporarily missing key cannot prevent filing a report or notice; where no authority is designated for an area, the EDF_ — RBQ classification signals that absence directly to the RBQ.

Neither the key nor the EDF_ — RBQ classification creates legal jurisdiction: they only link, route and retrieve administrative records.

Only the registry issues the EDF_ identifier (code EDF_). Its format is EDF_XXXXXXXXXX: exactly ten uppercase characters from 0123456789ABCDEFGHJKLMNPQRSTUVWXYZ (excluding I and O). It is permanent, unique, never reused and distinct from cadastral lots, addresses, assessment numbers and triage keys.

The EDF_ identifier follows the building through demolition and remains linked to its archived record; a complete reconstruction gets a new EDF_ identifier linked historically to the former one.

An EDF_ identifier is not required and must not be artificially generated in the transitional pre-registry. Issuance and documentary use begin only upon the region’s legal activation.

When a municipality issues a construction permit for a new covered building, it transmits the necessary information. The registry creates an “Authorized project” record and issues an EDF_ identifier. Reliable confirmation of completion or occupancy changes its state to “Active building”.

A demolition authorization does not archive the building; only confirmed actual demolition changes it to “Demolished building — archived”. Cancelled projects retain their EDF_ identifiers in history. Technical deadlines are in the proposed government regulation.

Administrative onboarding of buildings occurs in activated regions under the government-set schedule, not automatically when the Order is established.

Each legally competent municipality, RCM, intermunicipal board or other authority declares the buildings and domains for which it is responsible, then assigns its own triage key. Several authorities and municipalities may be associated with one EDF_ identifier. OPSI does not decide legal jurisdiction and does not automatically rely on a main doorway or 911 call centre.

After the 18-month initial-integration moratorium, the absence of an authority declared for a given area normally triggers a calculated EDF_ — RBQ classification. During the moratorium, this provisional absence does not produce mass alerts, but every actual ‘requiring action’ notice is routed immediately to the RBQ even with no designated authority. No notice is lost and the RBQ does not automatically become the responsible authority.

The EDF_ identifier, lifecycle changes, jurisdictional affiliations, old property references and links between successive buildings form a permanent administrative record. Old records are never silently overwritten.

Minimum periods of 15 years for ordinary documents, 25 years for non-compliance notices and 10 years for audit logs remain separate from that permanent identity history. Personal information is protected and is not retained indefinitely without a legal basis.

Yes. A competent authority may have an EDF_ identifier assigned to an older or omitted building without a new permit. The registry searches for matching records first to avoid duplicates. OPSI administers the technology without determining jurisdiction for the authorities.

Each authority separately declares whether the building is subject to its filing or monitoring duties in its fields. Different declarations may coexist. Permit details sent by a municipality also reach the concerned authorities without duplicate transmission where one organization fulfills both roles.

A competent authority may request correction, merger or subdivision of administrative building identity. Where several authorities share that identity, they must agree. If consensus fails, the RBQ settles only the administrative identification dispute under the proposed statutory powers; it decides neither legal jurisdiction nor applicability.

The simplified equipment directory records only “present”, “absent” or “undetermined”. That data alone creates no inspection requirement and imposes no new inventory on fire safety professionals. A report is flagged as potentially missing only where its obligation and due date can be established, subject to the existing 30-day grace period.

An authorized professional may have the presence of a system actually observed during a mandate entered in the directory without carrying out a general inventory or approving its design or installation. Maintaining this directory does not impose any standalone system-identification filing on engineers. Classification by standard, system or scope reflects only the documents and information received: NFPA 25 reports may be filed while no CAN/ULC-S536 report is present, and an NFPA 10 report may cover only some equipment. The registry certifies neither that all building systems are known, nor that every required inspection was performed, nor that the building is compliant. Unknown information remains unknown and creates no presumption.

Merging, subdividing or reconciling EDF_ identifiers requires a controlled, documented operation. Historical EDF_ identifiers, links to documents and notices and decisions of the authorities are retained; affected indicators are recalculated after the change.

Missing-document alerts and automated flags do not apply to regions not yet activated. Regional rankings must be determined from the buildings actually subject to the scheme and verifiable administrative records.

No.

The registry would remain non-public. Access would be granted according to the functions and legitimate needs of authorized persons and organizations, and every consultation would be logged.

