The complete proposal.

Persons who hold a permit issued under this Act and are entered on the roll of the Order constitute a professional order designated as the “Ordre professionnel des praticiens en sécurité incendie du Québec”, hereinafter referred to as the “Order”.

The Order may also be designated under the name “Ordre des praticiens en sécurité incendie du Québec” or by the acronym “OPSI”.

The Order is constituted upon the coming into force of the constitutive provisions of this Act, independently of the central registry’s documentary activation. The registry is established by law, but its documentary obligations are implemented later under section 61 (ACT RESPECTING FIRE SAFETY PRACTITIONERS).

Within a single legal person and under its legally competent bodies, the Order carries out its functions of maintaining the roll, administering the central registry, conducting professional inspections, operating the syndic and discipline mechanisms and discharging its other public-protection duties under professional legislation. These functions are not separate bodies and are financed from the Order’s general fund, subject to legally protected amounts.

Subject to the specific provisions of this Act, the Order and its members are governed by the Professional Code (chapter C-26).

The Order is administered by a board of directors formed in the manner provided for in the Professional Code.

The regular board has six elected seats held by eligible members and two seats appointed by the Office des professions under the Professional Code, subject to the mandatory additional mechanism concerning a person aged 35 or younger. The president is elected by secret ballot of the elected and appointed directors from among the six elected directors who stood for an elected seat, using the method in paragraph b of the first paragraph of section 64 of that Code. There is no separate candidacy for a seventh elected presidential seat and no additional elected seat resulting from that election.

In this Act, the following expressions mean:

1° “competent authority”: a municipality, a fire safety service, the Régie du bâtiment du Québec, a department, a public body, or any other person or authority charged by law with enforcing the fire safety requirement concerned;

2° “CBCS”: Chapter VIII — Building of the Safety Code made under the Building Act (chapter B-1.1), in the version made applicable to the building, place, installation, system, equipment or appliance concerned;

3° “CNPI”: the National Fire Code of Canada, in the edition, with the amendments and adaptations made applicable to the building, place, installation, system, equipment or appliance concerned by an applicable Act or regulation, including a municipal by-law, directly or by reference;

4° “applicable fire-safety requirement” means a legally applicable obligation arising from an Act or regulation, including a municipal by-law, directly or through one or more successive references to a code, technical standard or other technical document, including through the CBCS or CNPI;

5° “applicable technical standard” means a standard or other technical document made legally applicable to the case concerned by an applicable fire-safety requirement, directly or through one or more successive references, taking into account the edition, amendments, adaptations and limits of application legally applicable to the case concerned;

6° “authorized person”: a member of the Order or any other person who, under this Act, another Act or a regulation, is authorized to carry out the professional activity concerned;

7° “responsible person”: the owner, operator, manager, employer or any other person responsible for the building, place, system, installation, equipment or fire safety measure concerned;

8° “registry”: the “Registre central de l’Ordre des praticiens en sécurité incendie du Québec” (Central Registry of the Order of Fire Safety Practitioners of Québec), a permanent function administered by the Order under this Act;

Only a person who holds a permit issued by the Order and is entered on its roll may use the title “fire safety practitioner” or the initials “P.S.I.” to designate themselves professionally.

Within the regime established by this Act, the acronym “PDSI” denotes a “fire safety plan” and “PSI” denotes a “fire safety practitioner”. This terminological convention does not prohibit abbreviations lawfully used outside this regime.

The acronym “OPSI” is reserved for the Order.

The exact designation “PSI ret.” is reserved for a person previously admitted to the Order and entered on the roll as a retired member. It expressly identifies a person not entitled to practise under that status and may not be used to sign or approve professional work. The same reserved designation applies in both languages.

An Order membership number remains distinct from technical references assigned to persons by the registry. Such assignment confers neither the PSI professional title, a licence nor a right to practise; the membership number remains the number issued under the applicable professional rules.

The practice of the profession consists in inspecting, testing, assessing and documenting fire safety systems, installations, equipment, appliances and measures; professionally approving the fire safety and evacuation documents provided for by this Act; producing professional reports, assessments, attestations and opinions; and carrying out the other activities provided for by this Act.

The description of the field of practice does not, by itself, reserve every activity that may be related to it.

The board of directors of the Order may, by regulation, establish categories or statuses relating to admission, candidacy, internship, supervision, practice and entry on the roll, and determine the criteria applicable to each category or status.

The regulation may, in particular, determine:

1° the conditions for access to a category or status;

2° the conditions for maintaining, renewing, progressing within, changing or ending a status;

3° the programs of study, training, internships, periods of supervised practice, examinations, assessments or other qualification measures required;

4° the competencies that must be demonstrated;

5° the terms for recognizing prior learning, experience, training, certifications, internships or previous professional practice;

6° the conditions for equivalency or exemption;

7° the duration of a program, internship, supervision period or status, and the terms for extension or renewal;

8° the activities that may be carried out by a person who is not yet a member of the Order and the applicable supervision conditions;

9° the acts that may be signed, authenticated, approved or filed only by a member;

10° the conditions applicable to a member whose practice is temporarily supervised, limited or subject to supervision;

11° the information that may appear on the roll of the Order;

12° any other measure necessary to organize the admission pathway and control competence.

The permit issued by the Order is a single permit.

A member is personally responsible for ensuring that they possess the knowledge, experience, abilities, independence and means necessary before accepting or carrying out a mandate.

Fields of practice, training, competencies, experience or qualifications that may be entered on the roll of the Order do not constitute separate permit categories.

The member remains personally accountable for the professional acts, reports, conclusions and approvals that they perform, sign or endorse, whether self-employed, employed or practising in a firm or multidisciplinary organization. An employer or firm may have physical custody of records in accordance with the regulation on the keeping, retention, transfer and provisional custody of professional records without replacing the member’s judgment.

The regulation made under section 6 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) may provide that any person beginning a new admission pathway must pass through one or more categories or statuses before a permit is issued.

It may also allow the Order to recognize prior training, experience or practice as satisfying all or part of the requirements of a category or status.

No maximum duration for training, an internship or an admission pathway results from this Act. Those durations are determined in accordance with that regulation, based on the pathway and the competencies to be acquired or demonstrated.

The categories and statuses so established do not create separate permits or separate fields of permit.

Where a permit holder is subject to a limitation, a condition of practice or a supervision requirement, it is entered on the roll in the cases provided for by the Professional Code or by regulation.

Entries concerning a member’s right to practise permit the tracing of start and end dates of validity, renewals, suspensions, reinstatements, practice restrictions and the effective dates of those events, according to information lawfully available, without enlarging the scope of the permit.

Subject to the authorizations and exceptions expressly provided by this Act, including section 9 (ACT RESPECTING FIRE SAFETY PRACTITIONERS), the professional activities in this chapter and those concerning professional non-compliance notices specified in section 27 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) are reserved to members of the Order.

This section does not prevent certain operations from being carried out under supervision by a person registered in a category or status established under section 6 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) where the regulation provided for in that same section expressly permits it.

The periodic inspection and testing of a system, installation, equipment, appliance or device are reserved where the following conditions are met:

1° the obligation to carry out the inspection or test arises from an applicable fire-safety requirement;

2° the prescribed interval between inspections or tests is at least three months, including where it is quarterly, semi-annual, annual or longer;

3° the inspection or test concerns:

a) approved fire detection, alarm and signalling systems, appliances and devices, within the limits of their approval and field of application;

b) suppression systems, installations, equipment and appliances using water or another extinguishing agent, whether fixed or portable;

c) safety systems, equipment, appliances and devices intended to facilitate, direct or secure occupant evacuation, including:

i. emergency lighting systems;

ii. exit signs and exit-signalling devices;

iii. smoke-control, smoke-evacuation or smoke-management systems and devices.

Also reserved, where required under an applicable fire-safety requirement, are activities involving professional judgment and responsibility in initial verification following installation, acceptance, functional and commissioning tests, and verifications and tests required after alteration, repair, replacement or return to service.

Integrated testing of the coordinated operation of multiple interconnected systems, installations, equipment or devices is also covered. Where professional judgment is required, the reserved activities include determining the technical scope, preparing or validating procedures, technical direction or supervision, verifying sequences and interactions, analysing results, assessing additional tests and reaching professional conclusions.

Professional responsibility for the overall conclusions of an integrated test rests with one legally authorized and competent person, even where several professionals or other participants perform the work. Each participant remains responsible for their own distinct professional acts.

Mere administrative scheduling, coordination of timetables, physical operations, installation work and the physical performance of tests by authorized persons are not reserved solely by this section. The minimum three-month interval condition does not apply to initial, acceptance, return-to-service or integrated testing.

For verifications, inspections and tests referred to in this section, where the applicable requirement refers, directly or indirectly, to a code, technical standard or other technical document, the intervention is carried out in accordance with the provisions thereby made applicable, taking into account the edition, amendments, adaptations and limits of application legally applicable to the case concerned.

Within the scope of the applicable requirement, the intervention may include presence, condition, accessibility, operation, activation, supervision, signalling, transmission, commands, expected responses and interconnection. Integrated testing may also cover the test plan and sequences, coordinated operation, interaction results, limitations and elements not tested.

Where an element included in the required verification does not meet the applicable requirement, including because a device required to operate does not operate, a device required to be supervised is not supervised, a required transmission, activation or interconnection fails, equipment required to be present is absent where its presence must be verified, or an element cannot be verified, inspected or tested although that intervention is required, the finding falls under the non-compliance regime provided for in Chapter IV.

A verification, inspection or test of that kind does not, merely because it is carried out, impose an obligation to search for or verify conditions that are not among the elements the applicable requirement requires to be verified as part of that intervention.

Preparing, signing or authenticating the professional report resulting from these interventions is also reserved, including a report setting out the overall conclusions of integrated testing. Contributions from other participants may be identified without attributing the overall conclusions to them.

The mere reservation of those activities does not, in itself, make any verification, inspection, test, code provision, technical standard or other technical document applicable.

This reservation does not extend to engineering design, sizing, performance analysis, modification or approval of an engineering work. Engineers and professional technologists are expressly authorized by section 9 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) to perform the activities covered by this section when they have the necessary competence; the rights, duties, competence, signature, reporting, filing, correction and responsibility requirements of this Act apply to them on the same terms.

Where a verification, inspection or test referred to in this section gives rise to a report that must be filed in the registry, no person may issue a certificate or other document that stands in place of the report, dispenses with signing or filing it, conceals any qualification, limitation or non-compliance, or falsely implies general approval of the installation or intervention. A supplementary certification expressly permitted by the regulation made under this section remains authorized within the limits of its own subject matter and subject to these prohibitions.

The professional report signed and filed in the registry remains the official reference document. A supplementary certification does not alter its findings or qualifications and creates no new certification requirement in the absence of another legally applicable requirement.

This section does not prevent the issuance of a professional training or competency attestation provided for in section 12 (ACT RESPECTING FIRE SAFETY PRACTITIONERS).

It does not prevent the issuance of simple proof of training that is not represented as a professional attestation.

It does not prevent a certificate expressly required or authorized by another Act or regulation.

Nor does it apply to a tag, attachment, control mark or other identification affixed directly to a system, installation, equipment, appliance or device where that identification is required or contemplated by an applicable fire-safety requirement or applicable technical standard.

After consulting the Ordre des ingénieurs du Québec and the Ordre des technologues professionnels du Québec, the Order may, by regulation, permit certain certifications supplementary to a professional report, specify the eligible categories and set conditions governing their issuance, presentation and monitoring.

Such certifications remain optional under this Act. They may not replace the report or its filing, conceal its qualifications, limitations or non-compliance findings, certify matters beyond those actually verified, or create a false impression of general approval.

After the same consultations, and in accordance with the rules applicable to the adoption of regulations, the Order may add, amend or remove authorized categories of supplementary certifications. An administrative list may not change categories established by regulation.

This Act expressly authorizes an engineer entered on the roll of the Ordre des ingénieurs du Québec and a professional technologist entered on the roll of the Ordre des technologues professionnels du Québec to perform the same professional activities it reserves or authorizes for fire safety practitioners, provided the individual has the knowledge and competence needed for the activity and no incompatible limitation, suspension or other restriction on the right to practise. This authorization arises from this Act and does not depend on an identical pre-existing authorization under another Act or regulation.

This common authorization includes the inspections, verifications and tests, including initial and integrated tests, and reports covered by section 8 (ACT RESPECTING FIRE SAFETY PRACTITIONERS); approvals of fire safety plans, directions, procedures, floor plans and diagrams under section 10 (ACT RESPECTING FIRE SAFETY PRACTITIONERS); professional exercise evaluations under section 11 (ACT RESPECTING FIRE SAFETY PRACTITIONERS); professional training or competence attestations under section 12 (ACT RESPECTING FIRE SAFETY PRACTITIONERS); and reserved professional non-compliance notice activities under section 27 (ACT RESPECTING FIRE SAFETY PRACTITIONERS). Within the same scope it includes the lawful preparation, signature, authentication, revision, correction, retention, consultation and filing of documents.

For these activities, engineers, professional technologists and fire safety practitioners have the same rights, authorizations and opportunities and the same duties under this Act and its regulations concerning required competence, scope of verification, independence, signature, reports, notices, traceability, deadlines, retention, filing and personal accountability. No difference is based solely on professional title. Each person must refuse or limit work exceeding their actual competence.

Engineers and professional technologists need not join the Order or obtain a PSI permit to perform these activities. They remain registered with their own order and subject to its ethics, insurance, competence oversight, professional inspection and disciplinary regime. This Act transfers no disciplinary authority over them to OPSI and does not exempt them from any legally applicable individual restriction.

The common authorization permits no act that this Act does not authorize a PSI to perform. In particular, it grants no general authority for engineering design, calculation, sizing, modification of an engineering work or construction supervision, and no construction licence or trade qualification. Distinct acts reserved by another Act remain governed by that Act, subject to the express authorizations and legislative amendments provided by this Act.

A member of another professional order or any other person may also perform an activity where authorized by an Act or regulation and competent to do so. This Act preserves those rights without requiring membership in the Order and creates no additional professional right outside its express authorizations.

For documentary verification, the right to practise and any individual restriction are assessed at the dates of the act and signature. Administrative registration in the registry creates neither Order membership nor technical competence; it records the applicable authorization and resulting consultation and filing rights.

Every fire safety plan whose establishment, maintenance, revision or updating constitutes an applicable fire safety requirement must receive professional approval.

The same applies, where required by such an applicable requirement, to:

1° evacuation directions or procedures;

2° diagrams, floor plans or other graphic representations forming part of a fire safety plan or evacuation directions or procedures.

The requirement referred to in this section may arise, in particular:

1° directly from an Act or regulation;

2° from a municipal by-law;

3° from a reference to the CBCS or CNPI contained in an applicable Act or regulation;

4° from a reference made by the CBCS or CNPI to an applicable provision or technical standard.

The professional approval provided for in this section may be given:

1° by a member of the Order who possesses the necessary knowledge and competencies;

2° by an engineer entered on the roll of the Ordre des ingénieurs du Québec or a professional technologist entered on the roll of the Ordre des technologues professionnels du Québec, who possesses the necessary knowledge and competencies;

3° by a member of another professional order or another person where another Act or regulation expressly authorizes that person to give such approval.

The authorization conferred on engineers and professional technologists by subparagraph 2 of the fourth paragraph arises directly from this Act. For the approval referred to in this section, engineers and professional technologists are equally subject to the same requirements concerning competence, prior review, signature, validation, traceability, filing and personal accountability. Professional title alone does not change the scope of, or accountability for, that approval. The same rules apply to the revision, correction and renewal of the approval, and the signatory remains personally accountable for their review and conclusions, regardless of profession.

That authorization does not allow either an engineer or a professional technologist to perform any other activity they are not otherwise authorized to perform, and does not alter the reservation of professional activities under another Act.

Where another Act or regulation requires the involvement of another professional in relation to the same document or one of its elements, that requirement continues to apply.

Professional approval must be renewed following any revision likely to substantially change the content of the document and on any other occasion prescribed by an applicable requirement.

The person responsible for the building shall permanently keep, at the premises to which they apply, an up-to-date physical copy of the approved fire safety plan and any evacuation instructions, procedures and diagrams forming part of it. That copy must be accessible to persons responsible for implementing the plan and to competent authorities in the exercise of their functions, without relying on registry availability. It shall be updated following any applicable revision, subject to the protection of personal information it contains.

The development, preparation, drafting, formatting or material modification of a document referred to in section 10 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) is not, in itself, a reserved activity.

Before giving professional approval, the authorized person must carry out a sufficient review to allow them to assume personal responsibility for that approval and to conclude that the document complies with the applicable requirements within the limits of their mandate and competence.

The person may not give approval solely on the basis of the signature, approval or declaration of the person who prepared the document.

Conducting a fire or evacuation drill required by an applicable fire safety requirement is not a reserved professional activity.

The drill may be organized, directed and conducted by the responsible person, the building manager, supervisory staff or any other person designated for that purpose, subject to any other applicable requirements.

After each required drill, the responsible person must prepare or have prepared a fire or evacuation drill report documenting the conduct of the drill.

The report must contain at least:

1° the building or place concerned;

2° the date and time;

3° the nature of the drill;

4° the sectors or groups of occupants concerned, where applicable;

5° the main observations;

6° the difficulties, anomalies or problems identified;

7° the contemplated follow-up or corrective measures;

8° the name and capacity of the person responsible for the report.

This report is a building-management document.

It is neither a professional attestation, a certification of compliance, nor a professional assessment of the effectiveness of the fire safety plan or evacuation measures.

It is retained with the building’s fire safety documents for the prescribed period.

It must be capable of being produced to a competent authority or authorized person where legally required.

It is not filed in the registry solely by operation of this Act.

Producing a professional report, professional assessment or professional attestation in relation to a fire or evacuation drill is a reserved activity where such involvement:

1° is expressly required by an Act or regulation;

2° is required by a competent authority acting within its powers;

3° is performed under a mandate whose purpose is to professionally assess the conduct of the drill, the application of the fire safety plan, the evacuation procedures or related measures.

The authorized person must clearly distinguish:

1° facts personally observed;

2° information from the drill report or another source;

3° the limits of their involvement;

4° their professional findings and conclusions.

Their presence during the drill is mandatory.

This Act:

1° does not confer any power belonging to a competent authority;

2° does not authorize a member to carry out an activity reserved to another professional except to the extent permitted by law;

(3) subject to the express authorizations in sections 9 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) and 10 (ACT RESPECTING FIRE SAFETY PRACTITIONERS), does not authorize another professional to perform an activity they are not legally authorized to perform;

4° does not authorize the performance of construction, installation, modification, repair or maintenance work for which a licence, qualification, card or authorization is required;

5° does not reserve surveillance rounds, routine visual checks, internal records or purely material or auxiliary operations;

6° does not reserve an exclusively periodic inspection or test for which the prescribed interval is less than three months, subject to an activity reserved by another Act; this exclusion does not apply to initial, acceptance or return-to-service verifications or to integrated tests referred to in section 8 (ACT RESPECTING FIRE SAFETY PRACTITIONERS);

7° does not reserve the organization, conduct or factual documentation of a drill referred to in section 11 (ACT RESPECTING FIRE SAFETY PRACTITIONERS);

8° does not reserve training, teaching, self-training or the issuance of a simple proof of training, subject to the attestation referred to in section 12 (ACT RESPECTING FIRE SAFETY PRACTITIONERS).

9° does not transform a periodic inspection or test into a general verification of compliance of the design, construction, installation or prior modifications where those matters are outside the scope of the applicable requirement or mandate concerned.

The reservation does not make administrative coordination, physical operations or work lawfully within the practice of engineering or licensed contractors exclusive activities of members of the Order.

Training, teaching, coaching, practice, workplace learning and self-training in fire safety are not, in themselves, reserved professional activities.

Any person, employer, educational institution, manufacturer, association or body may offer or provide training, subject to requirements under another Act or regulation.

A person may acquire knowledge or competencies through experience, self-training, internal training, the reading of codes, standards or technical documents, or by any other appropriate method.

Issuing a professional attestation of training or competence for the purposes of this Act is a reserved activity. It may be issued by a member of the Order or by a person referred to in section 9 (ACT RESPECTING FIRE SAFETY PRACTITIONERS), within the limits of that person’s legal authorization and competence.

Such an attestation may concern, in particular:

1° the training or competence of supervisory staff responsible for applying a fire safety plan or evacuation procedures;

2° the training or competence of technical personnel called upon to perform inspections, checks or tests whose prescribed interval is less than three months.

The authorized person is not required to have personally provided the training.

Before issuing the attestation, the authorized person must nevertheless conduct a sufficient assessment of the knowledge or competencies concerned.

That assessment may take into account, in particular:

1° training received from a third party;

2° internal training;

3° experience;

4° prior learning or self-training;

5° a practical demonstration;

6° a written, oral or practical examination;

7° any other reasonable means.

A simple proof of attendance, participation, success or completion may be issued by the trainer.

Such proof does not constitute a professional attestation of competence.

General training of occupants is not reserved.

The Order maintains and administers the Registre central de l’Ordre des praticiens en sécurité incendie du Québec as a permanent part of its public-protection functions.

The registry and its technological platform belong to the Order’s functions. They have no separate legal personality, autonomous institutional administration or separate operating fund. The Order manages them without impairing the powers of its competent bodies or the rights of authorities and authorized persons.

The registry exists and operates exclusively in electronic form. Every official filing is made through its secure electronic interface, its secure application programming interface (API), or, if unavailable, an official electronic fallback mechanism provided by regulation. Email, postal mail, fax, hand delivery or any other channel outside those mechanisms does not constitute an official filing. Only receipt and confirmation by the registry or its official fallback mechanism establish the filing date and time, subject to outage-recovery rules.

Telephone calls and other urgent communications to emergency services or a competent authority remain subject to applicable obligations; they are not official filings and, where an official filing is required, do not dispense with subsequent electronic regularization. Providing information to an authority is distinct from filing it with the registry.

The registry receives and preserves filings, identifies and authenticates authorized persons, protects documents and information, traces operations, manages versions and makes notices available to legally authorized recipients. It receives substantiated danger reports and notices of reportable non-compliance, as well as their supplements, follow-ups, corrections and administrative closures, without charge; an unverified report does not constitute a formal finding of non-compliance.

The Order’s professional roll and the registry remain distinct as to the information they contain, their purposes, their confidentiality regimes and their access conditions. Registry administration does not restrict the right of other legally authorized professionals and persons to file or consult information, or the independence of the syndic or disciplinary bodies.

For each building subject to the Act, the registry maintains a permanent administrative record enabling the legally communicable events and documents to be traced in accordance with the procedures prescribed by regulation.

The electronic filing, consultation and receipt functions made available by the Order must be available through equivalent secure automated means, subject to the same legal entitlements, purposes, authorizations and restrictions; their technical protocols are prescribed by regulation.

The registry is not public.

The documents and information it contains are confidential.

Despite any inconsistent provision of the Professional Code or the Act respecting Access to documents held by public bodies and the Protection of personal information (chapter A-2.1), access to them is governed by this Act and the regulations made for its application.

They may be consulted, used, communicated, extracted or reproduced only by a person legally authorized to do so and for authorized purposes.

The Order may use information contained in the registry to produce anonymized and aggregated statistics for public protection, prevention and improvement of practices.

Those statistics may include the number and type of non-compliances, correction rates and correction times, changes over time, distribution by system type, activity or any other relevant category, and provincial or territorial trends where anonymity can be preserved.

No published or disclosed statistic may reasonably allow a person, professional, owner or building to be identified, directly or indirectly.

Summary or analytical data disclosed to competent authorities for prevention, planning or statistical monitoring shall first be anonymized and, where necessary, aggregated. This requirement does not deprive a competent authority of restricted access to information identifying a particular building where such access is legally authorized and necessary for its monitoring or intervention functions.

Public access is confined to information legally disclosable and to name- or identifier-based verification authorized by law; it does not permit bulk exports of personal information or a broader public roll than the Professional Code allows unless an Act expressly so provides. The regulation provided for in section 33 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) prescribes technical access, source authentication, appropriate logging, outage continuity and synchronization without adding access to confidential files.

Reports requiring verification and disclosures outside a mandate remain confidential within the registry. Only legally authorized recipients may access them, and their verification status must be clearly marked. Unverified facts may not be presented to the public as confirmed non-compliance; disclosure is limited to necessary information and respects professional secrecy, subject to express authorization or an exception provided by law.

As an exception to the confidentiality rule in this section, the Order's public membership roll, the public list of organizations authorized to offer the professional services governed by this Act, and the public directory of competent authorities are made available only within the limits of section 33 (ACT RESPECTING FIRE SAFETY PRACTITIONERS). These three directories are separate from confidential central-registry files and disclose no building report, notice, protected information or other building document.

The registry maintains an integral and verifiable record of operations performed within it, including access to the audit log. The technical recording requirements are prescribed by regulation without granting new access or lifting any confidentiality obligation.

The following must be filed in the registry:

1° professional reports arising from legally required interventions under section 8 (ACT RESPECTING FIRE SAFETY PRACTITIONERS), including the following categories, without prejudice to the required signed or authenticated preliminary report where the final report cannot be filed within the prescribed time:

(a) periodic inspection or verification reports;

(b) initial verification, acceptance or commissioning reports, including those required before putting a system into service;

(c) verification or test reports following alteration, replacement, repair or return to service;

(d) functional test reports addressing operation, commands, activation, signalling and other required functions;

(e) integrated test reports addressing coordinated operation, interactions and the overall professional conclusions for multiple systems, installations or devices;

2° fire safety plans professionally approved in accordance with section 10 (ACT RESPECTING FIRE SAFETY PRACTITIONERS);

3° evacuation directives, procedures, diagrams and documents professionally approved in accordance with that same section;

4° professional reports, assessments or attestations relating to a drill where a professional intervention under section 11 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) is required by an Act, regulation or competent authority;

5° professional attestations concerning compliance, by the person responsible for a building, with applicable staff training or competency requirements, where such an attestation is required;

6° professional notices concerning a non-compliance under documented action or requiring action in accordance with sections 27 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) to 30 (ACT RESPECTING FIRE SAFETY PRACTITIONERS);

7° notices changing the classification of a non-compliance entered in the registry;

8° correction notices and follow-up reports concerning a non-compliance under documented action or requiring action entered in the registry;

9. substantiated reports of danger requiring verification defined in Chapter IV, submitted independently of any professional report or mandate, together with related supporting documents and follow-up communications.

Reporting-exempt non-compliances are not filed in the registry solely because they were identified.

Apparent anomalies recorded in a report referred to in paragraph 1 may form part of the report filed, but their recording does not, by itself, constitute a non-compliance, a non-compliance notice or a separate registry entry.

Individual attestations issued to a natural person under section 12 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) are not filed solely by reason of this Act.

The ordinary drill report provided for in section 11 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) is not filed solely by reason of this Act.

The categories may overlap: a single documented intervention may fall within several categories without requiring multiple artificial reports or filings. This section does not itself require any test or report not otherwise required by the rules lawfully applicable to the building or installation concerned.

No policy, directive, form, guideline or standard of practice may add a category of document for which filing is mandatory.

The list in section 15 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) defines the documentary categories of the full registry; it does not create a filing requirement in an inactive region. Mandatory filing applies only to documents produced from the legal activation date for the region in which the building is situated, with no general retroactive reconstruction of earlier documents.

A substantiated report is a separate, free filing, not an inspection report or a formal non-compliance notice unless and until the facts required for the latter are sufficiently established. Its receipt, subsequent verification and any conversion into a formal notice are recorded separately, without creating a fictitious report or modifying an ordinary report otherwise required.

The regulatory requirements for complete documentary filing and the creation of official building and filing records take effect only when documentary filing becomes legally mandatory in the region concerned. An eligible report declared during the transitional period is not a filing and does not constitute an official filing operation. This restriction does not apply to receipt of documents voluntarily filed in the official registry under section 69 (ACT RESPECTING FIRE SAFETY PRACTITIONERS).

As an exception to the document requirements for a professional report, a substantiated report outside a mandate may be filed as a factual statement giving, at minimum, the reporter's identity and area of competence, the known location or a verifiable approximate location, observed facts or separately identified reliable sources, the nature of the suspected danger, limits of knowledge and verification status. It must expressly state 'Report requiring verification — non-compliance not confirmed' where the applicable requirement or serious-risk threshold cannot yet be established. Neither a full inspection, a mandate nor a professional report may be required as a filing condition. The registry preserves supplements and corrections with their source and timestamp.

