OPSI - UNENACTED working proposal

v308 | 2026-10-28T08:19:05+00:00 | Corpus 85

DRAFT REGULATION

REGULATION RESPECTING CATEGORIES, ADMISSION, INTERNSHIP, SUPERVISION AND RECOGNITION OF COMPETENCIES

I - PURPOSE

Section 1 | ART_89S51AF2JGT1ELM7 | Version 3

This regulation is made by the board of directors under sections 6 and 7 of the Act and the relevant enabling provisions of the Professional Code. Equivalence standards and procedures and permit-issuance conditions under paragraphs c and c.1 of section 93 and paragraph i of the first paragraph of section 94 are approved by the Office under section 95.0.1; activities authorized for non-members under paragraph h of that same paragraph follow section 95.2. Refresher training and courses under paragraph j follow sections 95.1 and 95.3. Provisions based solely on the Act’s specific enabling powers follow section 95. These procedures apply separately according to subject matter.

This Regulation establishes the categories and statuses forming the admission and practice pathway, as well as the conditions for progressing between them.

These categories do not constitute separate permits.

Section 2 | ART_RN34S0BKG56RTT91 | Version 2

The following categories and statuses are established:

1° applicant;

2° admission candidate;

3° intern;

4° member in supervised practice;

5° practising member;

6° inactive member;

7° transitional member during the initial admission regime, holding the single permit and entered on the roll with applicable limitations. This status is distinct from that of intern, member practising under supervision, and regular practising member; it is governed by the initial admission regulation.

8° retired member: a person previously admitted, entered on the roll and not practising any reserved professional activity under that status.

A transitional regulation may provide for other temporary statuses.

II - CANDIDACY

Section 3 | ART_BM2XTQCJHU16JF3Z | Version 2

Every person beginning a pathway leading to a permit is first registered as an admission candidate.

Section 4 | ART_T4XM644PVKSRV2CN | Version 2

A person is eligible for the pathway leading to issuance of a permit if the person satisfies one of the education or qualification pathways recognized by this Regulation.

Recognized pathways include, in particular:

1° successful completion of a recognized college diploma in fire prevention or fire safety, including the Diploma of College Studies in Fire Safety Techniques (311.A0), or training recognized as equivalent;

2° successful completion of the Attestation of College Studies in Fire Prevention (JCC.07) or a program recognized as equivalent;

3° obtaining the Diploma of Vocational Studies in Fire Protection Mechanics (5312);

4° holding a recognized complete professional qualification for trade 416 — fire-protection mechanic — independently of holding the diploma referred to in paragraph 3°;

5° successful completion of a fire-alarm training pathway recognized by the Order, including the CFAA-accredited pathway offered by Cégep du Vieux Montréal, or training recognized as equivalent;

6° obtaining the Diploma of Vocational Studies in Electricity (5295), the Diploma of Vocational Studies in Installation and Maintenance of Security Systems (5296), or holding a valid competency certificate issued by the Commission de la construction du Québec in the electrician trade or a relevant security-systems specialty;

7° successful completion of a relevant university program recognized by the Order;

8° recognition of education or a combination of education and experience considered equivalent;

9° recognition of prior learning and competencies in accordance with this Regulation.

Holding more than one qualification referred to in this section is not required where one of them alone constitutes a recognized pathway.

The pathways in this section remain separate and non-cumulative. Their recognition does not displace the diploma and training equivalence standards in sections 25 to 28 or competency assessments genuinely relevant to the single permit.

The education and qualifications listed here are proposed admission pathways, not, by their mere inclusion, a list of diplomas recognized as granting access to the permit by a regulation under section 12.0.1.1 of the Professional Code. Such a list must be established by regulation of the Office des professions du Québec, subject to required consultations and approvals. Separate routes established by the constitutive Act must remain distinct from equivalence to an officially designated diploma.

Section 5 | ART_5Y1BKNUKN1K8VVR6 | Version 2

Every person newly admitted to the Order, through an ordinary, transitional or equivalence pathway, must satisfy the mandatory initial training requirement in ethics, professional conduct, public protection, professional secrecy, independence and PSI responsibilities in section 24. The Order may not make this requirement optional; only objectively demonstrated equivalence permitted by law may be recognized.