Insurer access would be deliberately very limited. For a building it insures or is considering insuring, an insurer could only know that an active non-compliance requiring action notice exists, the nature of that non-compliance and its correction period. It would have access to neither reports nor plans, non-compliance under documented action or reporting-exempt non-compliances, supporting documents, nor the identity of the authorized person.

The distinction is tied to handling, not to two intrinsic levels of severity. A non-compliance under documented action has already reached the serious-risk threshold but is subject to immediate, serious and credible handling within a controlled period. As long as that handling remains real, the proposal does not provide for disclosure to the insurer.

Limited insurer access arises when the same situation carries status “non-compliance requiring action”: it is not being adequately handled, its handling has ceased or become insufficient, or the period associated with a non-compliance under documented action has expired without verified correction.

At that point, the regime also seeks to create a real incentive for correction. Where a serious risk remains without adequate handling in a building, it is difficult to justify systematically keeping the insurer that bears part of the risk unaware of its existence.

The mechanism nevertheless remains oriented toward correction rather than punishment. As soon as an authorized person confirms correction or the situation validly returns to status “non-compliance under documented action” because serious and credible handling is established, the notice ceases to be accessible to the insurer.

The proposal also limits the pricing use of this signal. A premium increase specifically attributable to the registry notice could apply only while the situation remains classified as a ‘non-compliance requiring action’. It would cease on the date the non-compliance becomes ‘under documented action’ or is closed following verified correction.

If part of that increase was paid in advance for a period after the status change, the insurer would have to grant a pro-rata credit or refund within 30 days after the registry’s electronic notification. If the non-compliance later again becomes ‘requiring action’, a new increase could apply only for that new period.

The insurer, firm or representative could not charge the client registry-consultation fees or administrative fees related to that consultation or notification. The registry would tell the insurer only that the status giving rise to the signal has ended, without disclosing whether the situation is under documented action or has been corrected.

Professional agreement would be required only to challenge, on unchanged facts, whether the finding was mandatorily reportable non-compliance; without agreement, the competent authority would decide. Documented developments, such as credible action, compensatory measures or verified correction, could update the status without that agreement while preserving the earlier finding. See section 31.

An insurer may use the interface or an authorized API to consult a building it insures or is being asked to insure in a real, verifiable insurance file. Access remains individual, justified and logged; prospecting, bulk searches and an unsupported parallel private database are prohibited. Only information necessary for the decision or legally required retention may be kept.

A duly identified owner or authorized representative could obtain a one-off copy of building documents to which they are legally entitled, even after initial delivery. Identity, authority to represent and protected third-party information would be checked; only reasonable copying or transmission fees could apply. The owner could seek help from an authorized professional and obtain a reasoned new professional assessment, without general permanent access to the registry.

Worker-representation access under section 24 is limited to central labour organizations with written delegation from their affiliated associations and independent associations legally authorized to represent workers. An affiliated association must act through its central organization and receives no parallel autonomous account. Proof of representation and presence in the building, named users and logging remain mandatory. Access is not opened to all workers or to the public.

The registry would not be merely a database about buildings. It would constitute a province-wide infrastructure for tracing professional acts in fire safety: who performed the act, under what legal authority, what it concerned, when, with what document, and the history of any correction or reclassification.

That is precisely why it should not be administered by a competent authority. Municipalities, fire safety services, the RBQ, government departments and other authorities would be users of the registry and may need to investigate, order corrective action or exercise coercive powers on the basis of its contents. Infrastructure shared by several authorities should therefore not be controlled by any one of them.

This separation protects the public and institutional transparency. The body that enforces a requirement or intervenes in relation to a building should not also control the infrastructure preserving professional findings on which that intervention may rely; the separation of functions must be both real and apparent.

OPSI would instead occupy the neutral, cross-cutting position in the system. Its role is not to enforce building regulation on behalf of an authority, but to oversee professional practice in fire safety and protect the public. The institutional continuity is natural: professional → professional act → signed document → filing and traceability → oversight of practice → protection of the public.

The registry would remain interprofessional. An engineer or member of another professional order would use it under their own legal authority and remain fully subject to their own order. Administering the infrastructure is not the same as administering the professions that use it.

Sections 93 and 94 of the Notaries Act provide a useful parallel, without being a perfect equivalent: they show that it is not foreign to Québec’s professional system for an order to establish and maintain infrastructure directly connected with professional acts. For confidentiality, logging, access, corrections and technical operation, see “Why a registry?”.