A correction, modification or partial review of a current document remains linked to the original filing, without a new fee or postponement of the due date. A separate new filing of a document under paragraphs 1 to 5 requires that the corresponding inspection, verification, testing or professional review have been fully repeated and approved; the applicable fee is then payable again. Where a periodic requirement applies, the new cycle begins on the last day of that work, not on the filing date; the next due date is calculated using that frequency. This rule applies to all those document categories, even if no substantive change is necessary. The registry preserves the documentary chain, work dates, versions and fees paid without erasure.

Every authorized person who professionally produces, signs, authenticates or approves a document referred to in section 15 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) is responsible for filing it in accordance with the central registry of OPSI regulation provided for in section 17 (ACT RESPECTING FIRE SAFETY PRACTITIONERS).

This obligation applies whether the person is a member of the Order, an engineer, a professional technologist, a member of another order or otherwise authorized. Engineers and professional technologists exercising the same authorization under this Act or its regulations are subject, without distinction based on title, to the same requirements concerning documentary validation, authentication, filing, correction and traceability and to the same personal accountability.

In the case of a document referred to in section 10 (ACT RESPECTING FIRE SAFETY PRACTITIONERS), responsibility for filing rests with the person who gives the professional approval.

Another person may carry out the electronic filing operation without transferring professional responsibility.

A filing operation may occur after an authorization has expired, provided the act and signature were lawfully completed at the relevant dates. Filing does not validate an act or signature performed without the required authorization.

For an integrated testing report, the legally authorized person assuming responsibility for the overall conclusions is professionally accountable for them and is identified as such. Professionals responsible for independent parts are identified according to their contributions; a participant who merely performs the testing operations does not thereby assume responsibility for the overall conclusions.

Existing duties to transmit documents to the owner or person responsible continue under the mandate and the law. A duly identified owner, or an authorized representative, may obtain a copy of building documents to which that person is legally entitled even if already supplied. The request is normally made to the professional who prepared or approved the document, or to another professional authorized under section 19 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) whom the owner mandates for this purpose.

A professional who lawfully holds the document or has the necessary access responds to a legitimate request within a reasonable time, using the professional record or the registry. The registry offers mandated and legally authorized professionals a one-off electronic extraction of eligible documents only, after verification of identity, authorization, access entitlement and protection of third parties, with logging. The Order need not manually handle ordinary requests, without prejudice to direct disclosures required by statute or court order. Supplying a copy requires no new inspection. Consultation is free; only reasonable reproduction or transmission costs, disclosed in advance and permitted by law, may be charged. This does not create general access or any new consultation charge.

Until the region concerned is activated, the documentary-filing obligation under section 16 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) and the regulatory requirements under section 16 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) to display building references on document pages are deferred. The monthly administrative declaration under section 64 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) must not be presented as a filing of the professional document in the registry.

For a member of the Order, mandatory filing with the registry does not remove the duty to create and preserve a professional record outside the registry under the regulation on records and transfer. An eligible employer or firm may hold that record without requiring a duplicate personal archive; this rule does not change the recordkeeping duties of professionals governed by other orders.

The reporting duty in Chapter IV may arise for a member of the Order independently of any mandate, signed document or professional report. A substantiated report identifies its author and the known facts; it requires neither a signature purporting to certify an inspection not carried out nor the prior creation of a fee-bearing report. The temporary absence of a registry building number or complete property reference may not prevent an urgent report; the link is regularized as soon as possible. Where the building-ownership prohibition under section 17 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) prevents that person from signing or filing a professional notice, the person fulfils the disclosure duty through a factual report requiring verification, within the same time limits and without waiting for another signatory to act.

The regulation made under section 17 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) applies to every person required to make a filing, whether or not they are a member of the Order.

It may not regulate the competence, professional ethics or professional methods of a member of another order. The registry signature and filing conditions under section 17 (ACT RESPECTING FIRE SAFETY PRACTITIONERS), including those concerning ownership of the building, nevertheless apply to every covered signatory and filer, without giving OPSI disciplinary jurisdiction over members of another order.

A professional document required to be filed must constitute a complete and authenticated documentary unit in accordance with applicable requirements; its format, supporting materials and version procedures are prescribed by regulation. No technical presentation requirement may artificially create a new professional obligation or a new filing fee.

The board of directors of the Order determines, by regulation, the operating arrangements of the registry, subject to the exclusive authority of the Minister responsible for the administration of the Fire Safety Act over registry fees and their collection and refund terms under section 35 (ACT RESPECTING FIRE SAFETY PRACTITIONERS).

The regulation may, in particular, determine:

1° filing deadlines, procedures and proofs, documentary categories, fields, metadata, formats and reasonable file-size limits, including for principal PDFs and supporting exhibits;

2° conditions for signing and filing registry documents, including the prohibition against a person signing, authenticating, approving or filing a professional document concerning a building that the person owns in whole or in part or effectively controls, and methods for identifying, authenticating, validating and electronically signing operations; signing an operation remains distinct from professionally approving the document;

3° corrections, replacements, cancellations, versions, documentary links and due dates, and resumption of operations following an outage;

4° retention periods, integrity, security, confidentiality, traceability and protection of the audit log, including logging access to the log itself;

5° access through an application programming interface, authorizations, use limits, suspensions and revocations;

6° methods and thresholds for producing, anonymizing, aggregating, publishing and disclosing statistics under section 14 (ACT RESPECTING FIRE SAFETY PRACTITIONERS);

7° making notices available, notifications, delivery failures, reminders, the distinction between consultation and acknowledgment, and the contingency directory and procedures;

8° the identification keys necessary for registry operations, including keys for buildings, filings, supporting exhibits and competent authorities, without limiting other useful categories, and the rules governing their assignment, historical links and geographic metadata, including provenance, accuracy and verification;

9° exclusively technical procedures for billing, payment confirmation, accounting reconciliation and processing refunds of lawfully established charges for the professional documents listed in paragraphs 1° to 5° of section 15 (ACT RESPECTING FIRE SAFETY PRACTITIONERS), without amending the collection or refund rules established by the Minister referred to in the first paragraph.

This regulation may not create, change or increase a fee or impose incidental charges for a danger report, a notice of reportable non-compliance or their supplements, corrections, follow-ups and administrative closures. It may not extend rights of access or diminish the confidentiality guarantees established by law.

The regulation may assign preparation and revision of a registry technical specification to the technical committee, subject to board approval and publication with its version number and effective date. The specification sets out formats, protocols and interoperability arrangements; it cannot alter statutory or regulatory duties, legal deadlines, fees, access rights, retention periods or confidentiality and traceability safeguards.

Every filing, transmission and communication expressly required by this Act is authorized and mandatory notwithstanding professional secrecy.

Only information reasonably necessary is communicated.

A member of the Order or any other person authorized under this Act, another Act or a regulation to perform a professional activity giving rise to the filing of a document in the registry may consult the registry where access is necessary to carry out a professional mandate within the scope of that person’s authorization or a function provided for by law. This right applies even if the mandate requires no filing and no document has yet been prepared. Merely uploading a document on another person’s behalf does not confer this right.

Such persons may also consult the registry before a mandate is concluded in response to a prior, express and verifiable request for an offer of professional services or an assessment of a contemplated mandate, made by the building owner, its manager or their duly authorized representative. Consultation may be used to assess their competence, capacity or availability, evaluate the feasibility of the contemplated services, determine the nature or scope of the mandate, or prepare an offer free of charge, on a time-and-materials basis, at a fixed price or on any other basis. No price, offer eventually submitted or mandate ultimately concluded is required. The request must concern a specified building and an identifiable professional need, without requiring that the services already be precisely defined.

Before consultation, the user must declare their identity, professional capacity, basis of authorization, the building concerned and purpose of access. For an existing mandate, the user must provide a verifiable reference to that mandate; for a prior request, the date and verifiable reference of the request and the requester’s identity and capacity must be declared. Consultation is read-only and limited to information objectively necessary for the stated purpose, within the applicable disclosure rights of the function performed or of the principal or requester. Neither professional authorization, the mandate nor the request overrides professional secrecy or a legal access restriction.

Consultations and extractions are authenticated and logged. This section permits no general, permanent or bulk access. Consultation in preparation for an offer of services remains occasional and restricted to the building concerned and the verifiable request; it is available through the registry interface or the application programming interface under section 13 (ACT RESPECTING FIRE SAFETY PRACTITIONERS), on the same terms. Neither channel may be used to search automatically for prospective clients, solicit business or conduct unauthorized bulk extractions. For an existing mandate, access through either channel is subject to the same professional and legal limits.

It is prohibited to consult the registry, its indexes or its metadata to identify prospective clients, obtain an owner’s or manager’s contact details in order to solicit them, ask whether they would like an offer of services or send an unsolicited offer. Using or reusing for such purposes information obtained during access authorized for another reason is also prohibited. A request obtained after a prohibited consultation does not retroactively legitimize that consultation. Consultations and disclosures expressly required by law remain governed by their own conditions.

A legally authorized professional who has signed or professionally approved a document filed in the registry retains a personal right to consult that document and its relevant versions or rectifications for the legally applicable retention period, even after employment or the mandate has ended. This right is separate from the former employer’s access or access based on a current mandate and is limited to professional acts for which that person is accountable and to a legitimate purpose, including verifying their work, responding to a complaint or cooperating with a professional inspection. It provides no access to former clients’ entire files, subsequent work by other professionals or unrelated commercial information. Professional secrecy, confidentiality, lawful access restrictions and audit logging continue to apply; this right cannot be used to solicit or divert clients.

As an exception to the personal signatory right in this section, a person entered as a retired member has no permanent, general or search access to the registry merely because of earlier signatures. The person may obtain only reasoned, temporary and narrowly scoped access to documents required to exercise a legally protected right, including defence in disciplinary, civil, administrative or judicial proceedings, on approval by a competent authority, normally on a read-only basis, with logging, expiry and automatic revocation. Mandatory disclosures and court orders continue to be respected. This exception does not restrict the personal signatory right under this section of other legally authorized signatories. Where exceptional access is granted, it may be exercised through the interface or application programming interface under the same authorizations and restrictions, without creating independent access through either channel. The registry permanently preserves the attribution of past operations to the former signatory. Retaining that identity does not grant any new right to sign a professional act or access the registry; any exceptional operation permitted by law must be personally authenticated under that same identifier and restricted to the authorization granted.

The Régie du bâtiment du Québec has, as of right, permanent read-only access to the entire central registry throughout Québec, regardless of the competent authority normally responsible for any particular building. This access includes, in particular, filed reports, plans and other documents, declared non-compliances, their classifications, statuses and histories, follow-up and correction notices, and previous versions. This access right belongs to the Régie as a body, not indiscriminately to all its employees. It is exercised by expressly designated persons within their functions and mandates, which may justify full individual access to the entire registry. Administrative confirmations “Flag seen”, “Notice consulted” and “Acknowledged” relating to notices of which the Régie is a recipient under section 20 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) are not amendments to a professional record and remain permitted notwithstanding read-only access. Use of the interface and API remains subject to confidentiality, security, purpose limitation and audit logging requirements under this Act.

The Régie has a province-wide dashboard, also accessible by API in accordance with the regulatory terms, allowing it to search and monitor records and obtain statistics by municipality, administrative region, building category, type of non-compliance, status and age of records. This access does not authorize the Régie to modify records, change their classifications or close them.

Where supplementary routing to the Régie applies to a building, the Régie du bâtiment du Québec receives, for every area giving rise to that classification, the same notices and reports that the competent authority would normally receive: initial non-compliance notices, notices “requiring action” or “under action”, substantiated reports requiring verification, changes of classification or status, follow-up and correction notices, including automatic notices triggered when a deadline expires. The registry makes them available to the Régie and performs the same supplementary notifications, delivery-failure checks and reminders upon the same events and within the same time limits, through both dashboard and API, as for a competent authority recipient.

Where the Régie is already legally the competent authority, it receives these notices in that capacity without duplicate delivery. In an institutional conflict, the competent authority continues receiving its ordinary notices and the Régie receives them simultaneously. Where no competent authority is declared, the Régie remains a recipient even if no other authority is designated. This administrative classification does not divert notices from an unrelated regulatory area to the Régie; no notice may be lost for lack of a recipient. Withdrawal from deciding a challenge is governed by section 31 (ACT RESPECTING FIRE SAFETY PRACTITIONERS).

Ordinary tracking flags, including “new notice”, “Flag seen”, “Notice consulted” and “Acknowledged”, remain distinct from the routing rules for the Régie. They are available to the Régie for notices of which it is a recipient on the same terms as for a competent authority, with separate recipient-specific timestamps and audit history. Confirming consultation or acknowledgment does not change documents and is neither approval of a finding nor mandatory intervention.

The Régie’s province-wide dashboard and API identify buildings subject to supplementary routing to the Régie, applicable grounds and relevant regulatory areas. Sources used for classification, changes in conditions, successive categories, transmissions and their timestamps are preserved in the permanent history. Rectification ends the current supplementary routing once no ground remains, without erasing prior events and without requiring a separate classification flag or manual entry.

These rules do not change non-compliance classifications, deadlines, professional duties or the statutory jurisdictions of authorities. They grant the Order no power to adjudicate jurisdiction and, subject to the decision-making power under section 31 (ACT RESPECTING FIRE SAFETY PRACTITIONERS), create no new Régie investigation, intervention or sanction power or duty. No classification, missing-document alert or consultation charge may be improperly triggered in a legally inactive region; no fee is payable for an unavailable service.

The Minister responsible for the administration of the Building Act (chapter B-1.1) may, by regulation, add any ground for supplementary routing of notices to the Régie for any reason that Minister considers sufficient. The regulation specifies verifiable criteria, relevant regulatory areas, authorized administrative sources, commencement, termination and transitional measures needed to avoid alerts based on provisional information. It does not permit arbitrary designation of an individual building by a non-regulatory decision and creates no new intervention power.

Solely for the purposes of an official investigation or inquest within their lawful duties, the coroner responsible for that investigation or inquest and a duly authorized member of a police force have equal rights, conditions and restrictions to read-only access to registry records and information directly relevant and necessary to the matter concerned. Each access requires identification of the person, the organization on whose behalf the person acts and the particular investigation or inquest justifying access; it remains subject to any judicial or other authorization required by law.

To the extent relevant and necessary for that matter, such access may include reports, plans, notices and supporting documents, successive document versions, amendment histories and corresponding audit-log entries, including the audit trail for consultations of that log. The Order shall make authorized records available securely and, when legally permitted, as readable and usable copies, without enlarging the authorized scope.

Authorization is personal, limited to the identified investigation or inquest and withdrawn as soon as it is no longer needed. It grants no general or permanent access, exploratory searches or right to alter, delete, reclassify or close records or notices. Every search, consultation, authorized extraction and transmission is authenticated, justified and logged under section 14 (ACT RESPECTING FIRE SAFETY PRACTITIONERS).

Information obtained may be used only for the investigation or inquest justifying access, subject to other disclosures, uses, retention measures and obligations permitted or required by law. This provision creates no additional investigative power, waives no legally required authorization and restricts no power to obtain documents or evidence granted by another Act or judicial order.

The Minister responsible for the administration of the Fire Safety Act administers the other access categories, subject to rights granted directly by law.

The Minister may, in particular, authorize access for:

1° engineers, professional technologists and members of other professional orders;

2° municipalities;

3° fire safety services;

4° departments and bodies;

5° competent authorities;

6° insurers, within the strict limits set out in section 23 (ACT RESPECTING FIRE SAFETY PRACTITIONERS);

(7) delegated central labour organizations and legally representative independent associations, within the strict limits of section 24 (ACT RESPECTING FIRE SAFETY PRACTITIONERS);

8° other categories determined by the regulation on external access under section 42 (ACT RESPECTING FIRE SAFETY PRACTITIONERS).

An insurer's access is strictly limited, for a building it insures or is considering insuring, to the existence of a currently effective non-compliance notice requiring action, the nature of that non-compliance and the correction deadline stated in the notice. Merely seeking a new professional assessment does not suspend the notice's status or effects.

Under that access, the insurer has no access to any professional report, plan, reporting-exempt non-compliance or non-compliance under documented action, note, supporting document, identity of the professional, or any other information contained in the registry.

When a non-compliance carrying status “non-compliance requiring action” validly changes to status “non-compliance under documented action”, or a person authorized to identify the non-compliance concerned files a correction notice, the notice ceases to be accessible to the insurer under this section.

The Minister responsible for the administration of the Fire Safety Act may not, by regulation or authorization, broaden an insurer’s access beyond the information provided for in this section.

For a building it currently insures, an insurer may consult only the information specified in this section through the regular interface or the application programming interface, according to its authorizations. For a building it is only considering insuring, it may also make a targeted consultation through either channel after authentication, identification of the building, and declaration of a genuine insurance application file and its purpose. Consultation permits no prospecting, automated querying of multiple buildings or bulk extraction. Every access is logged. The systematic accumulation of results to build a parallel private history, retention unrelated to the application, unauthorized resale or redistribution, and reuse without legal grounds are prohibited. Only retention strictly necessary for the insurance decision and legal evidentiary or retention duties remains permitted, including, where applicable, under section 11 of the Act respecting the protection of personal information in the private sector (chapter P-39.1). The choice of channel never changes the information that may be disclosed.

To apply the protection enacted by section 48 (ACT RESPECTING FIRE SAFETY PRACTITIONERS), the insurer also receives only an indication of whether the current notice resulted from an incidental discovery. This indication comes from the ‘Origin of finding’ metadata and provides no access to the mandate, report, supporting documents, professional’s identity or reason for a new assessment. Before any premium increase specifically attributable to such an incidental notice, the insurer must comply with the prior telephone contact and three-day grace period provided by that provision.

For a specified building where legally represented workers are currently present or assigned, read-only access to the existence of a current non-compliance notice requiring action, its nature and its recorded correction deadline may be granted to: (1) a central labour organization to which the association accredited or otherwise legally authorized to represent those workers has expressly delegated the exercise of this right; (2) an association accredited or otherwise legally authorized to represent those workers that is affiliated with no central labour organization. The right depends on legal representation and current presence in that building, not merely on industry, region or worker status.

An affiliated association exercises this right exclusively through its central labour organization and must have delegated its exercise in writing. The registry verifies affiliation, delegation, scope and validity; it does not simultaneously grant autonomous access to the affiliated association, local branches or delegates. An independent association establishes its legal representation authority and absence of affiliation with a central labour organization. An affiliation or delegation ending or changing triggers immediate reassessment of access and prohibits duplication.

Before access is granted, the applicant organization provides verifiable evidence of its identity and standing, the association’s connection to the represented workers and their current presence or assignment in the building, with the relevant validity period. The regulation specifies proportionate evidence reviewed regularly, without requiring workers’ identities by default. An unverifiable declaration is insufficient.

Each eligible organization nominates the individuals who exercise this right in their duties. Access is individual, limited, revocable and logged. Anonymous shared accounts and personal access granted solely because someone is a worker, union member or local delegate are prohibited. The registry remains non-public.

Consultation is exclusively for preventing fire risks affecting the represented workers’ safety and carrying out the corresponding legal representation duties. It confers no power to modify, reclassify or close a notice, direct the owner or competent authority, or exercise inspection or enforcement powers not provided by another Act.

No professional report, plan, non-compliance being addressed or exempt from reporting, supporting document, note, history, professional identity, worker personal information or other registry information is disclosed under this right. Requesting a new professional assessment suspends neither the notice’s status nor its effects.

Access to a notice ends as soon as it no longer has the status requiring action, including following valid action being taken or an admissible correction notice. If the eligible organization consulted the notice and retains a valid building connection, the registry may send a minimal notification identifying the notice, building and date and time that status ended, without disclosing the new status, reason, document or author’s identity.

Access to a building is suspended when evidence of representation, required delegation or presence becomes insufficient or outdated, and revoked when the conditions cease to be met. Recorded consultations remain auditable without conferring historical access. Affiliation, delegation, scope and notification data are retained only as long as legally necessary, then erased or anonymized subject to applicable rules.

Consultation may use the registry interface or an authorized API under the same data and scope restrictions, individual authentication, purpose justification and operation logging. General searches, building scans, bulk extraction, parallel notice files, resale, redistribution and incompatible reuse are prohibited. Only isolated retention strictly necessary to exercise a right or meet a legal obligation is permitted.

The minister responsible for the administration of the Fire Safety Act cannot expand this right by regulation or authorization beyond the information, buildings, persons and purposes specified in this section. It applies only where the relevant regional documentary registry function is legally activated and available.

Every competent authority in relation to a covered building declares to the registry, by relevant regulatory domain, the buildings over which it legally has jurisdiction and every new assignment, change or cessation of that jurisdiction. Several authorities, including several municipalities, may be associated with the same building in distinct domains or under concurrent jurisdiction. Intermunicipal agreements and transfers of responsibility are recorded on the basis of the declarations received.

An authority may declare that its jurisdiction has ended without naming a successor. The registry preserves all declarations and dates, does not determine jurisdictional disputes and neither grants nor removes legal jurisdiction. Neither the location of the main entrance nor the location of the 911 call-receiving centre automatically determines regulatory jurisdiction.

The regulation governing administrative transmissions sets out procedures for identifying buildings, determining recipients and communicating events, without conferring on a competent authority any jurisdiction not granted by law.

The Minister responsible for the administration of the Fire Safety Act may delegate to a professional order, municipality, fire safety service or public body the management of access granted to persons under its authority.

The delegate body identifies expressly authorized persons and sets each person’s access scope according to their duties and mandate, including relevant territories, building classes, documents, functions, categories of information and API operations. When legally justified by the mandate, an individual authorization may cover the entire registry. Grants, changes, suspensions and withdrawals are recorded and periodically reviewed; every consultation remains authenticated, justified and logged. Delegation does not confer any power to alter, reclassify or close a notice without separate statutory authority.

The Order remains responsible for access by its members.

Delegated access under this section normally takes effect for documentary files in a region once that region is legally activated. Until completion of regional deployment, legally authorized limited early access before activation of a region is an exception, subject to any authorization required from that Minister and without prejudice to rights granted by another Act.

For the purposes of this chapter:

1. 'non-compliance' means a sufficiently established failure to meet an applicable fire-safety requirement, found by a legally authorized person within that person's competence. The finding may arise in an activity or mandate covering verification of the requirement or, without a general inspection, from an incidental discovery supported by facts sufficiently reliable to establish the unmet requirement. In an inspection or test under section 8 (ACT RESPECTING FIRE SAFETY PRACTITIONERS), the finding falls within this definition where the applicable requirement called for that element to be verified;

2° “reporting-exempt non-compliance” means a non-compliance that does not reach the serious-risk threshold applicable to non-compliances under documented action or requiring action and that remains recorded in the professional report when it falls within the mandate, without being filed in the registry solely because it was identified;

3° “non-compliance under documented action” means a non-compliance that reaches the serious-risk threshold prescribed by the regulation made under section 30 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) and for which, at the time of assessment, immediate, serious, credible and documented handling exists on the part of the owner or responsible person, such that it is reasonable to allow correction within the applicable period; this classification means credible and documented handling exists, not that the non-compliance has been corrected;

4° “non-compliance requiring action” means a non-compliance that reaches the same serious-risk threshold as a non-compliance under documented action but for which no sufficient immediate, serious and credible handling is established, or whose handling has ceased, become insufficient or failed to result in verified correction within the applicable period;

5° “apparent anomaly” means a condition, absence, omission, arrangement or configuration observed during an intervention where verification of it was not part of the required inspection or test or the scope of the mandate and that appears capable of affecting a fire-safety function or warranting further verification.

6. 'substantiated report of danger requiring verification' means a communication separate from a formal non-compliance notice, based on directly observed facts or identifiable and sufficiently reliable information giving serious, objectively grounded reasons to fear a situation meeting the reportability criteria, although compliance or classification cannot lawfully be established from the available observations;

7. 'disclosure' means filing, without charge, a substantiated report or a formal notice of reportable non-compliance, together with their supplements and follow-ups, independently of any eligible professional report that may also be produced concerning the same facts.

Subject to the authorizations and exceptions in section 9 (ACT RESPECTING FIRE SAFETY PRACTITIONERS), the preparation, signature and authentication of a professional notice classifying reportable non-compliance as being addressed or requiring action, its reclassification, professional verification of correction and preparation and signature of professional conclusions supporting its correction, reasoned withdrawal or closure under this Act are reserved to members of the Order. This reservation also applies outside a mandate when the requirements for a formal notice are met. It does not reserve factual communication of a danger, a substantiated report requiring verification, physical corrective work or a competent authority’s own powers.

Where non-compliance reaches the serious-risk threshold and no immediate, serious, credible and documented handling is established, the authorized person classifies it as 'requiring action' under the regulation made pursuant to section 30 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) and acts without delay. Findings within a mandate or legally assigned activity are subject to the communication process under section 29 (ACT RESPECTING FIRE SAFETY PRACTITIONERS); for an incidental discovery, neither the absence of that process nor the absence of an owner's response prevents a sufficiently substantiated notice.

The person must:

1° for a finding within the verification scope of the mandate or assigned activity, inform the responsible person of the classification or, if that person cannot be reached, record unsuccessful contact attempts; for an incidental discovery, neither prior communication with that person nor any attempt to contact them is required;

2° file a notice in the registry as soon as possible and no later than 24 hours after the non-compliance and attainment of the serious-risk threshold are sufficiently established, without waiting for a response or award of a corrective mandate;

3° state in the notice the nature of the non-compliance and a correction period compatible with the urgency and severity of the situation.

A formal notice may be prepared and filed outside a mandate where the person is legally authorized, has sufficient information to find and classify the non-compliance and specifies the limits of the verification performed; neither a full inspection, a mandate nor a professional report is a filing condition. If those facts are insufficient but the authorized person has serious and objectively grounded reasons to fear a reportable danger, that person instead files a free report requiring verification within the same promptness and 24-hour maximum counted from sufficiently substantiated knowledge. This provisional filing is not an official classification and may not impose an unverified correction deadline. Any later formal filing remains separate and free; payment never delays the communication.

The follow-up, correction, reclassification and closure of non-compliance recorded in the registry remain available under the applicable legal rules, without erasure of the earlier finding or any presumption of compliance arising solely from a computerized operation.

Where an authorized person identifies non-compliance reaching the serious-risk threshold within the verification scope of a mandate or legally assigned activity, the person promptly informs the owner or responsible person of the nature and seriousness of the risk and that a notice will be filed in the registry, whether or not corrective work is entrusted to the person making the finding. The authorized person seeks information about measures taken or contemplated to remedy the situation, without requiring the corrective work to be entrusted to them. The date and means of communication, the response received or unsuccessful attempts to make contact are recorded.

At the conclusion of that process, where immediate, serious, credible and documented handling is established, the non-compliance is classified as 'under documented action' and the responsible person is informed in writing of the classification, expected measures and a reasonable correction period. Otherwise, including where no response can be obtained in time, it is classified as 'requiring action'. Refusal to award a corrective mandate to the person making the finding does not, by itself, establish an absence of adequate handling.

The corresponding notice is filed as soon as possible and no later than 24 hours after the non-compliance and attainment of the serious-risk threshold are sufficiently established. Communications and discussions concerning corrective work, a lack of response and completion of the professional report do not extend that deadline or delay emergency measures or communications otherwise required.

The person briefly documents the elements supporting the conclusion that the handling is immediate, serious and credible, including the commitment expressed by the responsible person, steps undertaken, the announced timetable and, where required by the risk, temporary or compensatory measures in place.

The period is determined having regard in particular to:

1° the level of risk;

2° the safety function affected;

3° the occupancy;

4° the number and vulnerability of occupants;

5° the extent of the situation;

6° redundancies or compensatory measures;

7° the expected duration;

8° the seriousness and reasonably foreseeable progress of the handling;

9° the reasonable complexity of corrective measures.

The period may not exceed 30 days except with written justification.

It may not exceed 60 days.

The period does not constitute any derogation from the applicable requirement, and classification as a non-compliance under documented action does not mean that the non-compliance is intrinsically less severe than a non-compliance requiring action.