Other integration components, including registry procedures, reporting duties and the technical legal framework, may be adapted to the candidate’s pathway and previously demonstrated learning.

Section 6 | ART_REBT6CGMEVLN8JWR | Version 2

The pathway is not subject to any automatic maximum duration.

The candidate remains eligible as long as the candidate meets the conditions for renewal of status and makes reasonable progress toward the required competencies.

III - INTERNSHIP

Section 7 | ART_12MYUUUEBP8HCJQ2 | Version 2

Before a permit is issued, the candidate must demonstrate sufficient practical experience to practise autonomously the professional activities that fall within the candidate’s competence.

This requirement may be satisfied through an internship, supervised practice, recognized prior professional experience, or a combination of those elements.

Section 8 | ART_US3USEFU7ENHUJA5 | Version 2

The purpose of the internship is to demonstrate the intern’s ability to carry out professional activities with competence, prudence, increasing autonomy and an understanding of their limits.

Section 9 | ART_0SE9DA4YELR19UUP | Version 2

The internship may be completed concurrently with an educational program or after it.

It may be discontinuous where justified by the nature of the program, employment or activities.

It continues until the required competencies have been demonstrated.

Section 10 | ART_GR2SVZY0QWYDNNPF | Version 2

The intern may carry out professional operations authorized by the Order under the required supervision.

The intern may not, in their own name:

1° sign or authenticate a final professional report;

2° give professional approval under section 10 of the Act;

3° issue a professional attestation under section 12 of the Act;

4° make a final classification of a non-compliance as a non-compliance under documented action or a non-compliance requiring action;

5° make a filing in the registry as the responsible professional.

Section 11 | ART_JX013TQBH6TGR30L | Version 2

Supervision may be direct or indirect according to:

1° the intern’s competence;

2° the complexity of the activity;

3° the risk to the public;

4° the experience already acquired.

Section 12 | ART_4WGV4YG141UF6MP9 | Version 2

The supervisor is normally a practising member.

The Order may recognize another legally authorized professional as a supervisor where that professional’s field of competence is appropriate to the activities being supervised.

Section 13 | ART_DH2ASA2DH03321XD | Version 2

The supervisor must:

1° determine the scope of the activities assigned;

2° be reasonably available;

3° review the work as necessary;

4° intervene where a situation exceeds the intern’s competence;

5° periodically assess the intern’s progress.

IV - RECOGNITION OF PRIOR LEARNING AND EXPERIENCE

Section 14 | ART_8BTBHU7TN2WR4JM9 | Version 2

The Order may recognize, in whole or in part:

1° prior education or training;

2° professional experience;

3° workplace learning;

4° a certification;

5° a trade qualification;

6° prior supervised practice;

7° professional achievements;

8° competencies demonstrated through an examination or practical assessment.

Recognition is based on competencies actually demonstrated and the diploma or training standards in sections 25 and 26; it is not a blanket exemption from the initial ethics requirement under section 24.

Section 15 | ART_D65G4Z4W6ERRMRHY | Version 2

Recognition may have the effect of:

1° exempting a person from part of a program;

2° reducing certain internship requirements;

3° recognizing a specific competency as acquired;

4° allowing access to a final assessment.

It does not automatically exempt a person from an overall assessment of competence.

Partial recognition must identify the competency areas recognized and the substantial gaps remaining, with complementary measures limited to those gaps and review rights under section 28.

V - MEMBER IN SUPERVISED PRACTICE

Section 16 | ART_H0KW5J73QSHE5GLM | Version 2

The Order may issue the permit while temporarily imposing the status of member in supervised practice where general competence has been demonstrated but an additional period of supervision is indicated.

Section 17 | ART_1RWYZJS08QQL668X | Version 2

The Order determines the activities, conditions and duration of the supervision.

The status is reviewed periodically.

It ends when the prescribed conditions are satisfied.

VI - PRACTISING MEMBER AND INACTIVE MEMBER

Section 18 | ART_J4TJ9R6SF27BFT59 | Version 2

A practising member may carry out the activities provided for by the Act, subject to the member’s personal duty of competence.