OPSI would therefore administer the institutional memory and integrity of professional practice; competent authorities would retain their enforcement powers; and other professional orders would retain jurisdiction over their members.

On receiving a professional report, the registry would check the signatory’s professional authority at the relevant act and signature dates. Subsequent expiry would not retroactively invalidate a lawful act. An engineer’s or other professional’s inclusion in the registry would not grant any new authorization, and an administrative issue must not block an urgent notice.

An authorized competent authority may filter by inspection date and result (“compliant” or “non-compliant”), standard, type of system or inspection, and other permitted metadata. It may look for buildings with a non-compliant report, an active non-compliance requiring action, a non-compliance under documented action nearing its deadline, or successive non-compliant reports.

The registry may also flag a periodic inspection whose expected report appears to be missing. The flag appears 30 days after the expected inspection date: for example, one year and 30 days after a reference annual inspection if no corresponding report has been filed. Reliable frequency and baseline dates are required; this indicator is not automatic proof of a breach and does not change the legal filing deadline.

These searches use existing reports and notices without creating a separate record for each anomaly in a report. Insurers retain the much narrower access already provided by the Act.

API traceability distinguishes the application, organization, authorization holder and triggering actor and, for filing operations, the validating professional and any separate filer. Rights remain limited to those authorized; technical authentication secrets are never recorded in logs.

Statistics and summary datasets used for prevention or planning are anonymized and aggregated where needed. Registry disclosures must not reasonably identify a person, professional, owner or building. A legally authorized authority may separately access strictly necessary identifying information about a specific building through confidential, logged access.

Statistics may use groups of 5 or 10 observations or broader categories. Grouping and rounding alone do not guarantee anonymity: filters, comparisons and successive releases must be considered to prevent re-identification through cross-matching or subtraction. Small categories are suppressed or combined as necessary.

The proposal gives the Régie du bâtiment du Québec (RBQ) permanent read-only access to the entire registry throughout Québec, via a secure interface and API. Its provincial dashboard supports filtering, including special reports. Access remains confidential and logged.

The ‘EDF_ — RBQ classification’ is automatically calculated from available information and authority declarations, with no separate manually entered flag field. It marks either an institutional conflict, where the authority dealing with a building also owns or manages it, or the absence of an authority designated for the relevant area. During the 18-month initial-integration period, a missing designation alone does not trigger widespread flags; institutional conflicts remain flagged.

An actual ‘requiring action’ notice filed with no designated authority is immediately routed to the RBQ, even during the moratorium. In an institutional conflict, the authority receives its regular notice and the RBQ receives the same notice concurrently. Underlying conditions and transmissions are retained in the history. The RBQ does not automatically become competent and the proposal imposes no new intervention duty on it.

The EDF_ — RBQ classification and other monitoring indicators are recalculated from relevant official information whenever jurisdiction, classification, deadlines or administrative affiliations change. A performance cache is not a separate authoritative source, and earlier alerts remain traceable.

OPSI would not be a private association free to establish its own rules without outside oversight.

Like other Québec professional orders, it would form part of the professional system established by the Professional Code and would be subject to the oversight mechanisms provided by that regime, notably under the Office des professions du Québec.

The Order would also have separate mechanisms for professional inspection, discipline, complaint handling and governance.

In other words, OPSI would ask its members to be accountable, but the Order itself would also have to answer for its actions.

We want younger practitioners to have a place in the preparatory nonprofit even though that nonprofit is not itself a professional order.

Section 77.1 of the Professional Code calls for an additional director aged 35 or under when the conditions following an order’s election are met. It governs the Order, not the nonprofit’s board.

The proposed nonprofit board has six directors, including a voluntarily designated position for a person aged 35 or under. The future Order would normally have eight directors, six elected and two appointed by the Office, with a possible ninth director under section 77.1.

The nonprofit youth position is a governance choice, not a requirement imposed on the preparatory organization by the Professional Code.

The financial model uses $250 annual membership dues as a planning assumption, not a legally fixed rate. The board would set dues under sections 85.1, 103.1 and 104 of the Professional Code. The initial $10 fee would apply before regional documentary activation only to eligible verification, inspection or testing reports declared in the pre-registry. After activation, it would apply per eligible standalone filing: inspection report, PDSI approved by a PSI or another authorized professional, separately approved evacuation documents, a required professional exercise evaluation or a required professional staff-competence attestation. Reports already subject to the transitional fee would not be charged twice. All danger disclosures and their follow-ups remain free of charge.