This section applies to central-registry operations in the region concerned only from its legal activation; it neither suspends nor replaces hazardous-situation reporting duties or public-authority powers arising under other laws.

The communication duties in the first two paragraphs do not apply to an incidental discovery outside the assigned verification scope, including one made during another mandate or without a mandate. The reporting person need not contact or attempt to contact the owner or responsible person before filing merely because of such a discovery. If the non-compliance and serious-risk threshold are sufficiently established, the person may immediately file a notice 'requiring action' where no immediate, serious, credible and documented handling is known to them; the notice records the incidental origin and the limits of available information, without claiming that the absence of handling has been verified with the owner. Handling already established by reliable information is assessed under the ordinary criteria. Where the facts do not legally establish the non-compliance or threshold, an authorized person subject to the disclosure duty instead files a substantiated report 'requiring verification' under section 27 (ACT RESPECTING FIRE SAFETY PRACTITIONERS). The 24-hour maximum, emergency measures and any direct communication independently required by another law continue to apply.

Unavailability of the registry does not suspend legally required urgent communications or the duty to report a serious danger. Backup procedures and subsequent electronic regularization are prescribed by regulation without altering mandatory time limits established by law.

The board of directors of the Order shall, by regulation, determine the serious-risk threshold applicable to non-compliances under documented action and non-compliances requiring action, the criteria for distinguishing those classifications according to the state of handling, the criteria for classifying reporting-exempt non-compliances, the terms for recording apparent anomalies in professional reports, and the terms for registry filing, display in the competent authority dashboard, setting periods, verification of correction, changes of classification, reclassification, independent professional reassessment, correction, reasoned professional withdrawal of an insufficiently substantiated notice and professional follow-up.

The regulation may establish application guidelines, assessment factors, grids, examples or presumptions to guide professional judgment, including regarding the serious-risk threshold, the immediate, serious and credible nature of the handling, reasonable progress of corrective measures, compensatory measures, the effect of the passage of time and occupancies involving particular vulnerability.

The regulation applies to every authorized person subject to this chapter, whether or not that person is a member of the Order.

It may not have the effect of removing from a legally authorized person the right to classify, change the status of, reclassify or verify the correction of a non-compliance within the limits of the person’s authorization and competence, subject to the signature and filing conditions under section 17 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) and the procedure for challenging reportability on unchanged facts in section 31 (ACT RESPECTING FIRE SAFETY PRACTITIONERS).

Any person directly concerned by a notice of non-compliance under documented action or requiring action may commission another legally authorized and competent person to examine the situation. That person makes an independent professional assessment, within the scope of the facts and verifications available, and assumes full professional and ethical responsibility for it. The registry records that new assessment and its consequences; neither the registry nor the Order adjudicates the substance of the non-compliance or a professional's responsibility through an administrative review procedure.

In assessing the risk and, where appropriate, justifying a new classification, that person may consider in particular:

1° the importance of the safety function affected;

2° the extent of loss of function;

3° redundancy;

4° compensatory measures;

5° the type of occupancy;

6° the number and vulnerability of occupants;

7° means of egress;

8° reasonably foreseeable consequences;

9° the duration of the situation or the age of a document or verification where relevant to risk;

10° the accumulation of several non-compliances;

11° the existence of corrective steps or work and their progress;

12° the immediate, serious and credible nature of the commitment and attention provided by the owner or responsible person;

13° changes to the building, occupancy, systems or occupant vulnerability since the last relevant verification.

The mere passage of time, an administrative delay or the age of a document does not automatically create a non-compliance under documented action or requiring action. They may, however, contribute to the risk assessment where they have a real effect on fire safety in the circumstances.

The regulation may not make the choice of provider, award of a corrective mandate, negotiation of a price or any other commercial interest a criterion for classification, maintenance or change of classification.

It may not automatically classify non-compliance as being addressed or requiring action, except for conversion on expiry from being addressed to requiring action under the regulation made pursuant to section 30 (ACT RESPECTING FIRE SAFETY PRACTITIONERS), nor alter an applicable compliance requirement.

Each reclassification, finding that corrective action has been completed, or reasoned finding that the notice lacked sufficient grounds must be signed by the authorized person assuming responsibility, stating the scope of the verification, supporting reasons and date of findings. The registry links the operation to the original notice, updates its status in accordance with applicable rules, and preserves all earlier versions and signatories without erasure. A new assessment does not in itself presume fault by the original signatory or suspend legally required safety measures.

Every new professional assessment of an already recorded reportable non-compliance must state in a separate metadata field whether it results from a change in the facts or circumstances, a disagreement between professionals about the same facts, or both. Its author identifies the notice and conclusions concerned, explains the new elements or point of disagreement and specifies the scope of the checks performed. This indication creates no non-compliance category, administrative review procedure or presumption of fault, and does not suspend any effect of the notice.

Where another authorized person disputes, on unchanged facts, that the finding met the legal conditions for mandatorily reportable non-compliance, that person discusses the matter with the signatory of the disputed conclusion and records their agreement on the proposed reclassification or withdrawal. Without documented agreement, including where that signatory cannot be reached despite reasonable efforts, the assessments and grounds of disagreement are submitted to the authority competent for the requirement concerned.

A competent authority that directly or indirectly owns, manages or operates the building withdraws from this decision and forwards the challenge to the Régie du bâtiment du Québec. If no competent authority is identified in the registry for the requirement concerned, or if it refuses to decide, the challenge is also forwarded to the Régie, which is authorized to decide it. If the Régie refuses to decide or is itself in that institutional-conflict situation, the challenge is forwarded to the Minister responsible for the administration of the Fire Safety Act, who must decide it. The person deciding the matter must not have participated in managing the building or in the disputed assessment.

The decision is reasoned and made after the professionals concerned and the responsible person have had an opportunity to submit observations; the registry gives effect to that decision upon receipt. The challenge alone does not alter the notice or prevent subsequent developments, automatic conversions or required safety measures from being recorded or taking effect. The decision does not determine professional liability and remains subject to applicable remedies.

A documented change in facts, including newly credible action, compensatory measures, deterioration, verified correction or a requirement becoming inapplicable, allows an authorized person to update the status or close the notice under the applicable rules without the previous signatory’s agreement or a prior authority decision. The development is dated and justified without rewriting the earlier finding; a mere challenge to its merits cannot be presented as a change in circumstances.

No person may prevent or attempt to prevent another person from complying with an obligation to file, give notice, correct or reclassify under this Act.

Any contractual clause having that object or effect is without effect.

Reprisals are prohibited.

A person who makes a mandatory communication in good faith may not be sued for that reason alone. In particular, where the registry and its electronic fallback mechanisms are unavailable, a reasonable, documented mistake concerning the identity or contact details of the recipient authority for a telephone report does not, by itself, constitute an offence or disciplinary fault, including for an authorized professional governed by another professional order, in the absence of a separate fault. This protection does not extend to bad faith, falsification or deliberate failure to make another legally required communication, and does not alter independent duties under other laws.

A substantiated or formal disclosure made in good faith under this Chapter may not, merely because no mandate, professional report or remuneration exists, constitute professional misconduct by a member of the Order. No reprisal may be imposed for the report alone. This protection authorizes neither entry onto private property without consent, nor disclosure of information subject to professional secrecy without consent or an express legislative authorization, nor a knowingly false statement or one made with gross disregard for the facts. It does not deprive affected persons of correction procedures or authorities of their legal powers.

This section applies to central-registry operations in the region concerned only from its legal activation; it neither suspends nor replaces hazardous-situation reporting duties or public-authority powers arising under other laws.

In addition to the regulations provided for by the Professional Code and sections 6 (ACT RESPECTING FIRE SAFETY PRACTITIONERS), 17 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) and 30 (ACT RESPECTING FIRE SAFETY PRACTITIONERS), the board of directors may, by regulation:

1° establish standards of practice for its members;

2° determine the terms relating to the membership card;

3° determine the fields of practice, training, experience or qualifications that may be displayed on the roll;

4° regulate the records, reports, signatures, approvals, attestations and authentications of its members;

5° specify material or auxiliary operations;

6° determine the assessment methods applicable to professional attestations of training or competence;

7° determine the practice requirements applicable to the approval provided for in section 10 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) and the assessments referred to in section 11 (ACT RESPECTING FIRE SAFETY PRACTITIONERS);

8° determine the criteria and procedures for the non-compliance regime mentioned in the first paragraph;

9° take any other measure within its jurisdiction.

No regulation of the Order may:

1° create a new fundamental category of reserved activity;

2° make applicable a code or standard that is not otherwise applicable;

3° modify an applicable edition or adaptation of a code or standard;

4° modify professional rights recognized by another Act;

5° impose the Order’s code of ethics on a member of another order;

6° reserve training or teaching where it is not otherwise reserved.

Within the powers conferred by the Professional Code, including powers concerning recordkeeping, preservation and transfer and practice through firms, the Order may prescribe proportionate conditions for its members’ practice within organizations. The Order neither issues general contractor licences nor disciplines members of another professional order.

The board maintains the official register of organizations authorized to offer, in their own name, professional services reserved by this Act. It records each organization's identity and business number, ordinary authorization or permanent transitional entitlement under section 73 (ACT RESPECTING FIRE SAFETY PRACTITIONERS), authorization status and relevant dates, and the professional delegate when required. An organization's registration never entitles it personally to perform a reserved act, which remains reserved to legally authorized individuals.

The Order maintains, or causes to be maintained under its responsibility, three distinct verification directories: (1) legally public information from its membership roll, including practice status and limitations; (2) authorized organizations, including holders of permanent transitional entitlements, their status, relevant dates and, where the law permits, the designated PSI professional delegate; and (3) competent authorities, with their declared territories, fields of jurisdiction and official business contact details. A directory listing is not a technical assessment of a building; the absence of an organization does not prohibit non-reserved work or work lawful under another statutory regime.

The three directories are available as an operational copy within the central registry and as a public version on a second server, physically or logically independent from the central registry filing and consultation infrastructure, with its own database and autonomous public service. The public version remains accessible during a central-registry outage; it displays the source, last verified synchronization time and currency limits. Suspensions, removals, withdrawals and restrictions are securely and verifiably synchronized as a priority.

The board may, by regulation and within the Professional Code, prescribe declarations, undertakings, insurance, respondents, delegation of professional judgment, registration, verification, transfer and termination for professional organizations, subject to statutory safeguards and the permanent transitional entitlement in section 73 (ACT RESPECTING FIRE SAFETY PRACTITIONERS).

Solely for the ownership of voting rights, governing-body composition and quorum conditions applicable to a professional organization in the ordinary regime, the board of directors may, in a regulation on practice in organizations and multidisciplinarity, determine which persons are eligible and incorporate by reference Schedule A to the Regulation respecting the practice of the profession of advocate within a partnership or a joint-stock company and in multidisciplinarity (chapter B-1, r. 9), as amended from time to time. The board may subsequently replace that reference, adopt its own categories or otherwise amend the regulation in accordance with the procedures and approvals required by the Professional Code. This reference does not confer any professional title or reserved act, transfer disciplinary authority or derogate from the permanent acquired right cited above. It does not make any otherwise inapplicable technical code or standard applicable.

The board of directors fixes the annual dues in accordance with section 85.1 of the Professional Code (chapter C-26), after considering the results of the advance consultation of members under section 103.1 and after consultation of members at a general meeting under section 104 of that Code. The board retains the decision-making authority conferred on it by the Code. Supplementary or special assessments, where applicable, are governed by the additional requirements and approval procedures prescribed by that Code. This authority is subject to the annual base-dues exemption for retired members under this section.

The Order has one general operating fund into which professional dues, transitional and ordinary registry filing fees, lawfully collected access fees and other eligible revenues are paid. The central registry is a permanent function of the Order and has neither a separate operating fund nor a separate financial envelope. Regardless of their accounting source, these resources may be used for all legally authorized functions and expenditures of the Order. Two successive fee arrangements apply in each region: a transitional establishment fee and an ordinary filing fee, never both charged for a report already subject to the transitional fee. After regional activation, the ordinary fee also covers the other eligible standalone professional filings exhaustively listed in the regulation referred to in the third paragraph. The collective name “Order and Central Registry of OPSI Establishment and Operation Fee” grants the Order no fee-setting power.

The Minister responsible for the administration of the Fire Safety Act alone is empowered to prescribe by regulation, following mandatory consultation with the Order and the Office des professions du Québec, every charge connected with the central registry and the pre-registry. This exclusive authority covers the creation and definition of fee categories, their amounts, establishment and filing fees, external-access, consultation and application programming interface (API) charges where authorized by law, exemptions, collection and refund procedures, indexation and any tariff change. The regulation is subject to legally required consultations, approvals, prepublication, publication and other formalities, including those under the Regulations Act (chapter R-18.1). No fee is payable until both its statutory authority and the prescribed rate are in force.

That regulation determines the initial period and rate of the transitional fee per eligible professional report and the ordinary fee per eligible standalone professional filing. It specifies the annual indexation formula, reference index, treatment of zero or negative changes, rounding, effective date and publication of the rate. Before a region’s documentary activation, only reports under paragraph 1 of section 15 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) may attract the transitional fee. After activation, only standalone documents under paragraphs 1 to 5 of that section may attract the ordinary fee. Mere receipt of another document or disclosure gives rise to no fee.

The Order administers and collects these fees within the limits of that regulation. It may not, by regulation, resolution, directive, contract or delegation, set or increase a rate, impose a surcharge, create a fee category, alter an exemption or depart from prescribed indexation. Professional dues and members’ contributions remain governed by the Professional Code, particularly the provision on dues mentioned in the first paragraph; the board of directors’ authority over those amounts is not transferred to that Minister.

Fees prescribed by that regulation form part of the general fund’s revenues. They contribute to financing the integrated public-protection regulatory scheme operated by the Order, including its institutional organization, the roll, the central registry and pre-registry, professional inspection, the syndic, discipline, administration, technological security and continuity, and professional liability insurance within the limits of section 39 (ACT RESPECTING FIRE SAFETY PRACTITIONERS). The Order need not reserve those revenues for an expenditure corresponding to their source. However, setting and maintaining such fees must be supportable by a documented analysis of their purpose, fee base, the costs of the integrated regulatory scheme and the regulatory benefits or services concerned; pooling does not turn a regulatory fee into a general tax or displace proportionality review.

The Order maintains one set of general accounts and analytical records identifying revenue by source, direct and shared costs by function, contributions to the group insurance plan, reimbursements, commitments, reserves and surpluses. This breakdown serves auditing, accountability and fee justification; it neither earmarks revenues nor prevents transfers between the Order’s functions. Only amounts for which separation or a specific use is expressly required by applicable law are excepted, including trust funds and legally protected assets of a separately constituted insurance or compensation fund. Recurring disparities between fee revenues and documented costs must be reviewed, and any tariff adjustment belongs exclusively to that Minister.

The annual base dues payable to the Order by a retired member are $0 throughout that status; no separate funding account is created for this exemption. This Order-dues exemption does not automatically eliminate the Office des professions contribution under section 196.2 of the Professional Code or other statutory amounts. An exemption from those contributions would require express statutory authority.

Each fee is borne by the owner of the legally covered building to which the eligible professional report or document relates. No fee applies to a building outside the scheme or to a person merely because of their status. Where one eligible standalone filing covers several buildings or owners within the scheme, regulatory arrangements provide a legally enforceable allocation of the single fee without multiplying it.

As of the legally established mandatory documentary activation date for a region, the ordinary filing fee, at the rate set by the regulation made by the Minister responsible for the administration of the Fire Safety Act under section 35 (ACT RESPECTING FIRE SAFETY PRACTITIONERS), is based on the actual number of new eligible standalone professional documents under paragraphs 1 to 5 of section 15 (ACT RESPECTING FIRE SAFETY PRACTITIONERS). The fee does not depend on floor area, property value, commercial category or the number of pages, annexes, diagrams, systems or buildings covered by one document. Artificially splitting a PDSI, its diagrams, a report or evacuation directives to multiply fees is prohibited. Genuinely distinct documents independently produced or approved where required under applicable rules may each be eligible. Non-compliance notices and related follow-ups remain free of charge.

A report on which the transitional registry establishment fee has already been paid and that is subsequently integrated into the registry may not be charged a second time for that integration alone. No retroactive fee arises for PDSIs, evacuation directives, assessments or attestations prepared before the activation of the region concerned. A correction, modification, partial review or retransmission of a current document already charged does not give rise to a further fee and remains tied to its original validity period; a preliminary and final report from the same verification, inspection or test form one chargeable unit. A new professional act and a genuinely distinct document remain subject to the normal conditions of the regulation referred to in the second paragraph.

On every invoice or collection document, the filing fee must appear on its own line, separately from professional fees, labour charges and any fixed or all-inclusive service price, into which it must never be bundled. It may be collected on the same invoice as professional services only if clearly identified and itemized. After regional activation, that line must state ‘Filing fee — Central registry of OPSI — [applicable amount]’. Any written quotation, estimate or offer of service that may result in an eligible document must also disclose the fee on a separate line at the applicable annual rate per eligible document, with the expected quantity where ascertainable; otherwise it must state the unit rate and how the final number will be calculated. The customer must be advised before invoicing of any change in the number of eligible professional filings known to the provider, in accordance with the regulations. A professional, employer or authorized agent may collect and remit the fee on behalf of the Order as prescribed by that regulation; the fee is not their professional fees or revenue. No commercial markup or disguised administrative surcharge may be added.

No right, filing, transmission, administration, receipt, notification, necessary submission access, update, supplement, follow-up or administrative closure fee may be imposed for a disclosure of reportable non-compliance, an eligible preventive warning or a substantiated report of danger requiring verification, whether during or outside a mandate, or subsequently charged to the reporter or building owner for that disclosure. Payment may not be a condition of receipt or routing. This mandatory exemption may not be displaced by regulation, resolution or directive. It does not exempt anyone from preparing and filing an independently required professional report or document or, where the standalone filing falls under paragraphs 1 to 5 of section 15 (ACT RESPECTING FIRE SAFETY PRACTITIONERS), paying the regulatory fee applicable to that filing, even where it and the disclosure concern the same facts. A free disclosure does not artificially create a fee-bearing report. Fees for a separate professional service actually commissioned remain subject to ordinary rules and may not be used to delay or condition mandatory reporting.

A separate new filing after the professional work has been fully repeated and approved is chargeable under section 15 (ACT RESPECTING FIRE SAFETY PRACTITIONERS), even before the previous due date or without substantive changes. Changes to the current filing remain free. A historical correction to an expired document does not restore its validity or replace required periodic work. Monitoring due dates are determined under that same section.

The professional documents under paragraphs 1 to 5 of section 15 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) are the only documentary filing categories that may be subject to the ordinary fee under section 35 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) and the regulation made by the Minister responsible for the administration of the Fire Safety Act, where they are genuinely separate professional acts and documents legally required in an activated region. A fire safety plan (PDSI) approved by a fire safety practitioner (PSI), or another person legally authorized to approve it, is a single document together with its integrated diagrams and annexes. Separately approved and filed evacuation directives or procedures count separately only where they form a genuinely independent professional document. No supporting exhibit, attachment, page, diagram, correction or retransmission attracts an additional fee; uploading a supporting exhibit does not constitute a separate chargeable professional filing. The filings and communications under paragraphs 6 to 9 of that same section, and all follow-ups and administrative closures concerning them, are entirely free of charge.

The transitional registry establishment fee is based solely on the actual number of new eligible professional verification, inspection or testing reports produced in a region where mandatory documentary filing has not yet been legally activated. No fee arises merely from a building’s, person’s or professional’s status or from a non-compliance notice or follow-up. The preliminary and final report for the same verification, inspection or test constitute a single chargeable unit.

After the Order’s legal establishment, commencement of the statutory and regulatory authority and the operational availability of systems capable of receiving, verifying and recording declarations, the transitional fee becomes payable at the rate prescribed by the regulation made by the Minister responsible for the administration of the Fire Safety Act under section 35 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) for new eligible reports produced in regions where the full documentary registry has not yet been activated. It contributes to eligible costs of the scheme without requiring complete documentary filing.

During that period, the responsible professional or, as permitted by that regulation, an employer acting on the professional’s behalf shall submit a secure written monthly administrative declaration of eligible reports and amounts due. Such declarations do not require full reports, plans or PDFs to be filed, or mandatory creation of an official building record in the registry. Duties to prepare, retain and report under other legislation continue to apply.

During the transition, the registry establishment fee must appear on a separate line from professional fees and service charges, labelled ‘OPSI central registry establishment fee — [applicable amount]’. Any written quotation, estimate or offer of service that may produce an eligible report states the applicable unit rate and expected quantity where ascertainable; any change in final quantity must be explained before invoicing. Collection and remittance on behalf of the Order are governed by that regulation and do not constitute fees or revenue of the professional, employer or agent. No commercial markup or disguised administrative charge may be added.

As of the legally established mandatory documentary activation date for a region, no new transitional fee may arise for reports produced in that region; the ordinary filing fee under section 36 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) replaces it for new eligible documents. This regional termination does not end the transitional scheme in other, not-yet-activated regions or cause retroactive charges or double billing. Declarations, outstanding amounts, amendments and refunds originating earlier remain governed by applicable law until settled, without requiring full reports to be filed solely on account of the administrative pre-registry.

The Order’s general-fund resources and surpluses remain available for all its obligations, public-protection functions, investments and justified reserves, without ring-fencing based on the origin of revenues. No amount may be distributed to members as profits, dividends, practice-volume rebates or personal financial benefits. Following year-end closing, approval of audited statements and provision for debts, refunds, obligations, commitments and necessary reserves, a net surplus may be paid to the Fondation de l’Ordre des praticiens en sécurité incendie designated in this section and identified under section 58 (ACT RESPECTING FIRE SAFETY PRACTITIONERS), only to the extent such a payment is legally authorized and compatible with the Order’s purposes. Such a payment may neither displace mandatory expenditures nor serve to justify regulatory fees in excess of what their legal basis permits. Each year the Order substantiates its regulatory-fee revenues against the costs of the integrated regulatory scheme and submits any necessary tariff adjustment to the Minister responsible for the administration of the Fire Safety Act. No transfer is made unless the Foundation is legally entitled to receive it.

The beneficiary foundation for surpluses from resources lawfully free of restrictions is expressly designated by this Act as the “Fondation de l’Ordre des praticiens en sécurité incendie”. It is separate from the Order and has its own board of directors. It is intended to result from amendment of the existing promoting non-profit’s name and constitutive purposes, in compliance with the formalities of its actual constituting law, or, if that cannot be done, from incorporation of one new not-for-profit legal person under the applicable general law as provided by the statutory requirements cited above. Its purposes must be exclusively compatible with charitable status: assisting people and families affected by fire, supporting recovery from fire-related loss, and providing fire-safety prevention and education activities yielding genuine public benefit. It exercises none of the Order’s admission, regulatory, professional-inspection or discipline powers and confers no private benefit on members. It must apply separately for registered charity status with the Canada Revenue Agency, without any guarantee of that status or authorization to issue official donation receipts. Net interest on general trust accounts is earmarked for direct remittance to it under section 40 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) and does not form part of registry fee proceeds. No transfer is made to a foundation that is not legally identified, established and authorized to receive it.

The regulation referred to in the third paragraph of section 35 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) governs monthly declarations and remittances, invoicing, collection, analytical reporting, reserves, refunds and corrections relating to regulatory fees. Such reporting requirements do not earmark revenue. Amounts subject to a trust regime or a legally separate fund remain governed by their respective legislation. Surpluses and Foundation transfers remain subject to this Act and other applicable laws. GST and QST apply only where required by tax law; this Act creates no tax exemption.

Every member who practises the profession must participate in the group professional liability insurance contract entered into by the Order, subject to exemptions expressly provided by regulation for members who perform no professional activities.

The board of directors adopts, in accordance with the Professional Code, a regulation determining the minimum terms of the plan, coverage limits, deductibles, post-practice protection, categories requiring complementary coverage and funding arrangements.

The Order may pay all or part of the premiums, contributions, administration expenses and other eligible costs of its group professional liability plan from its general operating fund, without distinguishing the source of the revenues credited to that fund. Despite section 85.2 of the Professional Code, solely to the extent necessary to make such payments, the board need not apportion among members the part of the costs actually paid by the Order; it shall nevertheless establish the plan’s full cost and apportion any remaining portion it determines must be paid directly by members or classes of members according to that section’s powers and criteria. Any contribution charged to a member shall be shown separately from base annual dues. This section does not waive mandatory coverage, alter supervisory powers or solvency requirements, or authorize the use of legally separate assets of an insurance fund established under section 86.1 of the Code.

For the purposes of sections 89 and 89.1 of the Professional Code (chapter C-26), the board must establish by regulation a trust regime strictly limited to advances for professional services in general trust accounts. No special trust account is permitted. Actual authorization to receive or hold an advance remains suspended until the prior accounting, oversight and compensation safeguards in the two applicable regulations have lawfully entered into force and their operation has been verified; without them, receipt of trust advances remains prohibited.

Any advance fee so received remains in trust until the corresponding professional services have actually been rendered and invoiced. A member may withdraw only the portion of the advance that has become earned in respect of services actually rendered and invoiced. Any unearned amount must be refunded to the client.

The member shall maintain separate accounting for each client identifying amounts received, withdrawals, invoices to which they are applied, refunds and the balance held in trust.

Net interest and other net income earned on general trust accounts belong to neither the member nor the client, subject to any rights recognized by applicable law. After deduction of only the account charges authorized by the trust-account regulation made in accordance with section 40 (ACT RESPECTING FIRE SAFETY PRACTITIONERS), they shall be remitted directly to the Fondation de l’Ordre des praticiens en sécurité incendie, designated by section 38 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) and identified and lawfully entitled to receive those amounts in accordance with section 58 (ACT RESPECTING FIRE SAFETY PRACTITIONERS), for the charitable purposes so provided. Such interest never passes through the Order’s single operating fund and is recorded separately so its remittance can be audited. If the Foundation cannot yet lawfully receive it, that interest shall remain separately identifiable and held under the rules governing trust accounts, without transfer to the single fund, until direct remittance becomes lawful.

The board of directors shall, by regulation and in accordance with section 89 of the Professional Code, determine the rules governing the opening, operation, control, bookkeeping, reconciliation, inspection, withdrawal, refund and transfer of interest applicable to general trust accounts. The regulation may not authorize a special trust account.

The board of directors shall also, in accordance with section 89.1 of the Professional Code, determine the indemnification procedure applicable where an amount held in trust is used for a purpose other than that for which it was remitted and, where applicable, the rules governing the establishment, administration and investment of an indemnity fund.

Trust mechanisms and the assets of any legally constituted compensation fund remain separate from the general fund to the extent required by the Professional Code and applicable regulations. Where legally authorized, establishment or replenishment of a compensation fund may be financed using the general fund; once lawfully allocated, the assets of the compensation fund remain governed by that fund’s own rules.

The relevant regulations must be made, approved and published under the provisions cited above and sections 95 and 95.2 of the Code and related procedures. Necessary financial parameters, including available compensation resources and any chosen cap, must be placed in effective regulatory provisions based on documented assessment before an individual authorization is issued. An administrative resolution alone cannot authorize possession of trust money or alter a regulatory cap. This financial-protection requirement does not prohibit financing based on the accounting origin of the Order’s general revenues.

The Government may, by regulation made after consulting the Order, the Office des professions du Québec and the professional orders concerned, prescribe interprofessional coordination procedures required to implement registry administrative obligations under sections 16 (ACT RESPECTING FIRE SAFETY PRACTITIONERS), 15 (ACT RESPECTING FIRE SAFETY PRACTITIONERS), 27 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) to 30 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) and 43 (ACT RESPECTING FIRE SAFETY PRACTITIONERS). The regulation specifies minimum identifying information for legally authorized professionals, verification of authorization, authentication of filings, administrative corrections and secure referral of suspected breaches to the authority having jurisdiction.

Those procedures also apply to legally authorized professionals from other orders and may not condition an activity already permitted by law on OPSI authorization. Where verification reveals reasonable grounds to suspect professional misconduct, the matter is addressed under the verification and referral provisions cited in the first paragraph; only the disciplinary authority of the professional’s own order decides on disciplinary steps under its own regime. OPSI acquires no disciplinary jurisdiction over that professional.