Section 19 | ART_HZ3TC28V0D8XLDNK | Version 2

An inactive member remains entered on the roll but may not carry out a reserved activity during the period of inactivity.

The Order may require refresher training before a return to practice where the period of inactivity or the circumstances justify it.

VII - ASSESSMENT AND TRANSITION BETWEEN STATUSES

Section 20 | ART_6CXM4QD8U7TFSUK6 | Version 2

The Order may use:

1° file reviews;

2° written examinations;

3° oral examinations;

4° practical assessments;

5° simulations;

6° structured interviews;

7° internship reports;

8° observations in the workplace.

Section 21 | ART_7KRW99X53WXLVYHN | Version 2

Progression is based on demonstrated competence and not on the mere passage of a fixed period of time.

Section 22 | ART_K12JRKC1U0KCNU1F | Version 2

The Order may extend an internship or status where the required competencies have not yet been demonstrated.

It may impose supplementary training, assessments or experience.

VIII - FINAL PROVISIONS

Section 23 | ART_SKF23JDLAEWWCYZ9 | Version 2

The status of a person who is not a member does not authorize the person to use the title “fire safety practitioner” or the initials “P.S.I.”.

IX - EQUIVALENCIES AND INITIAL PROFESSIONAL EDUCATION

Section 24 | ART_SRBE8G64MBAR3DEJ | Version 2

Every person newly admitted to the Order, including by equivalence or under the transitional regime, must satisfy mandatory initial training in professional ethics, the professional framework, confidentiality, independence, public protection and PSI duties. Objectively equivalent prior training may be recognized to the extent permitted by law; technical experience alone does not replace this requirement.

Except for an expressly authorized transitional measure in the constituting Act with safeguards, this training must be completed before independent practice rights are granted. Transitional entry on the roll before completion does not authorize independent practice contrary to this condition.

Section 25 | ART_SFEZF92NLAAZ8EGU | Version 2

For the purposes of paragraphs c and c.1 of section 93 of the Professional Code, ‘diploma equivalence’ means recognition that a diploma issued outside Québec demonstrates knowledge and abilities substantially comparable to those of a diploma giving access to the FSP permit and designated by regulation of the Office des professions du Québec under section 12.0.1.1 of the Code, approved as legally required. Since 2 April 2026, that provision has replaced the former section 184 framework, which has been repealed. This Regulation does not establish a single mandatory university diploma or authorize the Order itself to designate qualifying diplomas.

Diploma equivalence is recognized where documented assessment shows a comparable level of education, program content, practical training and assessment methods substantially covering core PSI permit competencies: interpreting applicable requirements and standards; inspecting and testing covered systems; reliable data gathering and analysis; risk judgment and limits of competence; reporting and traceability; and independence, safety and public protection. Differences in nomenclature, institution or program length alone are insufficient grounds for refusal.

When the Order is constituted, the exact list of diplomas granting access to the permit must be established and coordinated with the Office, relevant educational institutions and the competent authorities under the provision of the Professional Code mentioned in the first paragraph. Until an applicable regulation has designated a qualifying FSP diploma, no person may be deemed to have obtained formal diploma equivalence against a non-existent designated diploma. Distinct admission routes expressly provided for by the constitutive Act and section 4, including trade qualification and experience-based routes, may apply under their own statutory authority and competency assessments without usurping the Office’s diploma-designation power. Aligning the equivalence standards with any enacted designation is a precondition to using the formal diploma-equivalence route.

Section 26 | ART_UKK9X59FTBH5L4Y0 | Version 2

Training equivalence is recognized where a person without the normally required diploma demonstrates, through education, vocational training, trade qualifications, certifications, placements, actual experience and assessment, knowledge, skills and abilities substantially comparable to those required for the permit. Assessment considers relevance, currency, complexity, independence, supervision and verifiable outcomes of actual work.

Vocational (DEP), college (DEC/AEC), trade 416, electrical, fire-alarm, recognized certification, university and experiential pathways remain eligible within their scope; none automatically establishes equivalence or requires multiple qualifications simultaneously. Gaps are assessed competency area by competency area using section 25 criteria, without arbitrary academic-hour requirements.

A gap is substantial only if it compromises the ability to perform safely and independently an activity within the permit and cannot be offset by equivalently demonstrated skills. Legally binding mobility and recognition agreements remain applicable.