All receipts would be pooled in the Order’s sole general operating fund. The registry, roll, inspections, syndic, discipline, administration and group insurance could be financed from those resources without ring-fenced allocations by revenue source, except where amounts are legally protected. Analytical accounting would preserve the traceability of fees and integrated regulatory costs for proportionality review. After obligations and necessary reserves, only surpluses whose transfer is legally authorized could be paid to the Foundation; general trust-account interest would remain separate under its own statutory payment process. The $10 fee remains proposed and would be reviewed in the event of a structural mismatch. Its indexation and any other changes would remain subject to regulation made by the Minister responsible for the administration of the Fire Safety Act, not a decision of the Order.

The amount and indexation are proposed in a regulation made by the Minister responsible for the administration of the Fire Safety Act made by the responsible Minister after consultation with the Order and the Office des professions. The Order only collects and accounts for the fees; it does not set them. The constituting Act must first expressly authorize this ministerial power.

Pooled funding is a policy choice in the proposal. The document-related fee is borne by the owner of the covered building under section 36, regardless of the filing professional’s title. It is not the filer’s personal contribution to PSI insurance. It is invoiced on a separate line, without markup or inclusion in professional fees. Professional dues and any access-account fees remain separate obligations.

To distinguish the regulatory fee collected for the Order from professional fees and commercial charges, with no markup. The general fee scheme is called the “Fee for establishment and operation of the Order and the central registry of OPSI.”

The initial rate would be $10 per eligible standalone professional filing in an activated region and $10 per eligible inspection or testing report during the transitional phase, subject to the ministerial indexation formula after the first activation year. The fee would be separately stated on written quotations and invoices, without markup or bundling. A PDSI and its integrated diagrams count as one document; separately approved and filed evacuation directives may constitute a second chargeable filing. Corrections, retransmissions, pages and attachments attract no extra fee.

Reportable non-compliance notices, preventive or “requiring verification” danger reports and their supplements, corrections and administrative closures remain free of charge, with or without a mandate. The same danger may appear in an eligible report, PDSI or professional attestation and also be disclosed separately without charge: only the independently eligible professional document attracts a filing fee.

The owner of the covered building bears this fee. The collecting professional or business acts as a collection intermediary; the separate line distinguishes it from professional fees whether the filing is signed by a PSI, engineer or professional technologist.

The proposal does not itself create a tax exemption. GST, QST or any other tax would be added only to the extent required by applicable tax legislation.

As a current reference, Revenu Québec states that most taxable supplies are subject to 5% GST and 9.975% QST. If the OPSI filing fee is treated as a taxable supply, a $10 fee would therefore be about $11.50 including taxes. This example uses the initial $10 rate; in later years any applicable tax calculation would use the rate then in force if the fee is taxable.

Taxes collected would be accounted for separately and remitted to the tax authorities; they would not be treated as funding revenue of the Order.

The Chambre des notaires regulation, for comparison, sets fees of $7 for an electronic report and $10 for a paper report without creating a specific tax exemption in that regulation. The final tax treatment of the OPSI registry would have to be confirmed before launch.

The proposal would not create a new tax, but existing GST/QST rules still apply where required by law. The transitional fee’s characterization requires legal and tax review; merely calling it a “fee” is insufficient.

Yes. The proposal provides for a mandatory basic group plan for every member who practises the profession, with an exemption possible only where a member performs no professional activities.

Minimum coverage amounts remain to be set in the draft regulation. The figures of $250,000 per claim and $500,000 over twelve months are working assumptions, not amounts already written into the text. Coverage would be individual to each member, without a shared aggregate limit merely because members work on the same building, project or property complex; additional coverage could be required for certain practices.

This structure draws on existing models. Québec engineers participate in a basic group plan and, when they perform covered activities in private practice, in a complementary group plan. Professional technologists are also subject to mandatory group coverage, with higher coverage for certain private practices.

No actual OPSI premium is known yet. The model uses an internal working-budget assumption of $350 per member per year, or $682,500 for 1,950 members; no insurer quotation or independent actuarial assessment establishes that cost. This provision is included within the $1.45M Order-operations line and is therefore not added a second time to the $2.6M annual budget. If the actual cost is lower, the difference remains available in the Order’s general fund, subject to legally protected amounts.