The regulation may not create an offence, disciplinary sanction or restriction on professional practice without a statutory basis. Any amendment to another order’s professional scope or disciplinary mechanisms requires the legislative authority otherwise applicable.

The Minister responsible for the administration of the Fire Safety Act may, by regulation:

1° determine the categories of external persons and bodies that may consult the registry, subject to the limits set out in sections 19 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) to 25 (ACT RESPECTING FIRE SAFETY PRACTITIONERS);

(2) determine their access rights and purposes without expanding insurer access beyond the information expressly permitted by section 23 (ACT RESPECTING FIRE SAFETY PRACTITIONERS), or access by delegated central labour organizations and independent associations beyond the premises, purposes and information permitted by section 24 (ACT RESPECTING FIRE SAFETY PRACTITIONERS);

3° provide for delegation of access management;

4° establish security, confidentiality and audit obligations;

5° determine conditions for suspension or withdrawal;

Charges for external access, consultation and APIs are governed exclusively by the regulation made under section 35 (ACT RESPECTING FIRE SAFETY PRACTITIONERS); this section creates no competing fee-setting power.

The Office des professions du Québec may designate a person responsible for verifying compliance, by an authorized person who is not a member of the Order, with obligations relating to:

1° filing in the registry;

2° certificates prohibited by section 8 (ACT RESPECTING FIRE SAFETY PRACTITIONERS), excluding supplementary certifications duly permitted by regulation and issued in accordance with it;

3° non-compliance notices;

4° changes in classification or status;

5° regulatory criteria necessary for those obligations.

That person may require the information reasonably necessary for the verification.

That person is bound by confidentiality.

Verification is confined to administrative obligations actually imposed on the person by this Act. A request for information identifies its object and statutory basis in writing, allows a reasonable time to respond except in a legally justified emergency and does not compel disclosure of protected information beyond what law permits. The person’s observations and response are included in the verification record.

A person lawfully subject to such a request responds within the limits of this section. The verification and its resulting administrative findings neither amount to a disciplinary finding nor exercise disciplinary authority over that person.

The Order verifies compliance by its members with this Act and the regulations applicable to them in accordance with the Professional Code.

A member’s professional duties remain personal even where an employer or firm physically keeps the records. The Order’s power of verification does not automatically make it custodian of its members’ private archives.

Where a verification concerns a member of another order and reveals reasonable grounds to believe that professional misconduct has occurred, the necessary information is transmitted to that order.

The Order exercises no disciplinary power over members of another professional order.

A referral identifies the applicable provisions, verified facts, strictly necessary records and any observations received. It is transmitted securely, subject to professional secrecy and personal-information safeguards. The receiving order independently decides on any action within its jurisdiction; a referral is not a finding of misconduct.

Without limiting the penal provisions of the Professional Code (chapter C-26), every person who contravenes one of the following express obligations under this Act commits an offence and is liable, for each offence, to the fine under section 188 of that Code:

(1) carrying out without right an activity reserved by sections 7 (ACT RESPECTING FIRE SAFETY PRACTITIONERS), 8 (ACT RESPECTING FIRE SAFETY PRACTITIONERS), 10 (ACT RESPECTING FIRE SAFETY PRACTITIONERS), 11 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) or 27 (ACT RESPECTING FIRE SAFETY PRACTITIONERS), subject to the legally applicable entitlements and exceptions, in particular those provided in section 9 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) and in the provisions cited above;

(2) knowingly failing to file a professional document required by sections 15 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) and 16 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) after documentary filing obligations have come into force in the relevant region;

(3) knowingly failing, contrary to the reporting and classification requirements in Chapter IV, to file a mandatory notice or change of classification when the facts establishing the duty are sufficiently known;

(4) knowingly consulting or extracting registry or audit-log information without right, contrary to the access limits in sections 19 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) to 26 (ACT RESPECTING FIRE SAFETY PRACTITIONERS);

(5) knowingly modifying, destroying, disabling or attempting to bypass an audit-log entry contrary to section 14 (ACT RESPECTING FIRE SAFETY PRACTITIONERS);

(6) issuing a certificate prohibited by section 8 (ACT RESPECTING FIRE SAFETY PRACTITIONERS), subject to supplementary certifications authorized by regulation, or a reserved professional attestation without the entitlement required under section 12 (ACT RESPECTING FIRE SAFETY PRACTITIONERS);

(7) retaliating or knowingly preventing compliance with a statutory filing or reporting duty in contravention of section 32 (ACT RESPECTING FIRE SAFETY PRACTITIONERS);

(8) knowingly and without lawful excuse refusing to provide information required under section 43 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) or intentionally obstructing a verification lawfully authorized by that section.

(9) knowingly falsifying, with intent to mislead the recipient, a report, approval, attestation, non-compliance notice, follow-up or reclassification whose production, authentication or filing is governed by the professional filing and non-compliance provisions referred to in paragraphs (2) and (3) of this section, or knowingly filing such a falsified document;

(10) knowingly representing a document as signed or approved by a legally authorized professional when no such signature or approval was given, contrary to the approval and authentication rules for professional documents referred to in paragraphs (1) and (2) of this section;

Unlawful use of a title, initials or designation protected by section 4 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) is governed by sections 188 and 188.1 of the Professional Code under their respective conditions. No additional offence with identical constituent elements is created.

Offences under paragraphs (9) and (10) of section 44 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) require knowledge of the falsification or absence of approval and intent to mislead; a good-faith clerical error alone does not constitute either offence. No new regulatory offence may be created without sufficient statutory authority.

The rules for natural and other persons, repeat-offence penalties and prosecutions are governed by the Professional Code, particularly the penal provisions cited in the first paragraph and its section 189, and by the Code of Penal Procedure (chapter C-25.1). Nothing in the provisions defining those offences or this section confers on OPSI the disciplinary authority of another professional order.

Section 32 of the Professional Code (chapter C-26) is amended by replacing, in the first paragraph, “sage-femme, géologue ou comptable professionnel agréé ni utiliser” with “sage-femme, géologue, comptable professionnel agréé ou praticien en sécurité incendie ni utiliser”. The quoted French words are those of the authoritative French legislative text.

Schedule I to that Code is amended in the first paragraph:

(1) by replacing the period at the end of subparagraph 25 with a semicolon;

(2) by adding the following after subparagraph 25:

“26° l’Ordre professionnel des praticiens en sécurité incendie du Québec.”

Section 5 of the Engineers Act (chapter I-9) is amended by adding the following paragraph after paragraph 14:

“(15) prevent a professional technologist entered on the roll of the Ordre des technologues professionnels du Québec from carrying out, on the same conditions as an engineer and to the extent expressly authorized under the Fire Safety Practitioners Act, the professional activities provided for in that Act, including the fire-safety inspections, verifications and tests referred to in section 8 (ACT RESPECTING FIRE SAFETY PRACTITIONERS), the preparation, signing, revision, correction, retention and filing of related professional reports, opinions and other documents, and the approval, revision and correction of fire safety plans, evacuation directions and procedures, and the floor plans and diagrams forming part of them, as referred to in section 10 (ACT RESPECTING FIRE SAFETY PRACTITIONERS), in accordance with the competency, independence, responsibility and traceability requirements set out in that Act and its section 9 (ACT RESPECTING FIRE SAFETY PRACTITIONERS).”

This amendment does not confer a general authorization to carry out design, calculations, sizing, inspection of an engineering work or supervision of work reserved under the Engineers Act where those activities are distinct from the activities expressly authorized by the Fire Safety Practitioners Act. Other professional Acts and regulations remain applicable. A floor plan or evacuation diagram referred to in section 10 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) does not eliminate the authorizations required for any separate design or engineering activity that its contents may entail.

The Insurers Act (chapter A-32.1) is amended by inserting, after section 50, the following:

“50.1. Where an authorized insurer takes into account, in establishing or modifying a premium, a non-compliance requiring action notice to which it has access under the Fire Safety Practitioners Act, any premium increase specifically attributable to that notice may apply only during the period in which the notice retains that status.

The increase may not apply to a period before the date on which the notice became accessible to the insurer or before the date on which the insurer became aware of it.

Where a notice results from an incidental discovery, before applying a premium increase specifically attributable to that notice, the insurer must reach the insured or an authorized representative by telephone, explain the existence of the notice, the nature of the non-compliance, the recorded correction deadline and the contemplated increase, and then grant a grace period of three complete days, meaning seventy-two hours from that conversation. An unsuccessful call or voicemail does not start the period. The insurer records the date and time of the conversation and sends written confirmation of this information and the grace-period expiry.

No premium increase specifically attributable to that notice may apply during the period or retroactively for that period. At its expiry and before applying any increase, the insurer checks the current notice status. If the non-compliance is then validly being addressed or the notice is closed, no such increase may apply. If it still requires action, an increase may take effect only after the grace period expires and subject to the other conditions of this section. Any new increase based on an incidental notice returning to the status requiring action requires a new telephone conversation and grace period.

The grace period concerns only an insurance premium increase attributable to the notice. It does not defer filing, the recorded correction deadline, urgent communications or required safety measures. Implementing this protection gives the insurer no access to protected registry documents or identities.

It ceases to have effect as of the date and time when the notice ceases to have the status ‘non-compliance requiring action’, including because it is reclassified as ‘non-compliance under documented action’ or closed by a correction notice.

Where all or part of that increase was paid in advance for a period after that date, the insurer shall, within 30 days after demonstrable receipt of the electronic notification provided for by the regulation on external access to the central registry of OPSI, made under section 42 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) of the Act respecting fire safety practitioners, grant the insured a credit or refund calculated pro rata for the remaining period.

If the same non-compliance again acquires the status ‘non-compliance requiring action’, a new increase attributable to that notice may apply only for that new period and may not take effect before the new notice is accessible to the insurer and the insurer is aware of it.

A non-compliance under documented action, a corrected and closed non-compliance, or the history of such a non-compliance may not, by itself, justify maintaining, renewing or reimposing an increase attributable to the registry notice.

The insurer may not charge the insured any fee attributable to consulting the central registry of OPSI or receiving a notification from that registry.

This section does not prevent an insurer from taking into account a risk factor of which it becomes aware independently of the registry and which it may otherwise consider in accordance with law.”

Obligations under the documentary registry regime and its transmissions apply to a building only upon legal activation of its region. Existing authority powers and duties and obligations imposed by other legislation remain unchanged.

The Act respecting the distribution of financial products and services (chapter D-9.2) is amended by inserting, after section 84, the following:

“84.1. A firm, independent partnership, independent representative or damage insurance representative may not charge a client any fee, remuneration or other amount attributable, in whole or in part, to consulting the central registry of OPSI established by the Fire Safety Practitioners Act, receiving a notification from that registry or the administrative processing of such consultation or notification.”

Obligations under the documentary registry regime and its transmissions apply to a building only upon legal activation of its region. Existing authority powers and duties and obligations imposed by other legislation remain unchanged.

The Coroners Act (chapter C-68.01) is amended by inserting, after section 48.1, the following:

“48.2. A coroner conducting an investigation or inquest under this Act may, solely for the purposes of that investigation or inquest, consult in read-only mode the relevant and necessary records and information in the central registry of OPSI established by the Fire Safety Practitioners Act, in accordance with the conditions and limits in section 21 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) of that Act. The coroner has the same consultation rights and arrangements as duly authorized members of police forces conducting an official investigation, subject to any legally required authorization.

Such access may include, within the scope of the matter concerned, professional reports, fire safety plans, non-compliance notices, correction notices, supporting documents, prior versions, change histories and relevant audit-log entries, including records of access to the audit log. Another investigation or inquest does not, in itself, authorize general or exploratory consultation.

The Ordre des praticiens en sécurité incendie du Québec shall respond without undue delay to a justified request by a coroner, making authorized documents available securely or, where permitted by law, transmitting readable and usable copies of the necessary records.

Accesses, consultations and transmissions are entered in the audit log together with the identity of the user, their organization, the reference of the investigation or inquest and the information consulted, under section 14 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) of the Fire Safety Practitioners Act. Information obtained remains subject to legally applicable rules of confidentiality, use, disclosure and retention. This section creates no additional investigative power and does not restrict the other powers conferred on a coroner by this Act.”

Obligations under the documentary registry regime and its transmissions apply to a building only upon legal activation of its region. Existing authority powers and duties and obligations imposed by other legislation remain unchanged.

The Police Act (chapter P-13.1) is amended by inserting, after section 49, the following:

“49.1. A duly authorized member of a police force governed by this Act is entitled, solely for the purposes of a specific official investigation falling within the member’s statutory duties, to consult records, documents, information, amendment histories and entries in the audit log of the central registry of OPSI established under the Fire Safety Practitioners Act that are relevant and necessary to that investigation.

That right of consultation is subject to the same conditions and restrictions as apply to coroners under the Fire Safety Practitioners Act, including identification and authorization of the applicant, justification of the investigation, any legally required authorizations, limitations on the information consulted, confidentiality and logging of every access and consultation.

Access is read-only. It permits no amendment, deletion or alteration of information recorded in the registry and confers no general, permanent or exploratory access unrelated to a specific investigation.

This section confers no additional investigative power and is subject to the other laws governing the investigation.”

The Act respecting land use planning and development (chapter A-19.1) is amended by inserting the following after section 119:

“119.1. A municipality issuing a permit authorizing construction of a new building covered by the Act respecting fire safety practitioners must transmit to the central registry of OPSI the prescribed information necessary to create the project record and open its official record in the registry, upon issuance of the permit and in accordance with the procedures prescribed by government regulation.

Permit information is also communicated to the competent authorities concerned, directly or through an integrated registry transmission mechanism. A competent authority may confirm, supplement or correct the corresponding record within its responsibilities. Where the permit issuer also exercises the jurisdiction concerned, one traceable transmission satisfies both destinations without duplicate reporting.

It also transmits, in the cases and time limits prescribed, reliable administrative information relating to completion or occupancy of the building, cancellation of the permit or abandonment of the project, authorization to demolish and actual completion of demolition, and relevant changes to information previously transmitted.

The Government may by regulation prescribe the categories of buildings and authorizations, information, time limits, formats, electronic transmission methods, acknowledgements, corrections and matching procedures, including through an administrative interface or secure API, avoiding duplicate reporting where the same information may lawfully be obtained from a reliable administrative source.

This section changes no condition for issuing a permit, municipal inspection power or substantive building oversight obligation.”

Obligations under the documentary registry regime and its transmissions apply to a building only upon legal activation of its region. Existing authority powers and duties and obligations imposed by other legislation remain unchanged.

The Fire Safety Act (chapter S-3.4) is amended by inserting the following after section 35:

“35.1. A local authority, regional authority, intermunicipal board or other public body legally exercising jurisdiction to enforce fire safety requirements in relation to a building covered by the Act respecting fire safety practitioners must declare to the central registry of OPSI the buildings and regulatory domains for which it exercises that jurisdiction.

For each field of its jurisdiction, the authority declares, under the applicable legal requirements, whether the building is subject to its filing or monitoring obligations. Different declarations made by several authorities for the same building may coexist and do not, of themselves, constitute a jurisdictional dispute.

It may have a missing building record created without producing a new permit, update administrative references it holds, report a demolition, and request correction, merger or subdivision of the building’s shared identity.

Within the prescribed time limits, it also declares any new assignment, change, delegation, applicable intermunicipal agreement or cessation of jurisdiction, without having to name a successor. For each building declared, it specifies the areas of its jurisdiction and reports changes in accordance with procedures prescribed by government regulation.

The Government may by regulation prescribe information, time limits, electronic methods, rules for administratively associating declarations with buildings, correction procedures and acknowledgement mechanisms for declarations under this section, including by API or administrative interface, so as to limit redundant reporting.

A registry declaration does not create, change or remove legal jurisdiction. The registry does not resolve disputes between authorities. This section does not expand any legal investigation, intervention or enforcement powers of authorities or of the Régie du bâtiment du Québec. Receipt of a notice by a competent authority does not, under this section, create any new duty to investigate, process, correct, transfer, monitor or intervene. These limits do not affect the decision on a challenge to reportability on unchanged facts expressly provided for in section 31 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) of the Act respecting fire safety practitioners. Other existing statutory powers and duties remain unaffected. The Order maintains a trace of filings and routing without exercising the powers of public authorities. ”

The Fire Safety Act is also amended by inserting the following after section 35.1 enacted by section 53 (ACT RESPECTING FIRE SAFETY PRACTITIONERS):

“35.2. The central registry of OPSI makes non-compliance requiring action notices available to authorities with a legal right of access and, where the conditions for supplementary routing to the Régie under the Act respecting fire safety practitioners are met, to the Régie du bâtiment du Québec in the relevant areas, by building and declared area of jurisdiction. It provides a dashboard showing new notices marked by a flag, flags explicitly confirmed as seen, notices actually consulted and acknowledgments explicitly confirmed. Each event is timestamped and linked to its actor where identifiable.

The Minister responsible for the administration of this Act may by regulation set maximum time limits binding the registry administrator for making notices available, initiating supplementary electronic notifications, detecting failed deliveries and issuing technical reminders for notices not yet consulted. The regulation may specify technical procedures for updating and correcting notification contacts and consultation states in the registry.

Neither notice availability, display of a flag, nor the absence of consultation or acknowledgment creates, solely under this section, a duty for any authority to consult a notice, confirm receipt, analyze it, investigate, transfer a file or intervene within any set time. No regulation under this section may create such a duty. Powers and duties already imposed under other laws remain unchanged.”

Obligations under the documentary registry regime and its transmissions apply to a building only upon legal activation of its region. Existing authority powers and duties and obligations imposed by other legislation remain unchanged.

The Building Act (chapter B-1.1) is amended by inserting the following after section 111:

“111.1. Solely for administrative identification in the central registry of OPSI established under the Act respecting fire safety practitioners, the Régie determines a persistent dispute between competent authorities concerning a requested merger, subdivision or correction of administrative records affecting the shared identity of a building.

An authority concerned may refer the matter to the Régie after a documented attempt to reach consensus. The Régie invites the other authorities concerned to make representations and renders a written, reasoned decision communicated to the parties and the registry as prescribed by government regulation.

Its decision concerns only the administrative representation of buildings and the continuity of their records and administrative associations in the registry. It creates, changes or removes no legal jurisdiction, determines no regulatory applicability, and gives the Régie no additional general power to investigate, supervise or sanction.

Until that decision, existing administrative records, professional filings and mandatory notices remain usable. The decision is recorded in the permanent history and authorizes neither deletion of historical data nor improper reassignment of an administrative identity.”

Obligations under the documentary registry regime and its transmissions apply to a building only upon legal activation of its region. Existing authority powers and duties and obligations imposed by other legislation remain unchanged.

The Order’s first board consists of eight directors including its president: six directors drawn from the promoting non-profit identified in section 58 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) and two directors appointed by the Office des professions du Québec under section 78 of the Professional Code.

On the reference date set by regulation, the promoter’s board identifies by certified resolution the six directors duly serving on its board and, where appropriate, an ordered list of eligible substitutes under its own rules. Only persons who demonstrate at least 24 months of relevant professional experience, totalling at least 1,800 hours of actual practice in duties directly related to the activities governed by this Act, may initially be designated to one of these six seats. This experience may have been acquired as an employee, as a self-employed worker, or within a public or private organization. The duration and nature of the experience must be substantiated by verifiable supporting documents, including employer attestations, time records, contracts, work orders or professional reports. It promptly sends the registers, consents, proof of residence, declarations of interest and other required records to the Office des professions du Québec. The Office des professions du Québec verifies compliance with these conditions before making its recommendation. For this purpose it also examines individual eligibility, independence and regional requirements and obtains any necessary further information. Its recommendation must be in writing and give reasons. Only the Government may formally designate the six initial directors, by an order in council made on the Office’s recommendation and published in the Gazette officielle du Québec. The promoter’s resolution is a proposed slate, not an appointment to the Order’s board; no seat is acquired before the order in council and express acceptance of office.

By an express exception strictly limited to the first board, the prior roll-registration and electoral-candidacy requirements in sections 66.1 and 76 of the Professional Code do not bar the initial designation of a director from the promoter who is not yet a member of the Order. Solely for initial governance, these directors are deemed elected without a general election; the exception ends for every regular election and regular term.

Notwithstanding the admission requirements prescribed by regulation, the six founding directors drawn from the promoting non-profit who are initially designated to the first board and who meet the experience and documentary-proof requirements set out in the second paragraph, become, upon taking office, holders by operation of law of the Order’s single permit, without an examination, internship or additional prior-learning recognition process. They are entered on the roll of the Order in accordance with the mandatory requirements of the Professional Code, the Charter of the French language and other applicable laws. This admission results directly from this Act rather than from a regulatory admission pathway.

A proposal or designation to the board alone, without proof that the experience requirements set out in the second paragraph are met, grants no permit, protected title or right to perform reserved acts. This exceptional measure applies neither to the two directors appointed by the Office des professions du Québec nor to replacements or successors of the six founding directors, even where a replacement occurs during the first board’s term. It does not waive integrity or independence checks, conflict-of-interest rules, disqualifications or restrictions or suspensions of practice rights. The six founding directors remain subject to all professional obligations, including mandatory ethics training, continuing education, professional ethics, professional inspection and discipline.

The president is selected from those six directors by secret ballot under the legally adopted first-board procedure and does not occupy an additional seat. The two Office-appointed directors exercise their statutory powers and obligations under the Code.

As of constitution, the six promoter directors must collectively come from at least four of Québec’s seventeen administrative regions, with at least one director residing outside the Communauté métropolitaine de Montréal. Geographic qualifications are established by verifiable declarations; replacements seek to preserve regional diversity without automatically invalidating the board during a temporary vacancy.

After consulting the Office des professions du Québec, the Government prescribes by regulation the reference date, submission of supporting records, objective checks, interest declarations and procedures by which the Office recommends candidates. The Government then makes an individual order in council designating the six promoter-derived directors after considering the Office’s written recommendation; the order states when their terms begin and is published in the Gazette officielle du Québec. The Office separately appoints the other two directors under the provision of the Code on those appointments mentioned in the first paragraph. In case of refusal, death, ineligibility, incapacity or vacancy, the Office examines an eligible person proposed under the promoter’s rules or drawn from its reserve list and recommends a replacement to the Government; only a further order in council may fill one of the six initial seats. Evidence of residence, regional representation, incompatibilities and consent are verified again. This special Government designation power and the narrow exception to the electoral requirements cited above exist only if the legislature expressly enacts this section.

The first election of the six member-elected directors and their assumption of office must occur no later than one year after the first board takes office. The first board and secretary organize admissions, the election notice, nominations and voting early enough to meet that deadline, independently of the registry timetable. By a limited derogation from the minimum term in section 63 of the Professional Code, the six initial directors deemed elected cease to hold those mandates when the elected directors take office, without automatic extension beyond that year. The Office retains its powers under the Code if the election is not held as required by law. The two Office-appointed seats remain separate and governed by the Code. Former directors may stand if they meet the ordinary conditions, without reserved seats.

The first board limits its decisions to pressing statutory obligations, immediate public protection and acts indispensable to establishing the Order’s operations and holding the election. It promptly identifies potentially eligible persons, invites them to apply for membership, facilitates admission under the statutory conditions and holds the democratic election of the board as soon as reasonably possible, without waiting for the one-year maximum. Policy choices and commitments that can wait are left to the elected board; the first board records why its decisions are necessary.

The six promoter directors undertake to leave their director and officer positions with that non-profit upon completion of transfer operations, no later than before its transformation into the Foundation takes effect. Resignations are coordinated with the lawful appointment of successor directors to maintain corporate continuity. Transactions between the Order and the promoter remain subject to independence, conflict-of-interest, creditor-protection and donor-restriction requirements.

The constitutive provisions take effect on the date set by the government without awaiting operation of the full registry. The first board begins functioning as soon as legally possible and exercises the powers needed, within the initial mandate under section 56 (ACT RESPECTING FIRE SAFETY PRACTITIONERS), for initial admission, the roll of members, ethics, professional inspection, discipline and establishment of the administrative pre-registry.

Under a particular express statutory authority, after consulting the Office, the Government may prepare and make the initial regulations needed to establish the Order before its constitution, within the express limits of this Act. Those instruments must identify their enabling authority, be published and take effect no sooner than legally permitted, concurrently with constitution or under a published timetable. Mandatory consultation, approval and publication rules continue to apply unless a precise statutory exception is expressly enacted. Initial rules subsequently falling within the Order board’s jurisdiction remain amendable by that board under sections 95, 95.0.1, 95.1, 95.2 and 95.3 of the Code as applicable to each subject; instruments under the authority of the Government, the Minister responsible for the administration of the Fire Safety Act, the Minister responsible for the administration of the Professional Code, the Minister responsible for the administration of the Building Act (chapter B-1.1) or the Office, according to the applicable enabling provision may be amended only by the legally empowered authority. Solely for initial regulations made by the Government before constitution under this particular authority, and only if this statutory provision is enacted, the advance notice to members required before adoption by the board under the last of the Code provisions cited above is replaced by advance publication of the draft for at least thirty days and documented consultation with the Office and affected stakeholders. This transitional rule does not authorize an as-yet non-existent board to act, does not waive legally required publication, examination or approval, and expires upon constitution of the Order. Any later enactment or amendment by its board remains subject to that same provision of the Code where applicable.

The promoting OPSI not-for-profit is an existing incorporated legal person, whose current legal name is “[CURRENT REGISTERED LEGAL NAME TO BE VERIFIED]” and whose Québec enterprise number is “[NEQ TO BE VERIFIED]”. Its actual constituting statute and registration particulars must be verified before this provision is finalized. Before amending its name and purposes to become the Fondation de l’Ordre des praticiens en sécurité incendie, the organization prepares a certified inventory of its assets, agreements, debts, refunds owed, commitments and restricted donations. With the necessary internal resolutions, approvals and consents, it transfers to the new Order its net assets legally available for transfer for the Order’s establishment and operations, including amounts whose restrictions permit that use. The transfer protects creditor rights, gift restrictions and sufficient resources to discharge obligations that are not assumed by the Order. Contracts and liabilities may be assigned only with the required consents. Nothing is distributed to members or directors.

After those authorized transfers, the existing promoting corporation adopts, under its verified constitutive statute and internal rules, the resolutions required to change its name to “Fondation de l’Ordre des praticiens en sécurité incendie” and amend its purposes to the charitable objectives in section 38 (ACT RESPECTING FIRE SAFETY PRACTITIONERS). It obtains all required approvals and amendment documents. If governed by Part III of Québec’s Companies Act (chapter C-38), it applies for supplementary letters patent to amend its purposes and, where appropriate, its name; if federally incorporated, it follows the amendment procedures under the applicable federal Act. The formalities must be completed sufficiently in advance of provisions requiring the new name and before any amounts are remitted to the Foundation. The same legal person then remains in existence under its amended name, without dissolution, liquidation, amalgamation or statutory continuance. It retains obligations and restrictions that could not be assigned to the Order and does not retain assets validly transferred to it.

If the existing promoting corporation cannot lawfully amend its name or objects for the Foundation’s mission, a new not-for-profit legal person is to be incorporated under the applicable general corporate law, not established automatically by this Act. Section 218 of the Companies Act and Québec enterprise registrar formalities must be verified if incorporation under Part III of Québec law is chosen; federal incorporation formalities apply if the federal route is selected. No new person is incorporated if the existing corporation has validly completed the required changes. No assets or money may be transferred to the Foundation until its legal identity, valid amendment or incorporation, and entitlement to receive the property have been established. Any disposition of remaining assets or possible winding-up of the original corporation remains subject to creditors, refunds and restricted gifts.

The Foundation, whether the result of a lawful amendment of the existing promoting corporation’s name and purposes or, subsidiarily, a new incorporation under general law, is legally separate from the Order and has its own board. When its new mission begins, it aligns its governance and operations with the charitable objectives mentioned in the second paragraph, ends incompatible institutional advocacy, avoids private benefits and respects restrictions on existing gifts. It applies independently for registered charity status with the Canada Revenue Agency. Neither this Act nor a decision of the Québec government guarantees that status or a right to issue official donation receipts.