Section 27 | ART_V68MG5EA2FYHSACW | Version 2

The board establishes an equivalence committee of at least three persons collectively knowledgeable in fire safety, education and assessment; where admitted qualified practitioners are available, a majority has relevant professional practice experience. A person must not participate if they directly supervised, employed or assessed the candidate, have an interest in the outcome or could reasonably appear biased. Interest declarations and recusals are recorded.

The application may require, as relevant, diplomas and transcripts, course and competency outlines, placement records, trade certificates and authorizations, professional history, verifiable work records and appropriately redacted reports, references and reasonably necessary translations. The committee may require an interview, examination or practical demonstration solely to assess an identified competency and must consider evidence already provided.

Within ninety days after a complete file or the final reasonably required assessment, the committee issues one of the following: full equivalence; partial equivalence identifying recognized competencies; conditional recognition subject to targeted coursework, placement or assessment; or a reasoned refusal. Any exceptional extension must be explained to the candidate in writing. No foreign qualification is accepted without verifying regulatory standards.

Section 28 | ART_75KKRPJP569BNM8G | Version 2

A refusal, partial recognition or conditional decision must be written, apply the criteria in sections 25 and 26, give reasons, and be served on the candidate with a list of only the reasonably necessary measures to address substantial gaps, applicable deadlines and available review procedures.

The candidate may seek review in writing within thirty days of notification. A review committee whose members had no part in the original decision examines the file, receives written submissions and offers a meaningful opportunity to be heard. It issues and notifies its reasoned decision within sixty days after a complete review request, subject to an exceptional extension disclosed and justified in writing. Impartiality is required throughout and statutory remedies remain available.

X - RETIRED MEMBER AND RETURN TO PRACTICE

Section 29 | ART_J21PMRANLKMK5SPQ | Version 2

A previously admitted member may request retired status without an age or pension requirement. The member declares cessation of all reserved activities, including unpaid work, and undertakes not to resume without reactivation of practice rights. Retired status may not circumvent suspension, disqualification or practice limits.

Section 30 | ART_JCV1G0DZP1TK5W97 | Version 2

The roll clearly marks “retired member — not entitled to practise”. Only that category may use the exact reserved initials “PSI ret.”. Past competency records and professional accountability remain traceable and are not erased or transferred by retirement. The member’s personal SGN_ identifier is retained for historical attribution and remains non-reassignable. Retirement removes permissions tied to professional practice without deleting or rewriting operations attributable to that identifier; only operations expressly permitted by law may subsequently be authorized and logged.

Section 31 | ART_RXJMU74DUZ44YS17 | Version 3

A retired member files an annual declaration of non-practice and pays $0 in annual base Order dues. Amounts imposed by another statute, including the Office contribution, continue to apply unless expressly and lawfully exempted. Entry on the roll conveys no permanent registry access.

Past signatory status does not reinstate ordinary registry consultation rights for a retired member; only exceptional access under section 19 of the Act and section 54 of the registry regulation remains available. Retirement neither extinguishes responsibility for past work nor erases its documentary history.

Section 32 | ART_UE371D4ZCQ7PWET3 | Version 2

Return to practice is reactivation of practice rights, not a new initial admission. Upon fulfilling objective requirements a member is entitled to resume practising, subject to existing disciplinary measures, statutory limits and other lawful impediments.

Section 33 | ART_WAL4LTRT546FP6W2 | Version 2

Before practising again the member updates required initial or continuing education, completes reasoned proportionate supplementary measures reflecting the interruption and planned activities, pays applicable dues and reinstates professional liability insurance. No professional act may be signed before reactivation is confirmed.

Any individualized refresher requirement must be proportionate to time out of practice, intended activities and verifiable learning, and may be reviewed independently under section 34.

Section 34 | ART_GUCZJLMSM5J5EV9M | Version 2

Individual supplementary education, placement or assessment conditions must state reasons and be independently reviewable. Reinstatement may not be arbitrarily denied once all legal requirements are satisfied.

Section 35 | ART_ZYGNX3J31EGLPCKL | Version 2

This Regulation comes into force on the date determined in accordance with the Act.