Coverage for claims brought within five years after the duty to maintain coverage ends or the person ceases to be a member is mandatory and does not depend on the commercial availability of such insurance.

Professional dues, regulatory filing fees and other eligible receipts would feed OPSI’s single general operating fund. They could finance all of the Order’s lawful functions, including the registry and group insurance, without separate envelopes based on revenue source.

Registry revenue and cost tracking would remain mandatory in analytical accounts to document fee proportionality. Only the Minister responsible for the administration of the Fire Safety Act could set or revise those fees. Persistent surpluses would trigger a review of their legal justification and, if necessary, a regulatory adjustment.

After obligations and justified reserves, a surplus payment to the Foundation would be permitted only where authorized by law and consistent with the Order’s mission; legally segregated amounts could not be diverted. No profit or rebate would be distributed to members.

Trust money and legally separate insurance or compensation fund assets would remain governed by their respective rules. Net income on general trust accounts would follow the direct statutory route without passing through the general operating fund.

No. The proposal seeks a clear and workable legal framework without trying to anticipate every unusual situation. Existing rules apply first; any genuine difficulty is documented and referred to the body within the proposed Order that has the authority to consider it.

Some administrative or technical details could later be clarified by the future Order’s board of directors, within its lawful powers and when actual circumstances warrant it. This does not allow the board to create an unlawful exception, alter another authority’s jurisdiction or bypass a necessary regulatory or legislative amendment.

For example, consider one piece of equipment serving several buildings owned by different people, potentially in different municipalities, and covered by one report. These hypothetical cases do not require a new obligation today; they may later call for lawful filing, linking or consultation arrangements.

Another case is a signed report covering several buildings where an authority may consult only part of it. A redacted extract must preserve the signed original. If an exceptional authenticity issue cannot be resolved by existing mechanisms, it may be referred to the competent body, including the board when appropriate.

The board cannot compel a municipality or the RBQ to intervene, perform acts reserved to engineers, or replace other bodies’ decisions and legal remedies. Routine IT incidents still follow ordinary support procedures. The goal is a framework that protects the public without prescribing a legislative rule for every rare possibility.

The fee, initially $10 and indexed under the proposed regulation made by the Minister responsible for the administration of the Fire Safety Act, is borne by the owner of the legally covered building to which the report relates, even where a third party is the customer. Collection by an agent and allocation of a single fee between several covered owners require legally enforceable rules. No charge arises under this scheme for a building outside its scope.

No: the proposal does not seek to introduce a new general tax on individuals or businesses. It instead proposes a targeted regulatory fee, initially $10 and subsequently indexed using Québec’s all-items CPI, for each eligible inspection or testing report concerning only legally covered buildings. The number billed depends on genuinely necessary reports, never a tariff directly based on floor area, property value or business status. More systems may produce more reports, but not automatically; artificial splitting is prohibited.

The intended general label is “Fee for establishment and operation of the Order and the central registry of OPSI.” Its name alone does not determine legal classification: express statutory authority, a demonstrable link to scheme costs and transparent use of proceeds must be validated. Existing GST and QST apply where required.

The general designation would be “Fee for establishment and operation of the Order and the central registry of OPSI”. Before regional activation, invoices would state “OPSI central registry establishment fee” and, afterwards, “Filing fee — Central registry of OPSI”, in both cases followed by the actual annual rate in effect. The initial $10 would remain in force throughout the calendar year of the first regional opening; from the following 1 January, the formula based on Québec’s July all-items CPI would apply automatically, without allowing the Order to increase the fee or create additional charges.

Only the owner of a covered building bears the fee, once per eligible report, without markup or a second collection on later integration. The fee must be separately itemized on any written quotation and on the invoice, never bundled into a flat service price. If the number of reports is not yet known, the quotation states the rate and calculation method; known changes must be disclosed before billing. Legal classification and tax treatment require validation before commencement.

These tariffs would be set out in the proposed regulation made by the Minister responsible for the administration of the Fire Safety Act on financing and registry fees. The Order’s board could not change the rate or add fees by resolution.

The preparatory OPSI non-profit has not yet been incorporated. Its official name and NEQ must be confirmed after letters patent are issued and, where needed, inserted in section 58 before the proposed Act is finalized. The future Order would be a different legal person from the “Fondation de l’Ordre des praticiens en sécurité incendie”, which is expressly named in the proposed Act.