The six initial promoter-derived seats are reserved for persons who, on the reference date, are serving directors and eligible regular members of the promoting non-profit. An associate member, consultative observer, donor or partner has no claim, solely by reason of that status, to one of these six seats or to designation to it. Membership in or participation with the nonprofit, regardless of category, grants no automatic entitlement to a permit, entry on the future Order’s roll or a board seat. A former observer or associate may nevertheless apply separately for professional admission if they independently meet the statutory and regulatory requirements; their former status alone is not a permanent bar. The two Office des professions appointments remain exclusively within its statutory authority and disqualification rules; the nonprofit has no appointment right over them.

The board of directors may, by transitional regulation, establish a special regime for:

1° initial admission based in particular on experience, training, certifications, professional achievements and demonstrated competencies;

2° recognition of prior learning;

3° internship or supplementary training;

4° admission as a transitional member holding the single permit, with defined activities and limitations;

5° temporary continuation of activities lawfully carried out before this Act comes into force.

The regulation determines the application periods, criteria, conditions, renewal procedures and limits of those measures.

Transitional admission and the rules needed for initial entry on the roll must be effective before new independent practice rights are granted. Every entrant must satisfy the initial ethics requirement in section 24 (REGULATION RESPECTING CATEGORIES, ADMISSION, INTERNSHIP, SUPERVISION AND RECOGNITION OF COMPETENCIES) of the admission regulation or remain subject to an expressly authorized temporary practice restriction until completion or lawful recognition of equivalent training.

During the initial admission regime, the Order may admit as a transitional member a person whose recognized competencies permit limited practice although not all conditions for regular admission have yet been met. That person holds the single permit, is entered on the roll with a verifiable indication of status and limitations, and may practise independently and sign only acts expressly authorized within their competencies and the conditions set by the Order.

Transitional membership may be maintained or renewed following reassessment, without an automatic maximum duration. Progression to regular membership depends on demonstrated competencies and applicable requirements, not merely the passage of time. A reasoned refusal of progression does not automatically terminate transitional status where the conditions for maintaining it remain satisfied, subject to applicable remedies. Limitations, suspensions and withdrawals remain possible under the applicable rules.

The permanent retired-member status is distinct from inactive and transitional status. A retired member remains on the roll but may neither perform reserved activities nor present as an active practitioner, and remains accountable for past professional acts. The regulation made under section 6 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) governs annual declarations, zero base Order dues and reinstatement of practice rights upon meeting objective requirements without repeating initial admission, subject to lawful restrictions.

No maximum duration of a training pathway or internship necessary for transitional admission is set by this Act.

Once an activity becomes reserved, the transitional regime specific to the Order does not permit independent performance of that activity by a non-member merely because an application is pending or an earlier administrative authorization exists. Internships and supervised operations remain possible under their governing rules; rights independently arising under another Act are preserved.

Timelines for initial admission, recognition of prior learning, training and transitional-status renewal are separate from the minimum 24-month registry delay under section 63 (ACT RESPECTING FIRE SAFETY PRACTITIONERS); that delay sets no maximum training or professional-status period.

A transitional member holds the single permit and is entered on the roll of the Order, which indicates the member’s status and applicable conditions or restrictions on practice.

The member may practise independently and sign acts expressly within their authorization, within the activities, systems, equipment and competencies recognized by the Order; supervision, training or evaluation may be required under the conditions imposed.

The member remains subject to the Professional Code, ethical obligations, the syndic, discipline, professional inspection and the insurance obligations applicable to practising members.

Transitional membership alone does not automatically authorize a member to:

1° give the approval provided for in section 10 (ACT RESPECTING FIRE SAFETY PRACTITIONERS);

2° issue the attestation reserved by section 12 (ACT RESPECTING FIRE SAFETY PRACTITIONERS).

The approvals and attestations referred to remain subject to the authorizations, competencies and limitations applicable to those acts. This section does not alter the rights of engineers, professional technologists or members of other orders, or authorizations independently conferred by another Act.

Implementation of this Act may be progressive.

The Government may determine different dates of coming into force.

The Order may, by transitional regulation and within the dates determined by the Government, organize the operational phases of implementation.

Regulations may not require mandatory creation of official building records, filing of complete professional files or automated transmission of information specific to the permanent documentary regime before a region’s legal activation date. The transitional establishment fee is authorized exclusively by section 35 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) and its implementing provisions.

The Government provides for an initial integration phase for existing buildings using authorized administrative sources. An official record is established for each identified building; matching, duplicates and multiple buildings on one parcel are managed without requiring the Order to conduct a physical census. Authorities have a regulatory period to declare their jurisdiction and relevant administrative associations progressively. During that period, a provisional lack of affiliation does not, on its own, trigger supplementary routing to the Régie; once the period ends, ordinary rules apply to active buildings without a declared authority under section 25 (ACT RESPECTING FIRE SAFETY PRACTITIONERS).

Implementation follows three separate phases: (1) establishment of the Order and commencement of professional functions; (2) stabilization of the Order, secure development of the full registry and administration of simplified monthly declarations; and (3) mandatory activation of the documentary registry, region by region, on dates legally set by the government.

No mandatory regional activation of full documentary filings may occur before the expiry of a minimum period of 24 months following the first board of the Order taking office. The government sets the activation dates for Québec’s 17 administrative regions by order or another legally appropriate instrument; the board prepares, publishes and updates the corresponding operational plan but cannot bring forward a legal date.

Regions are activated in ascending order of the number of buildings actually subject to the scheme, not by population, land area or all buildings. Rankings are established after a census based on reliable, deduplicated and verifiable administrative sources; no definitive ordering is published until the necessary data support it.

During the transitional phase and from operational commencement of the mechanism authorized by section 35 (ACT RESPECTING FIRE SAFETY PRACTITIONERS), each professional concerned or authorized employer submits a simplified secure written monthly administrative declaration identifying, among other things, the responsible professional, period, number and category of eligible reports, a deduplication reference, amounts billed, collected and to be remitted, and corrections. Remittance of the transitional fee accompanies the declaration as prescribed by the regulation made by the Minister responsible for the administration of the Fire Safety Act under that same section.

During the transitional period, information collected through the administrative pre-registry is limited to what is needed for reporting, collection, verification and accountability. Its collection, use, retention, access and destruction must comply with applicable confidentiality and privacy laws.

During this phase, no mandatory filing of complete professional documents, plans or non-compliance notices, and no mandatory creation of an official building record, is required for an inactive region. Professional documents continue to be produced, signed, delivered and retained in accordance with independently applicable duties. No general retrospective reconstruction of pre-activation reports is required.

Building-integration deadlines, documentary transmission duties, missing-report alerts, mandatory registry notifications and other mechanisms specific to the mandatory regional regime apply only once the region is legally activated. Early access under section 72 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) does not have that effect. Inactive regions trigger no tracking flags, missing-document alerts or supplementary routing to the Régie based solely on a provisional lack of authority designation or filing.

The commencement of reserved acts and professional-admission rules is determined independently of the regional documentary schedule. No transitional provision suspends emergency notices or safety obligations under another law, and the Order exercises no disciplinary authority over members of other orders.

After the Order has been constituted and the relevant authorizations have come into force, the Order may, before the first mandatory regional activation or before another region is activated, organize technical tests, pilot projects, targeted validation and partial commissioning of the registry. Those measures may involve volunteer professionals, employers or competent authorities, as well as selected territories, documents or services.

The transitional implementation regulation provided for in section 61 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) may establish the operating arrangements, duration, and conditions for participation and withdrawal. It may not change dates set by the Government or the powers of the Minister responsible for the administration of the Fire Safety Act over access or fees.

Simulations using fictitious data or a demonstration environment remain separate from the official registry and do not constitute legally recognized filings.

Any professional documentary filing officially accepted by the registry before mandatory activation in the region concerned, through an official service authorized under section 67 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) or the voluntary filing provided for in section 69 (ACT RESPECTING FIRE SAFETY PRACTITIONERS), is evidenced by official proof of receipt and remains permanently traceable. The registry preserves the document, its version and the identity of its author and links it to the building’s official record, with subsequent reconciliation where necessary and without requiring a new filing. Subsequent regional activation does not require the same document to be filed again. Subsequent repeal of the transitional provisions under which it was received does not affect the validity of that filing.

An early filing referred to in the first paragraph does not make filing compulsory for others, start any mandatory regional filing deadline or trigger a missing-report alert. Urgent communications and statutory safety or reporting obligations that apply independently of regional activation of the registry remain enforceable.

Before activation of a region, a legally authorized person may, once the official service is authorized and operating, voluntarily file in the registry a professional document referred to in paragraphs 1 to 5 of section 15 (ACT RESPECTING FIRE SAFETY PRACTITIONERS), including outside a pilot project. The Order determines the technical procedures for receiving and checking filings without changing professional practice requirements.

Where a professional report has been subject to the transitional charge established under section 35 (ACT RESPECTING FIRE SAFETY PRACTITIONERS), no second charge is payable for its voluntary filing, transfer or continued presence in the registry after regional activation. The Order links evidence of payment to that report without treating the administrative declaration as an earlier documentary filing.

A document in another category that is voluntarily filed before activation does not become retrospectively subject to the ordinary filing charge upon activation. New standalone professional revisions remain subject to charges only under their own applicable conditions; changes to the current document are not new chargeable filings.

Tests and pilot access create no additional charge. The Order may not establish, increase or change a tariff.

Partial or pilot access implemented before a region is activated does not activate mandatory regional filing, missing-report alerts or any new oversight or intervention duty. It does not affect the rights of other bodies granted independently by law.

To prepare competent authorities for operation, the Order may grant them partial or pilot access to official files actually available before a region is activated. Access remains limited to legally authorized categories and purposes under section 22 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) and the external-access regulation, subject to any authorization or delegation required from the Minister responsible for the administration of the Fire Safety Act.

Each authorization is individual, temporary and revocable; its scope is restricted according to the mandate to authorized territories, buildings, documents, functions and operations. The Order ensures authentication, verification of authority and logging. Administrative declarations in the pre-registry alone are not accessible through this mechanism.

Notwithstanding the ownership, voting-control and management-composition rules applicable to new professional organizations, a legal person, partnership or trust carrying on a commercial enterprise that, before the commencement of the provisions constituting the Order, lawfully existed and actually offered the professional services governed by this Act may permanently continue to offer the professional services governed by this Act in its own name, regardless of its owners' professional status, if it satisfies the transitional authorization regime in this section, the initial filing under section 74 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) and the professional-organization regulation. The exception concerns ownership and corporate-control requirements only, not professional obligations, insurance or reserved acts.

The permanent transitional entitlement is a single right linked to the authorized undertaking. It may be assigned, sold or transferred with the entirety of that undertaking, including to a purchaser formed after commencement, subject to prior registration of the transferee and continued compliance with all conditions. The transferor then loses the right. A share sale or change of control of the same organization does not end the right while conditions remain met. No sale, merger, demerger, asset transfer, franchise, branch, business division or restructuring may split or multiply this entitlement into multiple authorizations: only one continuing organization may hold it; other organizations must qualify under the ordinary regime. An organization never originally admitted to the exception cannot create, obtain solely by age, or resell an entitlement it has never held.

The organization must continuously have an employee who is a PSI member and formally designated as professional delegate, with effective authority over ethics, technical decisions within the profession, member signatures and professional independence. If that person dies or becomes unable to perform the role, a qualified replacement must be designated and declared within no more than three months of the event; after that deadline the entitlement expires, subject to lawful remedies. During a vacancy no reserved act may be performed, signed or approved on the organization's behalf without immediate written designation of another legally authorized employee PSI as interim professional delegate with equivalent professional authority; appointing an interim does not extend the three-month limit. Without an interim delegate, reserved services are suspended and the organization may not suggest that its former delegate remains able to practise. For resignation, termination, suspension or ordinary loss of practice rights, a qualified replacement must be in place before reserved services resume, and the change must be promptly reported to the Order.

Failure to register within six months, fraudulent eligibility, duplication of the entitlement or permanent failure to meet its conditions results in loss of the transitional regime under the Act and regulations, after an opportunity to make representations unless urgent protective measures are necessary. Loss does not prohibit non-reserved work or rights held under other professional or construction-licensing regimes. Regulations govern proof, transfer and recordkeeping but may not make this transitional entitlement non-transferable, time-limited or divisible.

The eligible organization must file its official declaration and undertaking with the Order's organization register within six months after that commencement, with proof of its lawful existence and actual offering of those services before that date, identification of its controlling persons, and written designation of at least one employee who is an active PSI member and has genuine independent authority over professional decisions. The entitlement is definitively registered only after compliance is verified; a complete timely filing preserves continuity pending a decision without permitting any reserved act without a personally authorized practitioner.

For the purposes of the sunset provisions of this Act and the regulations referring to them, completion of regional deployment is the date on which the last of the seventeen administrative regions is legally activated by the Government for mandatory documentary filing. Earlier voluntary filings remain valid.

The administrative pre-registry closes on a date recorded in a published order of the Minister responsible for the administration of the Fire Safety Act, following completion of regional deployment and the period required to receive, reconcile and settle transitional declarations and charges. Closure does not destroy supporting documents, receivables or record-retention duties.

Completion of the initial building-integration program is established by a published government order after certification of source quality, duplicate handling and assignment status for competent authorities. It does not end the continued creation of official building records or inventory maintenance.

The initial board period ends when the regular board of directors actually takes office under the Professional Code. Initial terms then expire, subject to acts performed and rights lawfully created.

The period for receiving new initial-admission applications ends upon formal closure of that period by the Order and final disposition of every application filed on time, including outstanding remedies. Existing permits and statuses, including their maintenance and renewal, are not extinguished by that event.

The initial organizational-filing period ends after the six-month period provided in section 74 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) and final disposition of filings received during that period, including outstanding remedies; vested authorizations remain subject to their permanent conditions.

When the regular board of directors takes office as defined in section 76 (ACT RESPECTING FIRE SAFETY PRACTITIONERS), section 56 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) is repealed.

Upon completion of the initial-admission intake and processing regime established by that section, section 59 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) is repealed.

Upon final completion of initial organizational filings under that section, section 74 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) is repealed.

At closure of the administrative pre-registry as defined in section 75 (ACT RESPECTING FIRE SAFETY PRACTITIONERS), sections 64 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) and 37 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) are repealed. Repeal occurs only after completion of regional deployment and the period required to receive, reconcile and settle transitional declarations and charges.

Upon completion of the initial building-integration program under that section, section 62 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) is repealed.

Upon completion of regional deployment, sections 63 (ACT RESPECTING FIRE SAFETY PRACTITIONERS), 65 (ACT RESPECTING FIRE SAFETY PRACTITIONERS), 67 (ACT RESPECTING FIRE SAFETY PRACTITIONERS), 68 (ACT RESPECTING FIRE SAFETY PRACTITIONERS), 69 (ACT RESPECTING FIRE SAFETY PRACTITIONERS), 71 (ACT RESPECTING FIRE SAFETY PRACTITIONERS), 72 (ACT RESPECTING FIRE SAFETY PRACTITIONERS), 61 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) are repealed.

Section 81 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) is repealed only after all reports it requires have actually been submitted, including the five-year report and the supplementary assessments tied to regional activation. Filing only the five-year report extinguishes no supplementary obligation. A missed deadline does not end the duty to produce the relevant report.

The date and official instrument establishing each event under sections 75 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) and 76 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) must be made public. A mere announcement, pilot test, activation of a single region or internal resolution of the Order does not constitute an event reserved to the Government or the Minister responsible for the administration of the Fire Safety Act.

Repeal under sections 77 (ACT RESPECTING FIRE SAFETY PRACTITIONERS), 78 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) and 79 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) has no retroactive effect. It does not extinguish acts lawfully performed, permits, statuses, limitations, authorizations, vested rights, remedies, elapsed periods, payments, declarations, filings or notices lawfully established.

Retention, audit trails, refunds, corrections, investigations, decisions and safety duties continue under applicable permanent provisions. A previously paid report may not be charged again merely because it is transferred or a region is activated. A professional documentary filing officially accepted before mandatory activation of its region retains its proof of receipt, versions, permanent history and the links needed for its audit trail. Subsequent reconciliation with the building’s official record may be carried out without requiring another filing. Neither regional activation nor that reconciliation requires the same document to be filed again or permits a second charge where the applicable charge has already been paid. No mandatory regional filing deadline or missing-report alert takes effect retroactively for the period preceding activation.

A regulatory provision reaching its sunset is not deleted from archival or historical consultation records. Current legal text and its sunset metadata are distinct from legal proof that the triggering event has occurred.

Not later than five years after this Act comes into force, the Office des professions du Québec shall report to the Minister responsible for the administration of the Professional Code on its application.

The report shall address, in particular:

1° protection of the public;

2° operation of the registry;

3° logging of access;

4° the non-compliance regime;

5° the operation of categories, internships and admission pathways;

6° interprofessional interactions;

7° accessibility of services.

The report separately evaluates the Order’s establishment and professional oversight from gradual registry rollout, transitional declaration volumes, startup costs, regional dates, privacy, avoidance of double billing and access services actually in operation.

The Office also produces a supplementary report within six months after the third anniversary of the first mandatory regional activation of the documentary registry under section 63 (ACT RESPECTING FIRE SAFETY PRACTITIONERS). It distinguishes regions by their actual operating duration and explains the interpretive limitations for newly activated regions. A review covering at least three complete years of operation in every region is produced within six months after the third anniversary of the last mandatory regional activation. If these two deadlines coincide, one report may satisfy both obligations.

These reports use registry-generated data including correction times, days since opening, reclassifications and their reasons, professional disagreements, access, costs and service availability. They distinguish verified corrections from closures because a requirement ceased to apply, and the Order’s effects from the registry’s effects. The absence of pre-creation data does not dispense with measuring observable post-activation results; published data comply with confidentiality and anonymization requirements.

The Minister responsible for the administration of the Professional Code is responsible for administering this Act, except for functions expressly entrusted to the Minister responsible for the administration of the Fire Safety Act. The latter exclusively exercises the central-registry and pre-registry fee-setting authority under section 35 (ACT RESPECTING FIRE SAFETY PRACTITIONERS), the external-access powers under section 42 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) and the power to determine a challenge following a refusal by the Régie under section 31 (ACT RESPECTING FIRE SAFETY PRACTITIONERS), without affecting the board of directors’ power to set professional dues under the Professional Code.

Where responsibilities under the Professional Code, the Fire Safety Act and the Building Act fall to different ministers, the Ministers designated in this section coordinate their actions within the powers respectively granted by this Act and the Professional Code. That coordination neither delegates fee-setting authority nor creates any additional power.

The Minister responsible for the administration of the Building Act (chapter B-1.1) exercises the power to add grounds for supplementary routing of notices to the Régie by regulation under section 20 (ACT RESPECTING FIRE SAFETY PRACTITIONERS), without altering the separate responsibilities of the Ministers designated in this section.

This Act comes into force on dates set by Government order duly published according to law. Provisions constituting the Order and the transitional regulation designating its first board take effect on its coordinated constitution date. Before admitting members entitled to practise, the essential admission, roll, professional conduct, insurance, professional inspection, professional records and governance provisions must actually be in force.

The Government may make necessary initial regulations in advance only under the particular express authority in section 57 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) and following required consultation and approval, to prevent a regulatory gap at constitution. Regulations within the Order’s jurisdiction are subsequently made or amended by its board under the actual enabling rules: section 95.0.1 for the matters it lists; section 95.1 for regulations under sections 63.1, 65 and 90, paragraphs a, b, e and f of section 93 and paragraphs a, j and o of the first paragraph of section 94; section 95.2 for the matters it lists; and section 95 in other cases. Section 95.1 requires consideration of applicable guidelines, transmission to the Office and publication on the Order’s website, with commencement on the fifteenth day following publication or a specified later date. Prior communication under section 95.3 remains required for the matters it covers. Each provision follows the enabling power and procedure applicable to its subject matter, even when a text combines several enabling powers. Regulations belonging to the Government, the Minister responsible for the administration of the Fire Safety Act, the Minister responsible for the administration of the Professional Code, the Minister responsible for the administration of the Building Act (chapter B-1.1) or the Office, according to the statutory authority of each remain within their jurisdiction. Nothing dispenses with publication or turns initial subordinate regulations into ordinary statutory provisions.

Permission to receive trust advances is deferred until the safeguards in section 40 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) and the trust-accounting and compensation regulations are met. The administrative pre-registry and establishment fee may commence separately from full documentary filings; no region may be made subject to mandatory activation before the minimum twenty-four-month period in section 63 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) has elapsed and the prescribed government activation measure is made.

The transitional registry establishment fee provisions in section 37 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) may not take effect before the Order has been legally constituted, the applicable statutory and regulatory authority has commenced and the administrative means necessary to implement them are operational. Provisions on the ordinary filing fee in section 36 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) apply in each region as of its duly established and published mandatory documentary activation date. Such activation ends the creation of new transitional charges in that region only. The general repeal of section 37 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) then occurs at the official closure of the administrative pre-registry under section 78 (ACT RESPECTING FIRE SAFETY PRACTITIONERS). Pre-existing obligations and the permanent protections against retroactive charges and double billing, and for free non-compliance reporting, survive.

The annual base-dues exemption for retired members under section 35 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) applies to members who have lawfully acquired that status from the commencement of that provision. It does not depend on mandatory documentary activation in a region or the closure of the administrative pre-registry.

This regulation is made by the board of directors under section 65 and paragraphs a, b, e and f of section 93 of the Professional Code, within the limits of the Act. It takes account of the Office’s applicable guidelines, is transmitted to the Office and is published on the Order’s website under section 95.1 of the Code.

This Regulation governs the regular board, elections, general meetings and head office of the Order within the limits of sections 61, 65, 78 and 93 of the Professional Code. The first board is governed separately by transitional provisions.

The board has eight directors including its president: six directors elected from among eligible members, including the president, and two appointed by the Office des professions du Québec under section 78 of the Professional Code. The president is selected from the six elected directors and occupies no additional seat.

When section 77.1 of the Professional Code applies, an additional director aged 35 or under is appointed under the Code. The board may then exceptionally have nine directors; this does not establish a ninth permanent seat.

Four of the six elected seats are assigned to four distinct electoral regions: 1° East: Bas-Saint-Laurent (01), Saguenay–Lac-Saint-Jean (02), Capitale-Nationale (03), Côte-Nord (09), Gaspésie–Îles-de-la-Madeleine (11); 2° West: Outaouais (07), Abitibi-Témiscamingue (08), Nord-du-Québec (10), Laurentides (15); 3° Centre: Mauricie (04), Estrie (05), Chaudière-Appalaches (12), Centre-du-Québec (17); 4° South and metropolitan: Montréal (06), Laval (13), Lanaudière (14), Montérégie (16). Official administrative boundaries apply.

One director is elected in each of those four electoral regions and two additional directors are elected province-wide. Professional domicile recorded on the roll determines candidacy in an electoral region in accordance with the Code. The four regional seats promote representation of at least four administrative regions and provide for representation outside the Communauté métropolitaine de Montréal when filled. Elections do not confer a mandate to represent private interests.

A member entered on the roll is eligible if legally entitled to practise, compliant with the Professional Code and free of statutory disqualification. Retired members are not eligible where the law requires practising status until practice rights are reactivated. Appointed directors are selected exclusively by the Office.

The secretary publishes the election notice, seats to be filled, candidacy requirements, calendar and voting instructions within the statutory periods. Each nomination includes declarations of professional domicile, independence, relevant interests and acceptance of office.

For the first election, the timetable ensures voting and the six elected directors taking office as soon as reasonably possible and no later than one year after the first board took office, under section 56 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) of the Act. The notice states that deadline and the subsequent choice of president from among the six elected directors.

Elections are conducted by verifiable secret ballot, including electronically if legal safeguards for privacy, integrity, accessibility and recounts are met. A member votes only in the constituencies to which they are legally assigned. The secretary retains the record and audit evidence as legally required.

The president is elected by secret ballot of the elected and appointed directors from among the six elected directors who stood for an elected seat, under section 2 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) of the Act and paragraph b of the first paragraph of section 64 of the Professional Code. The result is recorded in the minutes. The president remains one of the six elected individuals; no seventh elected seat or additional presidential seat is created.

Elected directors serve three-year terms subject to statutory rules, duly established initial staggering and applicable term limits. A published calendar staggers elections so all six elected seats do not fall vacant at once. Appointed directors serve the term established by the Code.

Vacancies are filled under the Code, including a by-election or legally permitted appointment, respecting the affected regional seat. The secretary discloses vacancies, action taken and expected replacement dates. A temporary vacancy does not, by itself, invalidate lawful decisions made with a quorum.

The board quorum is that prescribed by law; absent a stricter mandatory rule, it is a majority of directors in office, never below a statutory minimum. Decisions are made by a majority of votes cast unless a valid law or regulation prescribes a special majority. Conflicted directors abstain as required.

The annual general meeting is convened within statutory timelines by means reasonably accessible to members. Its notice sets out the time, venue or platform, agenda, relevant records, voting rights and participation arrangements. Special meetings follow statutory notice rules.

The quorum at general meetings is twenty-five voting members or five percent of voting members, whichever is smaller, without prejudice to any higher requirement imposed by the Code. Quorum is documented and, if absent, only steps authorized by law may be taken.

The board maintains annual conflict-of-interest disclosures, requires recusal for actual, potential or apparent conflicts and ensures mandatory institutional training. Relations between the Order and the Foundation are subject to independent decisions and auditable transactions.

The Order’s head office is located in Repentigny, Québec, under paragraph f of section 93 of the Professional Code. The board publishes the actual administrative street address separately once established. The Foundation determines its own head office independently.

The provisions needed to organize the first election take effect early enough to meet the deadline in section 56 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) of the Act and apply to preparations and voting during initial governance. The regular board’s operating rules take effect when it assumes office. No provision requires waiting until the first board ends or the registry is activated before organizing the election.

This regulation is made by the board of directors under sections 6 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) and 7 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) 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.

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.

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

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 (REGULATION RESPECTING CATEGORIES, ADMISSION, INTERNSHIP, SUPERVISION AND RECOGNITION OF COMPETENCIES) to 28 (REGULATION RESPECTING CATEGORIES, ADMISSION, INTERNSHIP, SUPERVISION AND RECOGNITION OF COMPETENCIES) 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.

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 (REGULATION RESPECTING CATEGORIES, ADMISSION, INTERNSHIP, SUPERVISION AND RECOGNITION OF COMPETENCIES). 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.

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.

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.

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.

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.

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 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) of the Act;

3° issue a professional attestation under section 12 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) 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.

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.

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.

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.

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 (REGULATION RESPECTING CATEGORIES, ADMISSION, INTERNSHIP, SUPERVISION AND RECOGNITION OF COMPETENCIES) and 26 (REGULATION RESPECTING CATEGORIES, ADMISSION, INTERNSHIP, SUPERVISION AND RECOGNITION OF COMPETENCIES); it is not a blanket exemption from the initial ethics requirement under section 24 (REGULATION RESPECTING CATEGORIES, ADMISSION, INTERNSHIP, SUPERVISION AND RECOGNITION OF COMPETENCIES).

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 (REGULATION RESPECTING CATEGORIES, ADMISSION, INTERNSHIP, SUPERVISION AND RECOGNITION OF COMPETENCIES).

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.

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

The status is reviewed periodically.

It ends when the prescribed conditions are satisfied.

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

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.

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.

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

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.

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.”.

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.

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 (REGULATION RESPECTING CATEGORIES, ADMISSION, INTERNSHIP, SUPERVISION AND RECOGNITION OF COMPETENCIES), 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.

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 (REGULATION RESPECTING CATEGORIES, ADMISSION, INTERNSHIP, SUPERVISION AND RECOGNITION OF COMPETENCIES) 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.

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.

A refusal, partial recognition or conditional decision must be written, apply the criteria in sections 25 (REGULATION RESPECTING CATEGORIES, ADMISSION, INTERNSHIP, SUPERVISION AND RECOGNITION OF COMPETENCIES) and 26 (REGULATION RESPECTING CATEGORIES, ADMISSION, INTERNSHIP, SUPERVISION AND RECOGNITION OF COMPETENCIES), 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.

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.

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.

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 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) of the Act and section 54 (REGULATION RESPECTING THE CENTRAL REGISTRY OF OPSI) of the registry regulation remains available. Retirement neither extinguishes responsibility for past work nor erases its documentary history.

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.