When the Order is established, the non-profit would inventory its assets and obligations and transfer net assets lawfully available for transfer to the Order. Creditors, refunds owed, non-assignable agreements and restricted gifts would remain protected.

The existing organization would then adopt the necessary resolutions to amend its name and constitutive purposes through the procedures of its actual governing law. It would retain its legal identity and begin its new mission without the transferred assets; it would not be dissolved or automatically incorporated anew. If those amendments were legally impossible, a separate foundation could be incorporated under the ordinary procedures, without automatic creation by the Act.

The Foundation would have its own board and apply separately for registered charity status with the Canada Revenue Agency, with no guarantee of approval. Member dues and filing fees would flow into one common general fund; after obligations and necessary reserves, only surpluses whose transfer is legally authorized could be paid to the Foundation, without an exclusion based on revenue source and subject to legally protected funds. Net interest on general trust accounts would be remitted to it directly once legally permitted. See sections 38, 40 and 58.

The proposed preparatory non-profit board would have six director positions, with six people having agreed to participate. A separate Partner Advisory Council is also proposed, with eight advisory council member positions and six association advisory seats to fill, without board voting rights or participation in the board’s quorum. The Order’s first board would have eight persons including its president: six eligible regular directors of the preparatory organization proposed through the Office and designated by Government order, plus two directors appointed by the Office des professions.

The Order’s regular board would normally have eight directors: six elected from among eligible members and two appointed by the Office. The president is chosen from the six elected directors without an additional seat. Section 77.1 of the Professional Code may exceptionally provide for an additional director aged 35 or under.

Advisory council member or associate status in the nonprofit gives no right to the six founder seats, professional permit or automatic admission to the Order. A person independently meeting the professional admission requirements may still apply later; the Office retains exclusive authority over its two appointed seats.

The first election of the six member-elected directors and their assumption of office would occur as soon as reasonably possible and no later than one year after the first board takes office under section 56. The two Office-appointed seats would remain separate. The board would then elect the president by secret ballot from among the six elected directors who stood for office, without adding a seat. The registry would not have to be activated for this election.

An already admitted member could register as “PSI ret.” and perform no reserved activities, including unpaid work, with $0 annual base Order dues, subject to legally required contributions. There would be no permanent registry access: only temporary, targeted access authorized to defend a legally protected right could be granted.

Yes. This would be a reactivation of practice rights, not new initial admission. Members must update competence, complete justified supplementary training, pay applicable dues, reinstate insurance and comply with any lawful restriction.

The proposal requires at least ten hours of continuing education each year for practising PSIs, including periodic ethics content. Newly admitted members must also complete initial professional ethics training. Retired and inactive non-practising members are exempt from annual hours while in those statuses.

The corpus contains the proposed Act and 21 draft regulations covering elections, inspection, fees, general trust accounts, compensation, continuing education and board ethics. Receiving advances in trust would remain prohibited until the financial and regulatory safeguards are genuinely operational. No provision has been adopted.

Once the complete registry is legally activated in a region, filing a PDSI professionally approved by a PSI or another legally authorized professional would initially cost $10. The same unit fee would cover eligible verification, inspection or testing reports, independently approved evacuation directives, legally required professional exercise evaluations, and required professional attestations of building staff training or competence.

A PDSI, its plans and its integrated diagrams form one document and attract one fee. Where evacuation directives are approved and filed as a genuinely separate professional document, a second fee may apply. Pages, appendices and corrections are not charged separately.

Before regional activation, the pre-registry remains limited to eligible verification, inspection or testing reports. The former requirement that the responsible engineer file a separate documentary identification of a system is removed; no new filing is needed solely to populate the equipment directory.

Reportable non-compliance notices, outside-mandate danger disclosures, their supplements, follow-ups and administrative closures remain entirely free of charge.

For every covered document, a correction, modification or partial review remains linked to the current filing, without a new fee or postponement of the due date.

A separate new filing requires the corresponding inspection, verification, testing or professional review to be fully repeated and approved. The fee is then payable again. Where a periodic requirement applies, the cycle restarts on the last day of that work, even if the document is filed later. See section 15.

For example, for an annual cycle, an inspection completed on November 20 remains due the following November 20 despite a later change to the report. If the inspection is fully repeated on July 15, the new cycle starts on July 15, not on the filing date. The same rule applies to a fully reviewed and approved PDSI, even without substantive changes. Danger reports and their follow-ups remain free.

This is a deliberate policy choice to maintain service continuity. Some businesses, including large groups and publicly traded corporations, have ownership and governance structures that cannot reasonably be reorganized solely around a new profession’s conditions. The proposal therefore retains the grandfathered right in section 73 instead of requiring such restructuring to continue operating.

The right would be single and attached to the authorized business. A sale or control change could transfer it with that business, but no split, franchise, division or reorganization could multiply it. The business would have to retain an employed PSI with real professional authority, insurance, independence and all other duties.

The ordinary practice-in-firms regulation also permits eligible ownership structures. A commercial trust with PSI trustees and non-PSI beneficiaries may be considered if its constituting documents and operation genuinely meet the control, voting and governance conditions in section 3. Beneficiary status confers no power to direct professional judgment. This is not a universal means of restructuring every existing group and never permits evasion of the actual-control requirements.

Preserving the grandfathered right therefore expresses the chosen policy compromise for existing structures, without exempting competence, ethics or responsibility. The right cannot be created merely through seniority after the initial admission period.

The first election and assumption of office of the six elected directors would occur no later than one year after the Order’s first board takes office. Section 56 would make this independent of registry activation, whose minimum 24-month period would remain unchanged.

The six elected seats would be open to eligible members. Initial directors could stand if eligible, without automatic renewal. The two Office-appointed directors would remain separate.

Elected and appointed directors would choose the president by secret ballot from among the six elected directors under section 2 and the organization regulation. The presidency would add no elected seat.

The five-year report would remain required. Section 81 would add an assessment within six months after the third anniversary of the first mandatory regional activation, followed by a review within six months after the third anniversary of the last activation. The final review would therefore cover at least three operating years in every region. If those deadlines coincide, one report could satisfy both duties.

The analyses would distinguish regions by operating duration and use data on corrections, notice age, reclassification reasons, disagreements, costs, access and service availability. Filing the first five-year report alone would not end the reporting obligation.

No. Its mandate would be limited to pressing statutory obligations, immediate public protection and acts indispensable to start-up and the election. It would have to give reasons for its decisions and leave policy choices and commitments that can wait to the elected board.

Its priority would be to promptly identify potentially eligible persons and invite them to apply for membership, facilitate admission without lowering statutory requirements and hold the democratic election of the board as soon as reasonably possible. One year would be a maximum, not a term to wait out; the registry would not have to be activated. See section 56 and the first-board regulation 9.

Yes. The proposed route is a trust carrying on a commercial activity, with more than 50% of its trustees being practising PSI members who also form the majority of the quorum. Beneficiaries may be non-professionals, while trustee control and independent professional decisions remain governed by section 3; existing businesses’ grandfathered rights remain separate.

Whether funded through professional dues, an employer or report fees, costs normally pass through the service chain to clients and, subject to applicable rules, tenants. The proposed structure aims to avoid disrupting that chain: a separate transparent fee per eligible report and modest personal dues paid by the member or reimbursed by the employer. Those dues alone do not justify a steep price increase; professional fees remain tied to services actually provided.

The first board must reconcile public protection with professional self-governance: seats reserved for the profession should be held by members of the Order, including at its inception. OPSI therefore proposes a transitional compromise.

An important precedent to preserve

To our knowledge, among the orders constituted by a specific Act under the first paragraph of section 24 of the Professional Code that we have examined, no first board allowed directors deemed elected to govern without being members or having a statutory route into the profession. Section 76 requires the president and elected directors to be members; directors appointed by the Office des professions are governed by different rules. OPSI considers that a first board on which the profession’s representatives remained non-members would set a troubling precedent for professional self-governance.

Three specific Acts illustrate this link: acupuncturists (1994, ss. 27 and 29), whose first directors came from the register and whose registrants on the statutory date obtained roll registration and permits by right; midwives (1999, ss. 48 and 52 as originally enacted), whose first directors came from pilot projects and whose recognized practitioners received permits; and geologists (2001, ss. 18 and 20), whose first directors came from an association whose regular members received permits. Sexologists and criminologists were instead established by letters patent (s. 27 of the Code), not by a specific Act. None of these cases is identical to OPSI’s.