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 (REGULATION RESPECTING CATEGORIES, ADMISSION, INTERNSHIP, SUPERVISION AND RECOGNITION OF COMPETENCIES).

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.

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

This regulation is made by the board of directors under paragraph o of the first paragraph of section 94 of the Professional Code. Following communication of the draft to members under section 95.3, it takes account of the Office’s applicable guidelines, is transmitted to the Office and is published on the Order’s website under section 95.1.

Every practising member completes at least ten hours of qualifying professional development each reference year under paragraph o of the first paragraph of section 94 of the Professional Code. Reference-year dates and reporting methods are published beforehand.

Qualifying activities include relevant education on inspection, testing, applicable codes and standards, technical systems, risk assessment, public protection, regulation, confidentiality, recordkeeping, independence and professional ethics.

Activities must have verifiable learning objectives, competent instructors or sources and adequate completion evidence. Manufacturer or supplier training may qualify where relevant, verifiable and not solely promotional.

The Order publishes periodic ethics requirements countable within the ten-hour minimum. Initial admission ethics training remains distinct except where legally permitted equivalence is formally recognized.

Members record each activity, duration, provider and evidence and report their hours by the published annual deadline. Supporting records are kept for at least six years after the reference year, subject to longer statutory retention.

The Order may audit random samples or documented risks and request only reasonably necessary evidence. Members may correct clerical reporting errors within a reasonable time.

The annual requirement is prorated for entry, resumption or category changes during the year by a consistent published method. Transitional members are not arbitrarily charged more hours.

Retired and inactive members performing no reserved professional act are exempt while so classified. This does not waive education or competency assessment lawfully required to reactivate practice rights.

Reasoned exemptions or deferrals may be granted for illness, parental leave, disability or other recognized circumstances while handling sensitive information fairly. Written decisions explain resumption terms and available review.

When a deficiency is identified, the Order notifies the member of missing hours or documents and offers lawful time to correct it. Suspension or limitations may only be imposed using fair process authorized by the Code.

The ten hours are a general minimum and never excuse a member from further learning required by intended activities or changed applicable standards.

The competent committee may impose reasoned and proportionate targeted training, examinations or placements based on career interruption, planned activities and technical changes. Requirements are reviewable by an independent body under the rules.

This Regulation takes effect on its legally designated date and creates no retroactive training hours for a prior period.

This regulation is made by the board of directors under section 90 of the Professional Code. Following communication of the draft to members under section 95.3, it takes account of the Office’s applicable guidelines, is transmitted to the Office and is published on the Order’s website under section 95.1.

The Order establishes a professional inspection committee under section 109 of the Professional Code. It monitors practice quality and competency; it is not a disciplinary tribunal.

The committee consists of five members appointed by the board, normally practising fire safety professionals with diverse relevant experience. At startup, the board may rely on legally permitted competent persons and adaptations if too few experienced members are available. The board appoints the chair from among the committee members; the committee has a secretary bound by confidentiality.

Members serve three-year terms, renewable within board-established limits. Death, resignation, disqualification, prolonged recusal or loss of practice rights triggers lawful replacement; the committee may function despite a vacancy if quorum remains.

Every member, inspector or expert discloses interests and recuses themself for an actual, potential or apparent conflict. No one may inspect their own work or a file in which employment relationships or personal interests compromise impartiality.

The committee adopts an annual risk-based monitoring program covering the diversity of practice areas. It may use questionnaires, interviews, visits and record reviews on objective selection criteria.

A member cooperates with lawful inspection and provides, subject to lawful possession and access rights, relevant reports, test data, notes and supporting records. Filing a report in the registry does not replace review of the separate professional file.

Inspection addresses technical judgment, scope of competence, legally applicable standards, professional duties and traceability. It does not transfer a municipality’s, the RBQ’s or another authority’s power to enforce building compliance to the committee.

Except for urgency or contrary lawful grounds, reasonable written notice states the purpose, format, dates and documents requested. The member may seek a justified postponement without obstructing oversight. Site visits respect safety and confidentiality requirements.

Where significant competency concerns arise, the committee may undertake or recommend a special inspection or inquiry under the Code, defining scope and period. Any practice restriction is imposed only by the competent authority following lawful procedure.

The inspector submits a factual confidential report identifying methods, records inspected, findings and potential improvements. The member receives legally disclosable material and may submit written comments before an adverse recommendation is made.

The committee may recommend professional development, targeted education, supervised practice, an internship or a competency evaluation to the extent permitted by law. Recommendations state reasons and are proportionate to demonstrated risk.

A member retains the right to respond, to be heard and to seek statutory review when a decision affecting practice rights is considered. The committee does not impose disciplinary penalties.

Inspection records are securely kept separate from public roll information and the central registry. Disclosure is limited to persons and bodies authorized by law. Access is logged where legally or technically required.

The committee reports anonymized aggregate activity to the board without disclosing protected information. Any referral to the syndic follows the Code; inspections do not automatically become disciplinary inquiries.

While section 88 of the Professional Code remains applicable, this regulation is made by the board of directors following communication to members under section 95.3 and approved by the Office under section 95.2. The common regulation contemplated by section 12.0.1.2 falls within the Office’s authority and follows its own adoption and approval procedure.

This Regulation proposes conciliation and arbitration of professional fee accounts under section 88 of the Professional Code while that provision remains in force. Québec's 2026 Act, chapter 8, provides for a common scheme made by the Office des professions under new section 12.0.1.2; repeal of the existing enabling provision mentioned in the first sentence is deferred until the first regulation under that new provision comes into force. If such a common regulation comes into force and applies to the Order, it must be respected and any inconsistent provisions in this draft must be adapted or displaced as the law requires. Covered accounts include professional service fees and commercial disbursements, but exclude the statutory registry charges and their collection.

Any person who has paid or is liable to pay a professional fee account, in whole or in part, may request conciliation free of charge from the Order’s secretary within forty-five days after receiving the account, whether unpaid, partly paid or paid in full.

If multiple accounts relate to the same professional service or payment is due in instalments, the forty-five-day period begins when the most recent account is received or the latest instalment falls due. The request may cover all accounts issued or instalments due during the preceding year, as provided in section 88 of the Professional Code while it remains in force.

If a member deducts or retains amounts from funds held or received for the claimant, time begins only when that person becomes aware of the deduction or retention. A new request for conciliation may be made within forty-five days after a disciplinary council decision expressly questioning the quality or appropriateness of a billed professional act, provided the account has not already been conciliated or arbitrated.

The written request identifies the professional, account, amounts in dispute, reasons and supporting documents, and may be submitted securely online. The secretary acknowledges it and provides the independent conciliator’s details.

The board appoints a conciliator independent of the parties, bound by conflict disclosure and any required oath. If disqualified, a replacement is named without undue delay.

The conciliator notifies the professional, obtains an itemized account and relevant submissions and gives both sides a meaningful opportunity to be heard. Remote exchanges are permitted; irrelevant confidential information need not be disclosed.

Conciliation seeks a written agreement covering any payment or refund, deadlines and discharge. It does not waive professional duties or applicable regulatory fees.

If no agreement is reached within forty-five days after a complete file is received, or after an agreed extension, the conciliator issues a failure report explaining the arbitration procedure and deadline. Substantive negotiations remain confidential as required by law.

Within thirty days after receiving the failure report, the applicant may seek arbitration from the secretary, with accounts and report attached. The secretary notifies the professional and checks statutory admissibility.

Where the amount in dispute is less than $15,000, the arbitration is heard by one arbitrator; at $15,000 or more, it is heard by three independent arbitrators who choose their chair. The disputed amount is the difference between the account claimed and the amount acknowledged as owing, or the refund sought if the account has already been paid. Case complexity does not change the number of arbitrators.

The $15,000 threshold is a proposed regulatory choice based on section 15 of the Québec notaries' regulation (N-3, r. 12.1) and remains subject to economic validation for OPSI. The board appoints at least four eligible, knowledgeable and independent arbitrators for renewable two-year terms and appoints a secretary to the arbitration council. The secretary assigns cases by rotation among available impartial arbitrators, establishes a panel of one or three according to the first paragraph and gives the parties written notice of the names and composition. No arbitrator may serve after taking part in conciliation of the same case or where there is an actual, potential or apparent conflict; each signs a confidentiality and impartiality declaration and takes any required oath. The parties may give written notice of a ground for disqualification within ten days of notification or of later learning of the ground. The secretary, after consulting an independent arbitrator not challenged, decides the challenge in writing and appoints a replacement by the same rotation; if no listed arbitrator is available, the board appoints an independent substitute for that case. No internal policy or future guide may change the monetary threshold, number of arbitrators or these safeguards.

The arbitration secretary fixes the date, time and format of the hearing and gives the parties at least ten days' written notice; the notice identifies the arbitrators, permitted representation, a reasonable deadline for evidence and means of consulting filed material. Each party receives the material relied upon against it with meaningful time to respond and may present submissions, witnesses and relevant documents. The panel decides procedural matters and may adjourn for serious cause.

Hearings may proceed by video if fairness, confidentiality and witness questioning are protected. The tribunal rules on necessary evidentiary issues without deciding disputes outside its jurisdiction.

The arbitration panel issues a written, reasoned award within forty-five days after the hearing ends, subject to a lawfully permitted and reasoned extension. It upholds, reduces or cancels the account, may order a full or partial refund of fees already received and specifies amounts, due dates and the allocation of disbursements strictly authorized under section 13 (REGULATION RESPECTING CONCILIATION AND ARBITRATION OF PROFESSIONAL FEES). Three arbitrators decide by majority, or the sole arbitrator decides. The secretary serves the award and cost decision on the parties within ten days after filing. Applicable statutory remedies and enforcement procedures remain unaffected.

Conciliation and submission of an arbitration application are free of charge: the filing and referral fee and any mandatory advance payable by the applicant are $0. No deposit, security or other advance payment is a condition of admission or hearing of an arbitration application. Each party normally bears its own representation, preparation and travel expenses, subject to any contrary mandatory rule. Arbitrators' remuneration and ordinary administrative costs are paid from the Order’s general fund, without exclusion based on the source of revenue, with analytical allocation and detailed accounting reconciliation.

In its award, the panel may allocate between the parties only external disbursements actually paid by the Order, necessary to hold the arbitration and supported by records in the file; the aggregate amount chargeable to the parties must never exceed 10% of the disputed amount defined in section 9 (REGULATION RESPECTING CONCILIATION AND ARBITRATION OF PROFESSIONAL FEES). No flat administrative fees, penalties or undocumented expenses may be added. The panel expressly gives reasons for allocating such disbursements, taking into account the result, proportion of claims accepted and parties' good faith; it may leave all disbursements payable by the Order but must not obstruct access to the remedy. Any payment collected without authority or beyond a party's allocated share must be refunded in full within thirty days after the award. These numerical rules appear in this draft Regulation itself and are not deferred to a later schedule; they remain subject to the competent regulatory approval and any eventual common scheme under section 12.0.1.2 of the Code.

Under section 88 of the Professional Code while it remains in force, a member may not bring an action to recover fees before expiry of the time allowed to request conciliation. If conciliation is requested, such an action may not be brought before the regulatory deadline to request arbitration has expired; if arbitration is requested, the member waits until the award, subject to other mandatory legal rules.

As an exception, the syndic, designated for this purpose by this Regulation, may authorize an earlier action where serious grounds suggest recovery would otherwise be jeopardized. Authorization must be in writing and give reasons, and does not remove the client’s statutory entitlement to conciliation or arbitration. Prescription periods change only where the law so provides.

Applications, settlements and awards are kept confidential for the legally required period. Published statistics are anonymized and may not compromise professional secrecy.

A fee decision does not determine building compliance or discipline and never changes the amount, payer or chargeable event for the statutory registry fees.

This regulation is made by the board of directors under section 89 of the Professional Code, following communication to members under section 95.3, and approved by the Office under section 95.2.

This Regulation proposes to govern only the holding of advances for lawful professional services, exclusively in general trust accounts, under section 40 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) of the Act and section 89 of the Professional Code. No special trust account or other category of funds is authorized.

Actual activation and any first receipt of an advance are prohibited until both trust-accounting and compensation regulations have legally taken effect, banking and accounting controls are operational and the Order has demonstrated in an independent report the funding and real compensation capacity required by regulation. The Order publishes the effective authorization date and the list of lawfully authorized holders; an announcement or administrative resolution does not replace these prerequisites.

A member or legally eligible organization uses only a general trust account at an eligible financial institution. No individual special trust account is permitted; each client’s balance is tracked in the general account ledger.

The account is clearly identified as a trust account and segregated from personal, business and operating funds of the professional, organization and Order. It may not be used for ordinary operating costs.

Before receiving funds, the member gives the client a written agreement describing services, the advance, invoicing, refund, interest and fund-control rules. An advance is not earned merely because it was received.

A general ledger records each deposit and withdrawal, date, source, payee and bank reference. Separate client ledgers record opening balances, advances, settled invoices and refunds. Entries reconcile with bank evidence.

Advances are deposited promptly in the general account. The member provides a receipt and avoids cash where applicable controls or bank rules prohibit it.

A withdrawal to the member or organization is permitted only after the corresponding services have actually been delivered and billed, and only up to the earned amount available in the client’s ledger. The invoice and service date are retained.

Unearned funds are refunded without avoidable delay on completion or cancellation, subject to lawful rights. Fee disputes follow the applicable regulation and do not permit unilateral appropriation of disputed client funds.

No client subsidiary ledger may show a negative balance; one client’s money may not cover another’s shortfall. Discrepancies are documented and promptly corrected with appropriate notice.

The member completes and signs a reconciliation of the general account, client ledgers and bank statements at least monthly. Reconciliation evidence is preserved and unexplained shortages, suspected misappropriation or material security incidents are promptly reported to the Order.

Bank statements, receipts, invoices, agreements and ledgers are securely retained for at least ten years after the file closes, or longer when required by law or proceedings. They are available to legally authorized reviewers.

Subject to mandatory client rights and banking and tax law, a bank agreement provides for direct payment of net general-account interest to the legally eligible Foundation under sections 35 (ACT RESPECTING FIRE SAFETY PRACTITIONERS), 40 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) and 58 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) of the Act. Permitted deductions are transparent, documented and limited.

If payment to the Foundation is not yet legally authorized or necessary consent is missing, the interest is identified and held under applicable law, never transferred by default to the Order’s operating fund. Independent banking, tax and professional-law review is required before operation.

The Order may inspect accounts, reconciliations and controls through legally authorized persons. Professionals protect electronic access, keep transaction audit trails and produce legally required records without excessive disclosures.

Change of account holder, death, cessation of practice or closure of an organization triggers controls, inventory, reconciliation and secure transfer to clients or legally entitled custodians.

A trust account closes only once client balances are refunded or lawfully transferred, outstanding items reconciled and a closure report retained. Unclaimed client funds do not revert to the professional by default.

Misappropriation claims are governed by the separate compensation-fund regulation, not by professional liability insurance.

Before any activation, the Order formally establishes that compensation is operating under its regulation, general accounts can be audited and banking arrangements, including any lawfully designated interest for the Foundation, are valid. Otherwise new advances remain prohibited and services already delivered may be billed under ordinary non-trust rules.

This regulation is made by the board of directors under section 89.1 of the Professional Code and approved by the Office under section 95.2, in accordance with the applicable publication requirements.

Under section 89.1 of the Professional Code, the Order must compensate eligible claimants where a lawfully authorized member misappropriates funds entrusted in professional practice. This Regulation proposes a compensation fund separate from professional liability insurance. A proposed fund is neither funded coverage nor an effective permission to receive advances.

Compensation becomes operational only when the cumulative prerequisites in sections 3 (REGULATION RESPECTING THE TRUST FUNDS COMPENSATION FUND) and 16 (REGULATION RESPECTING THE TRUST FUNDS COMPENSATION FUND) have been satisfied and trust-advance authorization under section 40 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) of the Act and the trust-accounting regulation has lawfully taken effect.

The compensation fund, if established under section 89.1 of the Professional Code, maintains the separate accounts and statements required by its regulation and by law. It may be constituted from amounts lawfully allocated to it by the board out of the Order’s general fund, duly prescribed special contributions, recoveries, investment income and eligible insurance payments. Amounts legally paid into the compensation fund thereafter remain reserved for its proper purposes; their eligibility is not excluded solely because of their former accounting source in the Order’s revenues.

Before allowing any trust advances, the board commissions documented independent analysis tailored to PSIs, examining plausible advance volumes, engagement duration, maximum and average balances, concentration per holder, diversion scenarios, control effectiveness, extreme loss cases, actually available insurance and resources needed for timely compensation.

The board then introduces, through a regulatory amendment subject to required approvals, a minimum reserve or verifiable funding guarantee, contribution sources, replenishment rules and, if caps are chosen, maximum amounts per claimant and per member together with pro-rata allocation for competing claims. Numerical parameters cannot be imposed by administrative resolution or copied from notaries without evidence of relevance; no cap becomes effective merely by appearing in this consultation draft.

Once lawfully constituted, the assets of the compensation fund remain dedicated to its purposes and protected under the applicable regulation. Its commitments and actual compensation capacity must be established before the prohibition on new advance payments may be lifted; the general fund may contribute to its capitalization when lawfully authorized.

The board establishes a competent independent compensation committee whose members take the oath of discretion required by section 89.1 of the Code. The committee receives and investigates claims and makes recommendations; the board delegates decision-making only under an express delegation authorized by law. Members disclose conflicts and recuse themselves where required.

A claimant applies in writing, identifying the member and retainer and providing evidence of payment, agreed purpose and alleged loss. The Order assists with reasonably accessible evidence without demanding impossible records.

A claim is filed as soon as practicable after discovery of a diversion, without prejudice to statutory limitation periods or other mandatory deadlines. No deadline in this Regulation shortens a right under the Code. Claimants are advised of applicable periods and given reasonable time to supply missing evidence.

The secretary acknowledges receipt within fifteen business days, identifies missing evidence and sends the complete file to the committee. The committee may obtain required trust ledgers, bank records and other information by lawful means. An initial decision is normally made within ninety days of a complete file; any extension is explained and notified with a new target date. These proposed administrative timelines do not remove statutory remedies.

The member or representative may respond to the extent permitted by law without receiving unrelated confidential material. The claimant receives essential reasons for an adverse decision and information on legally available review.

The committee verifies that money was entrusted in a professional services matter, unauthorized use occurred, the net loss and prior recoveries. Professional negligence that does not constitute misappropriation is addressed through other liability remedies.

The board, or a committee lawfully delegated to decide, makes a written reasoned decision on eligibility, net loss, the award and payment terms subject to any effective limits expressly prescribed by regulation. Where competing claims against one member exceed a valid aggregate cap, allocation is pro rata as required by section 89.1 of the Code. This draft does not represent that funded coverage currently exists.

The fund prevents double recovery by accounting for compensation already received for the same loss where legally permitted. Settlements respect the rights of claimants and third parties.

To the extent of payments, the fund exercises available subrogation and recovery rights against responsible persons. Recovered amounts return to the fund.

Decisions remain subject to review and appeals provided by the Code and other applicable law; this Regulation does not extinguish statutory remedies.

The committee maintains a confidential file containing evidence, decisions, payments and recoveries. Authorized users comply with confidentiality and relevant access logging.

The Order publishes aggregate annual claim counts, payments, recoveries and fund resources without identifying claimants or exposing protected information.

Actual authorization to hold trust advances remains suspended until all of the following conditions are met: (1) trust-accounting and compensation regulations lawfully approved, published and in force; (2) effective regulatory provisions based on documented evidence setting minimum resources, contributions and, where adopted, caps and allocation rules; (3) funded reserves or verifiable guarantees actually available with separate accounting; (4) a competent committee and operational claims process; (5) effective banking controls, audit, logging and restitution arrangements; and (6) a published, reasoned determination by the Order supported by independent financial certification that all requirements are fulfilled.

If financial or control capacity becomes inadequate, the Order immediately suspends new authorizations and new advances until protection is restored, without prejudicing client money already lawfully received or claimants’ rights. No unsubstantiated reserve is represented as funded. Contributions from the general fund are subject to analytical allocation and detailed accounting reconciliation, without exclusion based on the source of revenue. Net trust-account interest follows the separate route under section 40 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) of the Act.

This regulation is made by the board of directors under section 17 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) of the Act; it is transmitted to the Office des professions and submitted for government approval under section 95 of the Professional Code.

This Regulation determines the procedures for filing, identification, authentication, correction, retention, security, logging, production of anonymized statistics and access to the registry through an application programming interface.

Provisions concerning documentary filings and EDF_ identifiers become mandatory for buildings only upon legal activation of the administrative region concerned. The statutory transitional monthly pre-registry remains separate.

Administration of the registry includes, in particular:

1° receiving and recording filings;

2° identifying and authenticating filers;

3° managing formats, metadata, corrections, replacements and versions;

4° preserving documents and their integrity;

5° technological security;

6° logging operations, including operations performed on the audit log;

7° determining filing procedures in accordance with section 17 (ACT RESPECTING FIRE SAFETY PRACTITIONERS);

8° producing anonymized and aggregated statistics in accordance with section 14 (ACT RESPECTING FIRE SAFETY PRACTITIONERS);

9° operating the technological access methods provided for by the Fire Safety Practitioners Act, including the application programming interface provided for in section 13 (ACT RESPECTING FIRE SAFETY PRACTITIONERS).

10° making notices available without delay to legally authorized recipient authorities, displaying new-notice indicators on their dashboards, providing supplementary electronic notifications, technical reminders and monitoring delivery failures;

11° maintaining a verified directory of administrative and fallback telephone contact details for authorities declaring jurisdiction, with a dated copy remaining available independently of the principal platform;

12° preserving, in the EDF_ identifier (EDF_ identifier) metadata, reference building coordinates in the reference system defined by the technical specification and their provenance, quality and history, without using those coordinates to confer legal jurisdiction on any authority;

13. the receipt without charge of substantiated danger reports requiring verification, formal notices of reportable non-compliance, and all supplements, follow-ups, corrections and administrative closures, with a clear technical and documentary distinction between those categories and fee-bearing eligible professional reports. The registry marks unverified reports as provisional for authorized recipients only and does not automatically treat them as confirmed non-compliance.

14. issuing, ensuring the uniqueness and retention of, and preventing reassignment of, EDF_, DEP_, DPJ_, SGN_, AC_ and EDJ_ identifiers, and preserving verifiable links between those identifiers, the persons or organizations concerned and the operations to which they relate, without creating any additional filing or fee.

Every person required or entitled to make a filing is subject to this Regulation, whether or not the person is a member of the Order.

Recording an apparent anomaly in a filed report does not, by itself, create a non-compliance notice or a separate registry entry.

Before activation of the region, this regulation does not require anyone to file a complete report, PDF, plan or notice or to obtain an EDF_ identifier; duties of transmission, retention and reporting imposed elsewhere continue to apply.

This regulation distinguishes three records: the eligible professional report, the formal notice of reportable non-compliance and the substantiated danger report requiring verification. The latter two are independent of the report and completely free, including outside a mandate and for all supplements and closures. An unverified report may not be displayed as a formal finding; no missing building identifier, mandate, exhaustive inspection or advance payment may prevent submission.

Every authorized filer, whether a member of the Order or not, indicates the capacity in which they act, the professional order to which they belong where relevant, any licence or authorization identifier legally required, the date of the act and the identity of the professional signatory. The registry checks authorization details relevant to the act without requiring OPSI membership. Clerical identification errors are corrected while retaining the original version and audit trail; an electronic filing operation performed by a third party does not transfer professional responsibility. The SGN_ identity of the document’s professional author and that of the person who carries out the electronic filing operation, if different, are retained separately; signing the filing operation does not constitute professional approval of the document.

A person may not sign, authenticate, approve or file in the registry a professional document concerning a building that the person owns in whole or in part or directly or indirectly effectively controls. This condition applies to every signatory or filer, whether or not an OPSI member; consent of the persons concerned does not permit an exception.

Effective control means decisive power over decisions concerning management or operation of the building, exercised personally or through an intermediary. Merely being employed by the owner, operator or manager does not, in itself, constitute such control.

This is a condition for signing and filing registry documents. It changes neither the scope of practice nor the disciplinary jurisdiction of the professional order to which the person belongs.

For a building covered by section 3 (REGULATION RESPECTING THE CENTRAL REGISTRY OF OPSI), professional documents intended for the registry, including reports, PDSIs, approvals and notices confirming action or correction, are signed or approved by another legally authorized person and filed by a person meeting the same condition.

The owner may prepare a document materially and communicate facts about the building. A factual danger report requiring verification remains permitted and free; it is not a professional report, approval or attestation that action or correction has occurred.

Official voluntary filing under section 69 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) of the Act is offered through a documentary intake service separate from the monthly administrative pre-registry. The person must be authorized for the document, and the registry must be able to identify and securely preserve it.

The registry verifies the information identifying the building and, when available, its genuine EDF_ identifier, as well as the identity of the filer and signatory, the category, the date of the professional act and file integrity. Temporary unavailability of the EDF_ identifier does not prevent an otherwise admissible voluntary filing where the information needed for subsequent reconciliation is provided. The registry assigns a permanent DEP_ identifier, preserves versions and provides proof of receipt; subsequent linking to the genuine EDF_ identifier is logged without another filing or creation of a fictitious identifier.

Subsequent regional activation does not require another filing of that same document. Changes to the current document incur no new charge; separate professional revisions retain their own regime. No missing-report indicator is calculated before activation.

As an exception to the activation restrictions in this regulation, the Order may use only the technical functions needed for official voluntary filings under section 5 (REGULATION RESPECTING THE CENTRAL REGISTRY OF OPSI): issuance of a genuine EDF_ identifier, validation, authentication, logging, preservation and legally authorized consultation. The duties and notifications of the mandatory regional regime remain inactive.

Subject to the seven-calendar-day period for the professional reports referred to in the second paragraph and to any more stringent provision, other documents referred to in section 15 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) of the Act are filed within ten calendar days after their final signature or authentication or, where their category requires professional approval, after that approval. If none of those formalities is required, the period runs from final production. This residual period neither replaces nor extends the specific period for reports under the second paragraph or the reporting periods under section 9 (REGULATION RESPECTING THE CENTRAL REGISTRY OF OPSI).

Every professional report resulting from a verification, inspection or test referred to in section 8 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) of the Act, including a stand-alone intervention, must be filed in final form or, in the circumstances described in the next paragraph, in preliminary form, no later than seven calendar days after the intervention actually ends, or after its final day where it spans several days. The period runs from that actual end, not from later receipt of external results, drafting, administrative review, signature or approval of the report; none of those steps extends it.

Where information, results or documents from external sources needed to finalize a verification, inspection or testing report remain outstanding, a preliminary report signed or authenticated by the responsible professional must be filed within the same seven-calendar-day period following the end of the intervention. It identifies the professional, the building or buildings and their EDF_ identifiers, the applicable standard or requirement and the intervention scope; it presents available findings and information, identifies outstanding external elements, distinguishes established findings from those requiring confirmation and allows the intervention and its progress to be traced. It makes no final conclusion on unverified elements. Awaiting external information never extends the first filing deadline.

The final report is filed as soon as the necessary information has been received and processed, without unjustified delay, and linked to the preliminary report, which remains in the history of the same intervention without constituting a separate intervention. Versions, supplements and corrections remain traceable. Neither waiting for the final report nor filing a preliminary report delays the reporting, within the reporting periods cited above, of non-compliance under documented action or requiring action, or any required emergency communication. An authorized third party may electronically file the preliminary or final report under section 20 (REGULATION RESPECTING THE CENTRAL REGISTRY OF OPSI) without assuming professional responsibility.

All filing periods under this section apply in each region only to documents produced on or after its legal activation date; no general retrospective reconstruction of earlier documents is required.

Corrections, modifications, partial reviews and retransmissions of a current document remain linked to the original filing, without a new fee or postponement of the due date. A new filing after the professional work has been fully repeated is governed by section 15 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) of the Act and the filing deadline for its category under section 7 (REGULATION RESPECTING THE CENTRAL REGISTRY OF OPSI). Where a periodic requirement applies, the new cycle begins on the last day of that work, independently of the filing date.