Section 56 would reserve the single permit by operation of law, without examination, internship or additional recognition of prior learning, for the six founding directors initially designated from the promoting organization who can substantiate at least 24 months of relevant professional experience totalling at least 1,800 hours of actual practice in duties directly related to activities covered by the Act. Experience may come from employment, self-employment, or work in a public or private organization. The Office verifies supporting documents before making its recommendation. Appointment alone is insufficient. Directors appointed by the Office, replacements and successors are excluded; mandatory statutory requirements remain applicable. This 24-month and 1,800-hour threshold is OPSI’s own choice, separate from the argument based on precedents.

These six members would remain subject to mandatory ethics training, continuing education, professional ethics, professional inspection and discipline. The first board would be temporary: elections must be held no later than one year after it takes office.

This compromise was selected to advance public protection. Charles Gibouleau, the project's proponent, personally assumes responsibility for this choice; parliamentarians may reconsider or amend it in parliamentary committee.

The proposal entails costs but seeks to allocate them fairly and limit the burden on members. Potential administrative savings must be measured rather than assumed.

Planned annual dues are $250 per member, plus legally applicable contributions and taxes. The Order’s board could revisit dues under the applicable rules.

From the Order’s legal and operational launch, the proposed transitional $10 fee per eligible professional report would finance registry development without PDF filings. After regional activation, the ordinary $10 filing fee applies to the relevant report, without a second charge for a report already subject to the transitional fee. The amount would remain $10 until 31 December of the calendar year of the first regional activation of the full registry. From the following 1 January, both the transitional and ordinary fees would be indexed using the July-to-July change in Québec’s all-items CPI, without any discretionary increase by the Order.

The owner would bear the fee through legally defined arrangements. Regulatory and tax characterization needs review. Additional public administration costs cannot be dismissed without assessment.

Any change to an oversight framework can have practical effects that must be examined before a model is finalized.

The work will need to document, in particular, costs for professionals, employers and owners, workforce availability, regional realities, possible overlap with existing responsibilities or qualifications, and any new administrative obligations that could result from the proposal.

It will also be necessary to assess appropriate transition periods and the risk that implementation that is too rapid or poorly adapted could disrupt services, particularly where certain skills are scarce or unevenly distributed.

These concerns should not be treated as secondary objections. They are part of the proportionality and feasibility analysis of the proposal.

When documented, they may justify changes to the scope of the activities concerned, admission rules, timelines, transition mechanisms or even the proposed oversight model.

OPSI seeks expedited, cross-party legislative adoption of its proposal. Its priority is to establish the Order promptly so that the professional roll, competency requirements, ethics, professional inspection and discipline can be put in place.

As a non-partisan organization independent of every political party, OPSI will seek cooperation from all parties represented in the National Assembly, in government and in opposition, to build broad agreement and pursue a timetable that moves as quickly as reasonably possible. No political endorsement, agreement or parliamentary schedule is assumed.

This approach does not seek to curtail debate through closure or impose an exceptional procedure to silence opposition parties. It respects scrutiny by the Office des professions, necessary consultations, parliamentary debate and members’ procedural rights. It does not change the minimum 24-month period after the first board takes office before full registry obligations can be activated region by region.

Never before 24 months after the first board of the Order takes office. The government would then set dates for Québec’s 17 regions; the Order would publish the corresponding operational plan. No regional dates have been established.

From the regions with the fewest buildings actually subject to the scheme to those with the most. Buildings covered by the rules must first be counted using reliable administrative records. No numerical ranking is published before validation.

The initiative would engage the Premier, the Minister responsible for the administration of the Professional Code, the Minister responsible for the administration of the Professional Code, the Minister responsible for the administration of the Fire Safety Act and the Office des professions. One minister may hold multiple responsibilities. Legislative decisions remain with the competent institutions and the National Assembly.

No. The proposal provides for a region-by-region activation, no earlier than 24 months after the Order’s first board takes office. The government would legally set activation dates and the Order would publish the corresponding operational plan. The rollout would begin with regions having the fewest buildings actually subject to the scheme, based on a verifiable administrative count. No definitive regional activation dates have been announced.

Before activation in a region, the pre-registry would, once legally authorized and operational, use simplified monthly declarations and an establishment fee at the applicable annual rate, initially $10 per eligible report, with no mandatory PDF filings or EDF_ identifiers. After activation, full documentary filing and related registry mechanisms would apply in that region. Existing obligations under other laws would not be suspended.

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