Finalization of a preliminary report remains subject to the fourth paragraph of section 7 (REGULATION RESPECTING THE CENTRAL REGISTRY OF OPSI); it does not start a new seven- or ten-day period. A report resulting from a new intervention referred to in section 8 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) of the Act is subject to its own seven-calendar-day period running from the actual end of that new intervention. None of these periods postpones a required disclosure or emergency communication.

Filing procedures distinguish reports requiring verification, sufficiently substantiated formal notices and eligible reports. They provide a completely free outside-mandate reporting path, a record of evidence and its limitations, provenance of information, corrections without erasure, processing audit trails and protection of affected persons. The regulation made under section 17 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) may not make a disclosure conditional on payment, a mandate or the artificial creation of a professional report.

Every non-compliance notice classified as 'requiring action' or 'under documented action' must be filed in the registry as soon as possible and no later than 24 hours after the non-compliance and attainment of the serious-risk threshold are sufficiently established by the authorized person. Findings within the verification scope of a mandate or legally assigned activity are classified in light of information obtained after notifying or attempting to contact the responsible person under sections 28 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) and 29 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) of the Act. For an incidental discovery, no prior communication or attempted contact is required and classification rests solely on lawfully available information. Waiting for a response, discussing a corrective mandate, or completing or filing a professional report does not extend the period. Where the non-compliance can only be established after receiving an external result, the period begins when the non-compliance and threshold can actually be determined. The 24 hours are a maximum, not a waiting period.

Upon filing of a “requiring action” notice, the registry immediately displays it with a new-notice flag on every lawful recipient’s dashboard, including that of the Régie du bâtiment du Québec where the EDF_ identifier is classified as “EDF_ — RBQ” for the area concerned. For each recipient it initiates the same supplementary electronic notifications, delivery-failure checks and technical reminders. Filing establishes only receipt by the registry; availability, technical notification delivery and consultation are logged separately for each recipient. No separate notice from the authorized filer is required in normal operation, subject to the telephone fallback report under section 27 (REGULATION RESPECTING THE CENTRAL REGISTRY OF OPSI). During initial integration, provisional missing designations alone do not generate mass alerts; an actual serious non-compliance notice “requiring action” in an area with no designated authority is nevertheless immediately routed to the Régie.

The 24-hour registry filing period begins only after legal activation of the building’s region. Direct notices and emergency measures independently required by other laws are not suspended.

A substantiated report requiring verification is filed as soon as possible, no later than 24 hours after a member of the Order acquires directly observed facts or reliable information giving serious and objectively grounded reasons to fear a reportable danger. The deadline does not depend on securing a mandate, issuing a report or subsequent official verification. The registry records the reported start time, preserves the 'requiring verification' status and routes the report without automatically turning it into formally established non-compliance. Emergency communications take priority. Ordinary formal-notice deadlines and legal regional activation remain unchanged.

For each formal notice of non-compliance classified as 'under documented action' or 'requiring action', the registry retains metadata on potential impact on firefighter operations under the non-compliance regulation. If that impact cannot be assessed at filing, the value 'undetermined' is recorded; that uncertainty delays neither filing nor delivery of the notice. Supplements and corrections confined to this metadata are free, attributed to their SGN_ author, dated and recorded under EDJ_, without creating a new notice, changing the original observation date or extending a correction deadline.

For every formal non-compliance notice and substantiated report 'requiring verification', the registry records the mandatory 'Origin of finding' metadata under section 29 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) of the Act. It distinguishes verification within a mandate or legally assigned activity from incidental discoveries, including discoveries made during a different mandate. The field accompanies the notice or report in consultations and notifications to authorized recipients through both the interface and the API. It may be corrected free of charge, with a reason, SGN_ signature, timestamp and EDJ_ audit record, without erasing the originally declared origin, creating a new notice or extending the filing deadline.

A non-compliance under documented action notice is filed in the registry within the period under section 9 (REGULATION RESPECTING THE CENTRAL REGISTRY OF OPSI) and, in every case, before the correction deadline it contains.

The registry preserves the deadline date and time. At that deadline, if no correction notice filed by a person authorized to identify the non-compliance concerned has closed the non-compliance, the registry automatically converts it into a non-compliance requiring action, time-stamps the conversion and immediately makes it available in the competent authority’s dashboard.

No separate declaration by the owner, manager or initial professional is required.

This automated conversion and alert mechanism operates only in legally activated regions; an inactive region cannot generate a false missing-filing or missing-correction alert.

A correction or status-change notice based on a documented development takes effect in the registry upon receipt without the previous signatory’s agreement. Only a challenge, on unchanged facts, to the reportability of the finding requires the documented agreement or decision under section 31 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) of the Act; filing the challenge alone does not alter the notice.

A correction notice closes the non-compliance concerned after an authorized person has verified that the condition giving rise to that non-compliance has been satisfactorily corrected with respect to the applicable requirement, within the scope of the verification performed.

The distinct status “Closure — requirement no longer applicable” is recorded on the basis of verifiable legal or administrative evidence from a legally empowered source and documented validation by a person authorized to confirm non-applicability in the situation concerned. The original finding and classification, effective date, legal reason and reference, validator’s identity and complete history are recorded. It is not coded as “corrected” and remains separate from reasoned withdrawal for insufficient grounds; the registry itself grants no exemption. Statistics distinguish verified physical corrections from these legal closures.

A notice reclassifying a non-compliance requiring action as a non-compliance under documented action records the new correction period and reactivates the automatic conversion mechanism provided for in section 10 (REGULATION RESPECTING THE CENTRAL REGISTRY OF OPSI).

The person making the filing may be different from the person who produced the initial notice.

A person directly concerned by a notice of non-compliance recorded in the registry may ask another legally authorized and competent person for an independent professional assessment of the facts or classification. The registry does not adjudicate the merits of the notice, and the Order does not establish an administrative review panel to decide the matter.

The person accepting that engagement determines the necessary checks within the limits of their authorization, mandate and lawful access. They assume professional and ethical responsibility for any conclusion, new classification, verified correction or reasoned finding of insufficient grounds that they sign and transmit to the registry. An unverified opinion does not alter a notice in force.

The registry links the operation to the same EDF_ building identifier and the original notice, retaining the dates of findings, reasons, verification limits, SGN_ identities, EDJ_ entries and previous versions. It presents the current state according to applicable chronology and priority rules, without erasing or rewriting earlier findings.

Only a challenge, on unchanged facts, to the legal basis or mandatory reportability of the finding requires documented agreement with the signatory of the disputed conclusion or a reasoned decision under section 31 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) of the Act. It does not suspend the notice or its deadlines and does not prevent an update based on documented developments, an automatic conversion or a legally justified closure. Notices, dispute submissions and decisions are filed free of charge; fees for a separate professional intervention follow the ordinary rules.

The new conclusion does not in itself establish fault by the original signatory. Any professional complaint or discipline remains under the jurisdiction of the syndic and disciplinary bodies of the relevant professional order; the registry is granted no disciplinary power.

The ‘Reason for the new assessment’ metadata required by section 31 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) of the Act is mandatory for a new assessment of an existing reportable non-compliance. Its values are ‘Change in circumstances’, ‘Disagreement between professionals’ and ‘Change and disagreement’. Initial filings and purely clerical corrections are identified as such rather than artificially assigned one of these values. The author links the reasons to the earlier notice and conclusions. The metadata, its author and any corrections are timestamped and preserved without erasure; they are visible only to persons whose lawful access scope covers this information. They do not resolve the disagreement, change the status by themselves or disclose additional information to insurers or worker representatives.

Each notice retains the date of the original finding and the cumulative time elapsed since then, even after reclassification, a renewed undertaking or a deadline change. Each transition retains its timestamp, author and grounds in the history accessible to authorized persons; no transition creates a new initial finding date.

For every notice based on a professional finding or new professional verification, the registry separately retains the actual date and time of the finding, as declared by the authorized person, and the date and time of filing as timestamped under section 23 (REGULATION RESPECTING THE CENTRAL REGISTRY OF OPSI). Automatic conversions retain their own timestamps and are not portrayed as new professional findings.

Where findings concern the same non-compliance, the same circumstances and the same scope, the most recent professional finding is used to represent the current situation, subject to the agreement or decision required by section 31 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) of the Act to challenge, on unchanged facts, the reportability of the finding by section 31 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) of the Act regardless of the order in which filings are received. A late filing that describes an earlier finding does not automatically replace a situation supported by a later finding. Findings concerning different circumstances or scopes remain distinct. This display does not alter the effects of validly filed correction or reclassification notices, or automatic deadline conversions; it does not authorize the registry to substitute its judgment for that of an authorized professional. The complete history of findings, decisions and transitions is retained.

The actual finding date gives a filing no retroactive effect against third parties: effects attached to receipt of the notice or classification change are governed by section 11 (REGULATION RESPECTING THE CENTRAL REGISTRY OF OPSI) and other applicable provisions, subject to automatic conversion on expiry under section 10 (REGULATION RESPECTING THE CENTRAL REGISTRY OF OPSI) of this regulation made pursuant to section 30 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) of the Act.

For each open reportable non-compliance, the registry automatically calculates ‘Days since opening’ from the timestamp of the first filing that opened the notice. This metadata states the number of complete twenty-four-hour periods elapsed and the calculation date and time; it is refreshed on each authorized consultation or extraction. The opening timestamp and actual date of the initial finding are retained separately. Reclassification, a renewed commitment, a changed deadline or a different professional resets neither clock. On closure, the duration at that date is preserved; reopening the same notice retains its original opening timestamp. A genuinely distinct new finding remains subject to its own rules.

Within its lawful access scope, the competent authority can consult this metadata and the age of the finding through the interface or an authorized API. They support the record and the authority’s assessment. They impose no new duty to intervene, penalty or additional reclassification solely because of the notice’s age, and do not alter correction deadlines or the automatic conversion already provided for.

The unique building number (EDF_) is issued exclusively by the registry and permanently identifies a building or authorized project. Its format is specified in the technical specification under section 40 (REGULATION RESPECTING THE CENTRAL REGISTRY OF OPSI). It must never be reused, including after project cancellation or building demolition.

The registry guarantees EDF_ identifier uniqueness through controlled generation and collision checking. The EDF_ identifier remains unchanged upon any change of owner, address, cadastral lot, property assessment number, name or competent authority. It remains linked to the archived record and permanent building history.

Each EDF_ identifier contains in its location metadata a representative building point expressed using the reference system and fields defined in the technical specification. The registry also records the point type, source, collection or validation date, estimated accuracy and verification status. Elevation is optional and is collected only where justified in a particular situation.

Within applicable access rights, the coordinates may be made available through an interoperable geographic API, using the technical specification formats. Missing or uncertain coordinates are expressly identified; coordinates must never be fabricated to satisfy the format. Every correction preserves the previous value and its provenance. Coordinates alone do not determine legal jurisdiction, the applicability of obligations or a building’s administrative identity.

Where a document or administrative event concerns a building without an EDF_ identifier, the registry searches existing identifiers before issuing one and provides advance allocation or exceptional matching. Temporary absence of an EDF_ identifier never blocks a filing or mandatory safety notice.

Each officially received filing operation is given a distinct DEP_ identifier, including a free correction, revision or exceptional filing without an available EDF_ identifier. The registry retains links to the original DEP_ identifier, acknowledgments, document versions and previously paid fees; a single filing relating to several buildings has only one DEP_ identifier. A DEP_ identifier is not by itself evidence of compliance or an additional fee entitlement.

Every natural person performing an authenticated registry operation receives a permanent, non-reassignable personal SGN_ identifier, independently of profession or represented organization. An SGN_ identifier is neither a licence, a professional order registration number nor a general access entitlement. Successive authorization statuses, represented organizations, restrictions and revocations remain historically verifiable without changing the identifier. Each registered authority receives a unique AC_ identifier, separate from its triage keys and buildings’ EDF_ identifiers. The registry assigns each audit-log entry a unique EDJ_ identifier, distinct from a filing’s DEP_ identifier.

The formats of SGN_, AC_, DEP_ and EDJ_ codes and their generation arrangements are set by the technical specification. The registry guarantees uniqueness, checks for collisions and never reassigns a code; editorial ART_ identifiers remain distinct and stable.

Assignment and retention of an EDF_ identifier do not depend on the building’s jurisdiction category. A change between the “EDF_ — Competent authority” and “EDF_ — RBQ” categories never changes the identifier, results in no new allocation and preserves existing links to associated documents, filings, authorities, versions and audit-log entries.

The rules for assigning SGN_ identities and EDJ_ audit entries apply to every authorized official or pilot operation, before or after activation of a region. Ordinary filing and EDF_ identifier requirements become mandatory in a region only upon its legal activation, subject to official voluntary filings and other statutory exceptions.

The DPJ_ code format and generation are specified in the technical specification. The registry guarantees uniqueness, checks for collisions and never reassigns it.

Each DPJ_ identifier denotes an individual supplementary evidentiary file. It remains linked to the DEP_ identifier of the associated filing, notice or report, including where the linkage is established when both are first received. A DPJ_ exhibit added after the initial filing is a linked and logged operation; it does not become a separate professional document, trigger a second charge or require a new DEP_ identifier for a report.

For the purposes of this Regulation, the categories of official identifiers are as follows:

1° “EDF_” (unique building number): the official, permanent identifier issued exclusively by the registry to a building or proposed building; it remains linked to its history even after demolition or cancellation and may never be reassigned;

2° “DEP_” (unique filing number): a permanent, non-reassignable identifier generated by the registry upon receipt of each official filing operation, even where the link to a building must subsequently be regularized; it provides traceability of the filing, its acknowledgment, documents, versions and linked later operations without conflating them;

3° “SGN_” (signatory): the permanent, non-reassignable personal identifier of any authenticated natural person who signs a registry operation, including a filing, an observation, a search, a consultation, the retrieval of a copy or a download. This may be a member of the Order, an engineer, a professional technologist, an authorized representative of a competent authority or the Régie du bâtiment du Québec, a police officer, a coroner or any other legally authorized person. It is separate from that person’s title, licence, professional registration number and permissions;

4° “AC_” (competent authority): the unique permanent administrative identifier issued by the registry to each registered authority or recipient public body, including the Régie du bâtiment du Québec when acting in that capacity; it is separate from statutory jurisdiction and does not confer it;

5° “EDJ_” (audit-log entry): the permanent, non-reassignable identifier assigned to every entry in the registry’s audit log, distinct from filing and document identifiers;

6° “administrative triage key”: a reference specific to a competent authority, assigned by that authority to a building within its jurisdiction and linked to the building’s EDF_ identifier and the authority’s AC_ identifier; it replaces neither identifier.

7° “DPJ_” (supporting-exhibit filing): a unique, permanent, non-reassignable electronic identifier assigned by the registry to each supplementary evidentiary file associated with an official filing, notice or report; it identifies the exhibit, not a new professional report, compliance certificate or separate professional act. It is distinct from DEP_, EDF_, SGN_ and EDJ_ identifiers and does not, by itself, constitute a professional signature, approval or certification.

The prefixes EDF_, DEP_, DPJ_, SGN_, AC_ and EDJ_ identify the official codes for the categories defined in this section. They are assigned directly under the registry rules. An SGN_ identifier is neither a professional-order membership number nor a licence number. Permanent identifiers for legislative and regulatory provisions in the form ART_ remain distinct.

The technical specification sets out identifier specifications and interoperability arrangements. Conditions governing issuance, reconciliation, presentation on documents, correction of errors and retention of history remain governed by this regulation.

The Regulation prescribes the rules for linking a report or notice to one or more EDF_ identifiers, procedures to correct, merge or subdivide a building's administrative identity, and the simplified directory of systems and equipment. It preserves the distinction between each building's identity, links specific to a filing and each authority's separate applicability declarations.

The technical categories “EDF_ — Competent authority” and “EDF_ — RBQ” referred to in this Regulation serve solely to route notices administratively under the conditions set out in sections 25 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) and 20 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) of the Act. Their labels and identifier prefixes may be amended through the technical specification without changing those conditions, access rights, legally entitled recipients or the requirements for preservation and traceability.

Each distinct building has its own EDF_ identifier, including where multiple buildings share a cadastral lot; a building may also be linked to several lots. The registry retains cadastral references, addresses, property assessment numbers and their validity dates, without treating them as its official identifier.

The geographic location associated with each EDF_ identifier represents the building it identifies, not merely the centroid of a cadastral lot that may contain several buildings. Where the building position is uncertain, the registry indicates limited accuracy or “verification pending”. A spatial match to a municipal boundary or mapping area supports searching but never automatically confers legal jurisdiction on an authority.

Changes in cadastre or address, location errors and duplicates are handled through traceable matching that preserves prior values and records. When duplicate records are merged, no previously assigned EDF_ identifier is reused; an explicit matching link is preserved.

A request for an administrative merger or subdivision does not erase previously assigned EDF_ identifiers. A mere administrative association or the linkage of one report to several EDF_ identifiers does not warrant the issuance of new EDF_ identifiers; new EDF_ identifiers are contemplated only for a genuinely new building identity, following the required decisions and consents and with a permanent historical link.

The registry distinguishes, in particular, the administrative states “Authorized project”, “Active building”, “Demolition authorized”, “Demolished building — archived” and “Cancelled project” under the conditions prescribed by the central registry of OPSI regulation provided for in section 17 (ACT RESPECTING FIRE SAFETY PRACTITIONERS). An administrative state is neither a professional finding of compliance nor a decision on an authority’s jurisdiction.

For the purposes of the functions under section 13 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) of the Act establishing the Order, the following requirements supplement this Regulation:

For each building covered by the Act establishing the Order, the registry establishes and maintains a permanent administrative record, including administrative lifecycle events, successive property references, competent-authority affiliations as declared and historical links to successor buildings. The Order maintains these data technically without itself carrying out a physical building census or determining the legal jurisdiction of any authority.

The registry allows competent authorities to declare a building's administrative applicability within their respective fields. It retains successive declarations and documents linked to each building record. These operations confer no power on the Order to determine jurisdiction or applicable legal requirements.

The legal existence of the registry does not immediately make full filings, mandatory creation of official building records, documentary access or notice transmissions mandatory. Those functions become mandatory in each region only on the date fixed by the government under section 63 (ACT RESPECTING FIRE SAFETY PRACTITIONERS).

Before those dates, the Order may operate a separate administrative pre-registry limited to monthly declarations of eligible report volumes, fee accounting and payment evidence; it is not equivalent to full documentary filing and does not create fictitious official building records.

Where several lots are concerned, all relevant lots must be entered.

For every building within its jurisdiction, each competent authority provides the registry, under its own identity, with the administrative triage key it has assigned, together with the EDF_ identifier, its own AC_ identifier and, where applicable, the area concerned. The key is unique among buildings handled by that authority and remains stable. Where several authorities have jurisdiction over the same building, the registry keeps their keys and links to the same EDF_ identifier separately.

The key may not be replaced or corrected merely at the request of a professional, owner or the Order. A change requires a written, reasoned and dated request from the authority that assigned it, allowing the registry to permanently log the requester’s identity, the old and new values, the date and the reason.

A temporary failure to assign or communicate a key is shown as administrative information to be completed; it does not block a filing or non-compliance notice. When an authority ceases to have jurisdiction, the former key and its link are preserved in the history. If no authority remains designated for the area concerned, the EDF_ identifier is classified as “EDF_ — RBQ” for lack of a competent authority under section 25 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) of the Act, subject to initial-integration rules, without the Order deciding the legal jurisdiction of authorities.

Declarations of jurisdiction identify each regulatory domain and each authority claiming jurisdiction, including concurrent powers, buildings crossing municipal boundaries, transfers and cessations without a successor. Every declaration and date is retained. The registry does not infer jurisdiction from the main doorway, the 911 call centre or the cadastral location alone.

The registry maintains a separate directory of administrative fallback telephone numbers declared by authorities, organized by regulatory area and declared territory, with the date and source of their latest verification. A dated copy, fully independent of the principal filing and consultation service, is downloadable or available through separate fallback infrastructure. Directory numbers support good-faith routing; they are not a legal ruling on jurisdiction. Unavailability or staleness of a number does not defeat the protection for a reasonable good-faith report.

Triage keys are managed separately for each authority: only the authority assigning a key may request its change in writing. The registry verifies uniqueness within that authority, date, grounds and requester identity, and permanently preserves prior values.

Each authority also retains its own dated declaration, with reasons when amended, on whether the building is subject to its filing or monitoring obligations in each of its fields. Differences among authorities are preserved without adjudication by the Order and without inference from the building category, address or cadastre.

The mechanisms described in sections 16 (REGULATION RESPECTING THE CENTRAL REGISTRY OF OPSI) and 18 (REGULATION RESPECTING THE CENTRAL REGISTRY OF OPSI) and in this section apply in a region only after legal activation and creates no corresponding duty in inactive regions.

The official competent-authorities directory also supplies one of the three autonomous public directories under section 33 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) of the Act. The public copy, hosted on the independent second server, contains only legally releasable jurisdiction declarations, territories, practice areas, official contact details and verification times. It stays usable during a registry outage without turning a directory into a decision on legal jurisdiction.

Official jurisdiction declarations received from authorities are the source of the public edition. Corrections and withdrawals are propagated by authenticated, controlled synchronization; the public copy shows its last synchronization date. No private telephone number or sensitive response information is published merely under this provision.

Each responsible professional is identified by name, professional order, permit or membership number and the electronic identifier required by the platform.

The registry retains or checks, through lawfully authorized sources, the validity periods of the right to practise, renewals, suspensions, reinstatements, restrictions and their effective dates. For members of other orders, this information comes from the appropriate professional framework; registry enrolment gives no additional right to practise.

Accounts authorized to consult sensitive records or update administrative metadata use multifactor authentication. Consultation, professional filing and administrative update permissions are separate and granted according to functional need.

For a transitional member, the registry uses the same professional authorization tables and checks as for other members; it verifies the status entered on the roll, authorized activities, limitations, validity and effective dates. This documentary check constitutes neither an additional permit nor a technical validation.

PSI identity and practice status are checked against the Order's official membership roll. The central registry holds an operational copy, but legally public fields are replicated to the independent second server under section 33 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) of the Act, without disclosing professional files, home addresses, non-public discipline records or other protected personal data.

The official list of authorized organizations, including status as holder of a single permanent transitional entitlement, identifying number, legally public delegate identity and authorization effective dates, follows the same copy, verification and publication process. Legally effective suspensions or withdrawals are prioritized for the public copy with visible status and last-synchronization time; the public service does not depend on central-registry availability.

A filing may be made electronically by an authorized third party.

The registry distinguishes the responsible professional from the person carrying out the electronic filing operation.

For every filing, the registry separately retains the SGN_ identity of the document’s professional signatory or approver, the relevant professional order and licence where applicable, and the SGN_ identity of the person carrying out the filing, the act performed, its time stamp and the basis for any delegation, without allowing personal credentials to be shared. The receipt’s DEP_ identifier is linked to the filing’s EDJ_ entry. If the person carrying out the filing differs from the professional signatory, signing the filing does not make that person a professional signatory or author of the report.

On receipt of a professional report, the automated check addresses the signatory’s authorization on the actual date of the act and on the signature date, taking the applicable history into account. The filing date is recorded separately, and later expiry does not invalidate a lawful act. The registry does not recognize as valid a professional report signed or performed without the required right to practise and records the reasons for refusal, without preventing receipt or routing of an urgent notice. The check remains documentary and does not assess system design or technical compliance.

For a transitional member, verification also includes practice restrictions and signing rights applicable to the act on the relevant dates. A pending application for admission is not independent authorization. This check does not modify rights governed by another professional order.

Where a lawfully accessible official source later corrects an entitlement period or practice limitation with effect on an earlier date, the registry preserves the previous information and the source of the correction, identifies potentially affected documents and reassesses entitlement to perform and sign each act at the relevant effective dates. Provisional or disputed information requires administrative verification and does not amount to definitive invalidation. Recognition of a document changes only where applicable law and verified information warrant it; the decision, versions and, where necessary, notices to authorized recipients are recorded in the history. A suspension taking effect after a lawfully completed act does not retroactively invalidate it.

For integrated testing, the registry links the overall report to its responsible professional and, where applicable, to independent reports and their signatories. A participant who physically performs part of the tests does not thereby sign the overall conclusions.

Before the ordinary filing of a professional document, its signatory or approving professional personally validates the actual final PDF being transmitted and its essential metadata, including the EDF_ identifiers, category, dates and professional identity. A traceable electronic attestation links that validation to the exact file version and validated metadata, notably through a cryptographic digest. An existing signature or approval may fulfill this function where it already guarantees that correspondence; no second signature is then required. A later material change to the file or those metadata requires appropriate renewed validation. Electronic filing by a third party or software remains permitted without transferring responsibility; emergency, preliminary-report and service-continuity arrangements remain in place.

The mechanisms in section 20 (REGULATION RESPECTING THE CENTRAL REGISTRY OF OPSI) and this section apply to mandatory filings in an active region and to authorized official voluntary filings before activation. They do not create any duty to file in inactive regions.

Validation applies to the complete, self-contained principal PDF of each professional version, including preliminary or final reports and their integrated documentary appendices. A separate DPJ_ file submitted with that PDF or added later is authenticated and logged as a supporting exhibit without altering the principal PDF digest, signature or approval. It may not be used to change professional conclusions without the required new validation.

Each filing must identify at least:

1° the date of the document or intervention;

2° the authorized person who assumes responsibility for it;

3° the SGN_ identifier of the person who professionally signs or approves the document and, separately, that person’s Order membership number if an OPSI member or, in other cases, the professional order or statutory basis for the person’s authorization and any relevant membership, licence or authorization number;

4° the EDF_ identifier or EDF_ identifiers (NURs) of the building or buildings concerned, issued or retrieved by the registry; if no EDF_ identifier is available at the time of an exceptional filing, the property and administrative references required for its allocation or reconciliation, including relevant cadastral lots and an address where one exists, none of which replaces the EDF_ identifier;

5° the document category;

6° the complete signed, authenticated or approved document.

7° in the case of a professional report resulting from an intervention referred to in section 8 (ACT RESPECTING FIRE SAFETY PRACTITIONERS), the applicable technical standard on which the report is based or, where no technical standard is made applicable, the applicable requirement on which the report is based.

8° for each verification, inspection or testing report filed under paragraph 1 of section 15 (ACT RESPECTING FIRE SAFETY PRACTITIONERS), the actual inspection date or, where it takes place over several days, its starting and ending dates; for a final report, the overall conclusion “compliant” or “non-compliant” recorded by the authorized person; a preliminary report distinguishes verified matters from outstanding items and makes no final conclusion about the latter;

9° for a report on a periodic intervention of that kind, the specific subject of the inspection, including the system, subsystem, equipment or area concerned, and, where they can be determined from the applicable requirement, the prescribed frequency and date of the next normally expected inspection.

10° where a statutory or regulatory periodicity applies to a document, the reference date of the monitoring cycle, the next due date, the last day of the professional work, the permanent identifier of the original filing, the distinct identifier of each version, and the reason for the new operation, distinguishing changes to the current filing from a new filing after the work has been fully repeated. These metadata do not create a verification duty not otherwise imposed by applicable law.

11° the DEP_ identifier assigned on receipt, the relevant EDF_ identifiers, the SGN_ identifier of the person carrying out the electronic filing operation and, where an authority receives a notice, its AC_ identifier; the corresponding EDJ_ audit entry remains linked to the DEP_ identifier. A person carrying out the electronic filing operation may differ from the professional signatory of the document. A temporarily unavailable EDF_ or AC_ identifier does not block an otherwise admissible mandatory filing; subsequent matching is logged without duplicate filing.

12° for integrated testing, the identity of the person responsible for the overall conclusions, independent professional contributions, the systems and interconnections covered, relevant procedures or sequences, results, limitations and tests not performed. These particulars may appear in the filed document or documentary appendices integrated in the same PDF, without additional data entry or documentary filing where their traceability is ensured.

For the purposes of the functions under section 16 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) of the Act establishing the Order, the following requirements supplement this Regulation:

Each official filing contains the information needed to identify the document or notice, the professionally responsible person, the person carrying out the filing, the building or buildings concerned, relevant dates and interventions, and linked versions and exhibits. The regulation respecting the central registry of the OPSI determines the fields, metadata and verification procedures without creating a new condition of professional authorization.

Each filing of a professional document under paragraphs 1° to 5° of section 15 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) comprises one complete, self-contained principal PDF containing the report, plan, certificate or other document concerned, including its pages, tables, diagrams, drawings and documentary appendices forming an integral part of it. The document may not be artificially divided among separate PDFs. The principal file is the one subject to the applicable professional signature, authentication or approval. Each professional version, including a preliminary or final report, separately satisfies this requirement while remaining linked to other versions of the same intervention. A report may cover several systems or buildings and standards incorporated by reference, subject to the separate reports required by section 49 (REGULATION RESPECTING THE CENTRAL REGISTRY OF OPSI).

Photographs, video or audio recordings and other technical supporting files may be associated with the filing, a notice or a factual report as separate supporting exhibits without artificially converting them to PDF or treating them as another professional report. Subsequent addition of such an exhibit does not amend the signed PDF or its professional conclusions. Changing those conclusions requires the appropriate new professional act or validation.

Non-compliance notices, changes in classification or status, follow-up statements and substantiated reports validly received through structured electronic fields do not require the artificial creation of a professional PDF. The exceptions in section 15 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) remain applicable.

The responsible professional may not allow a third party to use the professional’s personal authentication credentials.

Each filing receives:

1° a unique number;

2° a timestamp;

3° an electronic acknowledgement of receipt.

For an EDF_ identifier classified as “EDF_ — RBQ” under sections 25 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) and 20 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) of the Act, the registry makes available to the Régie du bâtiment du Québec, for the relevant areas and upon the same events and within the same time limits as for a competent authority, reportable non-compliance notices, substantiated reports requiring verification and all follow-up, change-of-classification or status, and correction notices, including automatic notices. It initiates the same notifications, delivery-failure checks and reminders. In an institutional conflict, notices reach the Régie and the competent authority simultaneously; where there is none, the Régie receives them without another recipient. Every category change, ground, relevant area, transmission and timestamp is recorded permanently, without duplicate professional notices or additional filing formalities.

For each “requiring action” notice and every recipient, including the Régie for a “EDF_ — RBQ”, the registry separately timestamps availability, flag display, electronic notification attempts, delivery failures and reminders, voluntary “Flag seen” confirmation, actual “Notice consulted” opening and voluntary “Acknowledged” confirmation. A displayed indicator does not mean “seen”; a notification sent is not necessarily technically delivered; none of these events proves an authority’s intervention. Unconsulted notices remain visible and may trigger automated registry reminders without imposing an authority duty to acknowledge or intervene.

Administrative events received from permit issuers or competent authorities also receive an acknowledgement, timestamp, operation identifier and, if an error occurs, an actionable message allowing resubmission without loss of the original transmission. Mandatory fire safety notices remain the priority.

The mechanism described in this section applies in a region only after legal activation and creates no corresponding duty in inactive regions.

A substantiated report requiring verification has a separate identifier and audit trail. It may display an informational flag 'Reported danger — verification required' on the dashboard of each legally designated authority, including the Régie where the EDF_ identifier follows the “EDF_ — RBQ” routing category, without creating confirmed non-compliance, prejudging jurisdiction or imposing duties to intervene. Facts, evidence and corrections are accessible only to authorized persons and every change retains its history. Reports and formal notices remain free throughout their lifecycle.

Each supplementary evidentiary file accepted by the registry receives its own DPJ_ identifier and is linked to an identifiable DEP_ filing number, the relevant document version or notice where applicable, and the relevant EDF_ identifiers where available; missing links are regularized without inventing identifiers. The registry retains for each exhibit: 1° its DPJ_ and DEP_ identifiers; 2° the relevant version or notice identifier, where applicable; 3° available EDF_ identifiers; 4° the SGN_ identifier of the person uploading the file; 5° its known author or source, separate from the uploader; 6° the exhibit type; 7° a short description and its relevance; 8° the actual capture or creation date and time, if known, separately from the official receipt timestamp; 9° original filename, format, MIME type and size; 10° a cryptographic integrity digest; 11° its confidentiality classification, possible personal-information content and access restrictions; and 12° references to EDJ_ entries for filing, consultation, correction and subsequent operations.

Permitted formats include photographs, video and audio recordings and technical files expressly authorized by this regulation or technical terms it authorizes. They remain in their authorized original formats without mandatory conversion to PDF. Maximum sizes, malware scanning and other security controls must be reasonable and published; compressed archives, executables and unauthorized formats must not circumvent the single principal PDF rule. Unknown capture, provenance or location details are identified as unknown; information that cannot be established is not required.

DPJ_ exhibits and their metadata are accessible only to legally authorized persons, subject to the purpose and confidentiality of each exhibit; mere access to a building record gives no automatic access to all exhibits. An exhibit may be filed with the principal document or added later by an authorized person, without altering that document or attracting another filing charge. Additions, consultation, correction and retention are logged and remain subject to the legal requirements of the related record.

Upon filing, the notice is immediately made available and marked by a new-notice flag on the dashboard of every legally entitled recipient authority, including the Régie du bâtiment du Québec where an EDF_ identifier is classified as “EDF_ — RBQ” for the area concerned under sections 25 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) and 20 (ACT RESPECTING FIRE SAFETY PRACTITIONERS). For each recipient the registry initiates the same supplementary electronic notifications, delivery-failure checks and technical reminders prescribed by the central registry of OPSI regulation made under section 17 (ACT RESPECTING FIRE SAFETY PRACTITIONERS). A real notice is routed without delay to the Régie even during the initial integration moratorium when it must receive that registry notice. The new-notice flag remains independent of the EDF_ identifier category.

The potential impact on firefighter operations, recorded for each non-compliance, is shown separately in the notice and in the structured information provided to legally authorized recipients, through both the interface and the API. This indication is neither a new non-compliance classification nor a new tracking flag, and creates no additional recipient or intervention power.

A correction may not erase the previous version.

Lifecycle events, authority affiliations, prior identifiers and links between a demolished building and its successor remain retained without retroactive rewriting. Originally signed documents remain intact.

Every correction, cancellation or substitution must indicate:

1° the document replaced;

2° the reason;

3° the author;

4° the date;

5° the new version.

Where several documents are affected by the same documentary error, including a defect in document-generation software, the registry may link them to a common incident, identify affected versions and track corrections and necessary communications for each filing. Each signed original, correction, author, date and reason remain traceable. This function does not require universal tracking of software or tools used during inspections and does not replace professional duties to correct errors.

Every DPJ_ exhibit retains its original file and initial metadata. Corrected metadata, a substituted file or a new version preserve the original exhibit identifier and a verifiable link to each new exhibit identifier, author, reason, dates, cryptographic digest and corresponding EDJ_ entries. No change silently rewrites the signed principal PDF or the original exhibit; legal retention and personal-information requirements continue to apply.

A withdrawn or replaced document remains retained with an indication of its status.

For the purposes of section 16 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) of the Act, an ordinary copy is provided by the professional who prepared or approved the document or by a professional authorized under section 19 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) of the Act and mandated for that purpose. The registry supplies that professional with an electronic function for one-off search and delivery of official documents the owner or representative is legally entitled to receive. This function does not require routine manual processing by the Order.

Before permitting extraction or transmission, the registry verifies the identity and professional authorization of the person acting as intermediary, the requester’s identity and entitlements, the authorization and the building concerned. Access is limited to the eligible document; protected third-party information is redacted without altering the original, and operations are logged. Any charges are confined to reasonable reproduction or transmission costs allowed by law and disclosed in advance. This creates neither general access to the file nor a new consultation charge; existing remedies remain available.

Where a technological problem prevents filing, the person required to file:

1° retains proof of the filing attempt and its time;

2° securely retains the document;

3° uses the registry's official backup filing mechanism where available;

4° makes or completes the filing as soon as service is restored.

During normal operation, registry unavailability does not create a general duty to send a separate notice to an authority. However, where the registry and its electronic backup mechanisms prevent transmission of a “requiring action” notice normally destined for a competent authority or for the Régie du bâtiment du Québec under the “EDF_ — RBQ” routing category, the professional must use the fallback telephone reporting procedure below, without waiting for the outage to last 24 hours.

The registry provides disaster recovery, secure queueing, duplicate-event detection and exceptional filing when an EDF_ identifier or triage key is missing. A mandatory notice is never refused solely because of an administrative identification gap; reconciliation is logged after receipt.

The official fallback filing mechanism is electronic and must verifiably confirm receipt and its timestamp. An emergency telephone call, email, postal mail, fax or physical delivery does not replace that mechanism or the filing operation that must later be regularized. The urgent telephone communications required by sections 28 (REGULATION RESPECTING THE CENTRAL REGISTRY OF OPSI) and 29 (REGULATION RESPECTING THE CENTRAL REGISTRY OF OPSI) remain mandatory in their applicable cases without being treated as official filings.

For the purposes of the functions under section 29 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) of the Act establishing the Order, the following requirements supplement this Regulation:

Where the registry and its electronic backup mechanisms are unavailable and prevent routing a non-compliance requiring action notice, the person responsible for filing makes a fallback telephone report as soon as possible, without waiting 24 hours, in accordance with section 27 (REGULATION RESPECTING THE CENTRAL REGISTRY OF OPSI) of the registry regulation. The registry makes available, independently of its principal system, a dated directory of declared and verified fallback telephone contacts. Where notices concerning a building must also be routed to the Régie for the area concerned, the Régie is among the recipients of the telephone fallback notice, in addition to any competent authority legally entitled to receive it. If the legally competent authority or its contact details cannot reasonably be determined during the outage, the professional in good faith calls the authority reasonably believed competent on the information then available or the Régie du bâtiment du Québec through the fallback channel, retaining evidence of that effort. For any authorized professional, whether or not a member of the Order, contacting in good faith an authority later found not to have jurisdiction does not, by itself, constitute a disciplinary fault or breach of this procedure in the absence of a separate fault. The person completes the filing and, if the correct authority is identified in the meantime, corrects the recipient as soon as reasonably possible. A message on an official voicemail is acceptable under the regulation without requiring a reply from the authority. The procedure does not delay any emergency communication required under another law and creates no new intervention duty for an authority.

Sections 28 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) and 29 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) and this section apply to central-registry operations in the region concerned only from its legal activation; it neither suspends nor replaces hazardous-situation reporting duties or public-authority powers arising under other laws.

A competent authority may request creation or matching of a missing building record even without a recent permit. A professional may report the omission when filing. Duplicate checks and administrative regularization follow the filing without delaying a mandatory safety notice.

Where the registry and its electronic backup mechanisms cannot route a “requiring action” notice, the person responsible for filing promptly uses the number in the last verified copy of the fallback directory, accessible independently of the registry, for the area and building concerned. If that directory is unavailable, incomplete, outdated or cannot reasonably establish legal jurisdiction, the person may in good faith call the authority reasonably believed competent on the available sources or the Régie du bâtiment du Québec through the fallback mechanism. If several authorities are reasonably identified, contact is attempted where practicable. A message on an official voicemail is acceptable without awaiting acknowledgment, unless another law requires more. The message provides the professional’s contact details, the building, the general nature of the risk and a means of calling back. The professional records the sources consulted, time, number, person contacted or voicemail left, and completes the notice when service is restored. A reasonable, documented mistake identifying the authority contacted does not, by itself, constitute a disciplinary fault, including for a professional governed by another order, in the absence of a separate fault; once the correct authority is identified, the professional corrects the recipient as soon as reasonably possible. The 911 service remains reserved for an emergency warranting its use; other legal emergency duties remain unchanged.

For a non-compliance “under documented action”, the 24-hour maximum reporting period continues to apply; however, a documented inability to use the registry and its electronic backup mechanisms does not automatically require a telephone call to the competent authority. The professional keeps the information and evidence of unavailability and completes filing as soon as service is restored, without delaying any otherwise required emergency communication.

A documented outage does not, by itself, constitute a breach of the electronic filing deadline where the professional has followed the applicable fallback procedures. The dates of identification, telephone reporting and subsequent filing remain distinct and traceable. The rights of authorities and the rules concerning immediate dangers remain unchanged.

A report requiring verification indicating immediate danger is communicated first to emergency services or the appropriate authority under applicable law; registry downtime does not justify waiting. Backup telephone contacts and protection for a reasonable good-faith error apply to disclosures outside a mandate, with unconfirmed facts identified as such where required. Subsequent electronic filing is free. Sections 27 (REGULATION RESPECTING THE CENTRAL REGISTRY OF OPSI) and 28 (REGULATION RESPECTING THE CENTRAL REGISTRY OF OPSI) and this section create neither a right of forced access to a building nor a duty for an authority to intervene.

Professional reports, fire safety plans and other ordinary professional documents are retained for at least 15 years.

The 15-year minimum is not permanent retention. Successive versions and appendices remain linked to the original filing for the applicable legal retention period. Personal information is handled under applicable statutory retention, confidentiality, destruction and anonymization obligations.

Technical and historical data that do not constitute personal information are retained permanently to the extent permitted by applicable law. Properly anonymized data may be retained over the long term when lawful, consistently with legitimate purposes and applicable anonymization rules. Originals containing personal information remain subject to their own retention periods, access restrictions and destruction or anonymization requirements. Merely removing names does not establish lawful anonymization.

The minimum periods in this section apply to registry documents; they do not prescribe the minimum period for independent professional records maintained under the regulation on keeping, preservation and transfer of records.

DPJ_ exhibits associated with a professional document, and their exhibit versions, follow the legally applicable retention period for the related record, subject to personal-information protections, stricter retention rules and statutory exceptions. Linkage history is retained without making the retention of a file permanent after its lawful period has expired.

Notices relating to non-compliance under documented action or requiring actions, changes in classification or status, and corresponding follow-up or correction documents are retained for at least 25 years.

This 25-year minimum does not remove permanent retention of only the essential administrative metadata identifying buildings, their lifecycle and authority affiliations required by section 14 (REGULATION RESPECTING THE CENTRAL REGISTRY OF OPSI), subject to applicable personal-information laws.

The record of an unconfirmed substantiated report retains its provisional status, sources and verification, correction or administrative-closure actions. Document retention and access are limited by legal necessity and proportionality; no unauthorized publication or disclosure may turn it into confirmed non-compliance. Traceability of verified facts and changes is preserved.

DPJ_ exhibits associated with a non-compliance notice, status change, follow-up or substantiated report follow the corresponding record’s retention rules and its necessity, confidentiality and personal-information safeguards; an unverified report does not, solely on that basis, automatically attract the retention period for a confirmed formal notice.

Every EDJ_ audit-log entry is retained for at least ten years after the operation it records. Throughout that period, the integrity of the entry, the corresponding SGN_ identity, evidence of the operation’s signature and the references needed for verification must remain usable.

The 10-year minimum does not replace the permanent history of EDF_ identifiers, creation, cancellation and demolition events, reference changes and declarations of jurisdiction. Those essential events are recorded in a separately protected history without retaining every technical log or item of personal information indefinitely where not legally justified. The SGN_ identifier and the historical cross-reference required to attribute past actions to their actor remain preserved after that person leaves, dies or retires, subject to applicable personal-information protection laws.

Every operation under section 14 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) of the Act automatically creates a verifiable EDJ_ entry linked to the authorized person’s SGN_ identifier. The record includes the reason, reliable date and time, authorization, scope, relevant identifiers, outcome and evidence required to verify the electronic signature of the operation. Consultations and retrievals of copies are signed only as registry operations; they do not create a professional signature on a report. Traceability must be verifiable for both the interface and API, including where an identified user is refused access.

Each entry identifies:

1° the unique EDJ_ identifier of the entry and the SGN_ identifier of the authenticated natural person to whom the operation is attributable;

2° the exact date and time of the operation, in Coordinated Universal Time, using a reliable and verifiable time stamp;

3° the precise nature of the operation, including a search, consultation, filing, observation, reading a notice, approval, retrieval of a copy, download, correction, modification, deletion or refused attempt;

4° the relevant EDF_, DEP_, AC_, EDJ_ or other identifiers, documents, versions or data concerned and the actual scope of the operation;

5° the declared reason, with a verifiable reference to the mandate, request, file, investigation or legal basis, as applicable;

6° the personal authorization actually relied upon, its scope and its validity period at the time of the operation;

7° the outcome of the operation, including acceptance, refusal or failure;

8° the organization, function and capacity in whose name the person acts, where applicable;

9° the channel used, including the interface or API, and the technical information necessary to verify authentication, integrity and traceability, without excessive collection of personal information;

10° reliable electronic evidence linking the authenticated person, the operation authorized by that person, the elements concerned and the time stamp so as to permit later verification.

Where an operation concerns the log, the entry must indicate its scope.

Consulting the audit log, including a consultation covering several entries at once, creates a separate EDJ_ entry bearing the viewer’s SGN_ identifier, the precise set of entries or actual range reviewed, the reason and the outcome. Reading several entries does not permit logging to be omitted or access beyond that person’s permissions.

For a consultation or transmission to a coroner or an authorized member of a police force under section 21 (ACT RESPECTING FIRE SAFETY PRACTITIONERS), the log also identifies the relevant police force or coroner's office, the verifiable reference for the investigation or inquest, the authorization relied upon, the records and documents actually accessed or transmitted, and the dates and times of the operations. Access to amendment histories and to the audit log itself is recorded to the same standard, without public disclosure of this confidential information.

Every individualized search or consultation and every download or retrieval of a copy is electronically signed as a registry operation by its SGN_ actor, using a verifiable method suited to that operation. This signature attests to the registry action, not the authenticity or professional approval of the report viewed or downloaded; it never makes the viewer a signatory of that document.

For an automatically executed action, the log identifies its technical nature, originating process and, where one exists, the EDJ_ identifier of the triggering operation. It retains the SGN_ identifier of the person who initiated the chain or, where no person initiated it, of the individual officially designated as responsible for that process, without falsely attributing a manual act or professional signature to that person. Attempts made before authentication for which no SGN_ identity can be established are retained in a separate technical security log; they must not be falsely attributed to another person and are linked to audit entries if later attribution becomes verifiable.

The automatic entry of an operation in the log does not constitute a new operation to be logged.

The transitional pre-registry must maintain an audit trail appropriate to declarations and payments without being treated as the comprehensive documentary access log required after activation.

For every notice and recipient authority, logging separately records receipt of the filing by the registry, availability and display of its flag, notification attempts and delivery failures, reminders, “Flag seen” confirmation, “Notice consulted” opening and “Acknowledged” confirmation. A missing event must not be replaced by a presumption of reading or intervention.

For the purposes of the functions under section 14 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) of the Act establishing the Order, the following requirements supplement this Regulation:

Every consultation, search, extraction, transmission, modification, correction, deletion, attempted access or other operation performed on the registry is entered in an audit log.

Every consultation, search, extraction or other access to the audit log is also entered in that same log.

This obligation applies to every person, including:

1° members and employees of the Order;

2° the Minister responsible for the administration of the Fire Safety Act and persons acting under that Minister’s authority;

3° delegate bodies;

4° technology administrators;

5° persons responsible for an investigation, audit, inspection or verification.

An entry may not be deleted or modified after it is created.

A technical correction must preserve the original entry and create a new entry indicating the correction, its author, date and reason.

Any attempt to modify, delete, disable or bypass the log must itself be entered to the extent technically possible.

The log is confidential.

Every access to the audit log itself, including a search, consultation or extraction, is signed as an operation and recorded under a separate EDJ_ identifier bearing the authorized person’s SGN_ identity, the reason, date and time, scope actually reviewed and outcome. A grouped review of ten entries, for example, may create a single consultation EDJ_ entry if it unambiguously identifies all ten entries examined; it confers no additional access rights.

This rule also applies to access by:

1° the Order;

2° the Minister responsible for the administration of the Fire Safety Act;

3° an administrator;

4° an investigator;

5° an auditor;

6° a delegate body.

Automatically writing that new entry does not itself generate another entry, in accordance with section 14 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) of the Act; the duty arises again only when a person or distinct process actually consults the log.

EDJ_ audit-log entries are protected against alteration and deletion. Their identifier, SGN_ code, time stamp, references and electronic evidence of the operation remain verifiably linked; a correction is made through a new entry linked to the original rather than by rewriting it.

Backups necessary to preserve the integrity of the log are kept separately from the operational database where reasonably possible.

Verified backups, a continuity plan and restoration mechanisms protect data, versions and administrative events. Access permissions are revocable and reviewed periodically.

Before any professional consultation under section 19 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) of the Act, the user is personally authenticated under that user’s SGN_ identifier, within their individual permissions, and states:

1° the EDF_ identifier of the building, or references enabling the registry to determine it before document access;

2° the professional purpose of the consultation;

3° the nature of the mandate, statutory function or prior express request for an offer of services or assessment of a contemplated mandate;

4° the identity and capacity of the person for whom the user acts, where acting on behalf of another;

5° where mandated to provide a copy to an owner or representative, a verifiable reference to the mandate and the relevant document or building;

6° for pre-mandate consultation, the date and verifiable reference of the prior request, the identity and capacity of its author, and the professional need expressed, without requiring a price, offer or previously defined mandate;

7° the user’s professional capacity and a reference enabling verification of authorization where this has not already been confirmed by the registry. Merely being permitted to upload a document on behalf of another person does not constitute authorization to consult.

For personal consultation of a document the person has signed or professionally approved, the holder must indicate the authorized purpose related to that act; a current mandate from a former client need not be declared. The registry verifies the person’s identity and professional responsibility for that document without reusing the former employer’s account. The search, consultation or retrieval of a copy receives its own operation signature and EDJ_ reference, without attributing the document’s professional signature to the viewer.

Access is based on a personally authenticated SGN_ identity, declared and verifiable permissions and a stated reason; it is subject to subsequent review. Rights are assigned and revoked by individual and function, including for staff of competent authorities, the Régie du bâtiment du Québec, police forces and the Coroner’s Office; an SGN_ identifier does not itself confer any consultation right.

A ‘My reports’ function enables a duly authenticated authorized professional to retrieve only documents they signed or professionally approved, together with their relevant versions and rectifications, within section 19 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) of the Act. Searches, consultations and exports are logged and limited to authorized purposes. Unusual use may be reviewed without any automatic presumption of misconduct or access to the former employer’s client portfolio.

The “My reports” feature remains targeted access to filed documents and is neither general access to working papers held by an employer nor a replacement for the independent professional record.

A function separate from “My reports” allows an authenticated member of the Order or any other person authorized under section 19 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) of the Act to consult, on an occasional basis, official documents needed for a professional mandate or a function lawfully performed concerning the building identified by its EDF_ identifier, within applicable disclosure rights. Access does not depend on a filing being required under the mandate or on the user being the signatory of the documents consulted. When copies are supplied, access is limited to documents the owner or representative is legally entitled to receive. Searches, extractions and transmissions are logged and limited to the verified purpose, with no general or permanent access to another person’s files.

For a prior express request for an offer of professional services or an assessment of a contemplated mandate under section 19 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) of the Act, the registry distinguishes that purpose from an existing mandate and records the date and verifiable reference of the request declared before access. Occasional consultation may enable the professionally authorized person to assess their competence, capacity or availability, determine the feasibility or scope of the contemplated mandate and prepare an offer, even where no price is stated or offer ultimately submitted. Reading rights are limited to the EDF_ identifier and lawfully disclosable information needed for the declared purpose; operations remain traceable and subject to subsequent review, without routine manual processing by the Order or searches for clients or contact details for prospecting purposes.

Each search, document opening, consultation, download or retrieval of a copy generates an EDJ_ entry signed as an operation by the relevant SGN_ individual. This access attestation does not make the viewer a signatory of the report and does not change the identity of the professional responsible for the filing.

Fees payable for a filing or a registry-related service are those determined by the Regulation respecting funding of the Order and registry fees.

Eligible preventive reports, substantiated reports requiring verification, formal notices of non-compliance under documented action or requiring action, changes of classification, supplements, correction notices and corresponding administrative closures are received, routed, tracked and processed entirely without fees, during or outside a mandate. Receipt and follow-up may not be conditional on payment or subsequently invoiced. Only separate filings of eligible professional reports and documents under paragraphs 1 to 5 of section 15 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) of the Act remain subject to the ordinary fee, without duplicate collection.

For each paid filing, the registry retains the applicable fee amount and invoicing status for administrative traceability without altering the professional content of the filed document.

The transitional establishment charge, initially set at $10 and then indexed under the regulation made by the Minister responsible for the administration of the Fire Safety Act under the Act, applies at the annual rate to eligible reports before activation pursuant to section 35 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) of the Act and the financing regulation. The pre-registry does not store the full report, and the transitional charge is not a filing. Official voluntary filing under section 69 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) is distinct from that process and does not entail a second charge for the same report. The ordinary charge takes over without duplicate charging.

Each chargeable document retains a single chain linking the original filing, its corrections and later revisions, without erasing earlier versions. Metadata identify the cycle reference date, the next due date and the basis for its calculation under section 15 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) of the Act.

The Order may process registry information to produce the anonymized and aggregated statistics provided for in section 14 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) of the Act.

Those statistics may include:

1° the number and type of non-compliances;

2° correction rates and correction times, with closures based on requirements that no longer apply counted separately from verified physical corrections;

3° changes over time and progress curves;

4° distribution by system type, activity or any other relevant category;

5° provincial or territorial trends where anonymity can be preserved.

Before any publication or disclosure, the Order applies the anonymization, aggregation, suppression or grouping measures required so that it is not reasonably possible to identify, directly or indirectly, a person, professional, owner or building. Categories or cross-tabulations containing too few observations are grouped or suppressed where necessary.

Format, protocol and interoperability specifications are set out in the registry technical specification prepared and revised by the technical committee and approved by the board under section 17 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) of the Act. Each version is published with its effective date and transition arrangements; it changes no right, duty or safeguard established by statute or regulation.

Authentication, professional validation of filings, file integrity, per-operation permissions, data minimization, confidentiality and logging apply equally regardless of channel. An application acting for a user and the person carrying out the filing as distinct from the signatory remain identifiable. Any express confirmation must actually be requested and may not be inferred from an automated read. Individual operations use an authenticated personal SGN_ identifier retained in the corresponding EDJ_ entry, including where software, a third party or a technical account submits the call. Electronic signing of the operation remains distinct from any professional signature on the document.

An insurer may use the API for a targeted consultation about a building it is considering insuring, within the limits of the information set out in section 23 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) of the Act, after authentication and declaration of a genuine verifiable insurance application file. Prospecting, automated exploration of several buildings and bulk extractions remain prohibited on either channel.

A competent authority or the Régie du bâtiment du Québec may integrate through the API the information and operations to which it is entitled into its information systems, subject to its authorizations and the legal restrictions on modifying records.

The same secure transfer functions are available for the principal professional PDF and DPJ_ supporting exhibits, with receipt, integrity checks, metadata, permissions and acknowledgments equivalent to those of the Web interface.

Geographic coordinates and their metadata are available through the API only within the user’s legal scope. Their format and presentation arrangements are governed by the technical specification and confer no additional access right.

Every operation offered through the registry’s electronic interface is also offered through a secure application programming interface, in accordance with the regulatory procedures. Subject to the functions legally authorized, this equivalence includes filing and consulting documents, notices, supporting exhibits and information, and the corresponding acknowledgments of receipt.

Choosing between the interface and the API creates, removes or changes no legal right. A person or organization may perform an operation through the API only if entitled to perform the same operation through the interface. The same rules governing professional capacity, mandates, purposes, consent, professional signature or approval, confidentiality, authentication, per-operation authorization, security, auditability and lawfully prescribed fees apply to both channels. Confirmations requiring an express act may not be presumed merely from a read request. Every individualized operation, including a consultation or download, remains attributable to the individual’s identity and the corresponding audit log entry; the use of an application or technical account must not obscure the individual on whose behalf it acts.

Technical permissions are scoped to each function, revocable and logged. Reasonable rate, volume and security limits must not amount to a general refusal to offer through the API an operation lawfully available through the interface. Bulk searches, prospecting and access outside the authorized purpose remain prohibited under their own rules. Procedures are specified in the regulations made under sections 17 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) and 42 (ACT RESPECTING FIRE SAFETY PRACTITIONERS).

When a delegated central labour organization or independent association uses the API, each request complies with section 24 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) of the Act and the external-access regulation: an authenticated eligible organization, individual user, authorized building, valid representation and, for a central organization, a current written delegation. The response contains only the existence of the current notice requiring action, its nature and deadline; it supplies no general premises list, worker identity, document or historical extraction. An affiliated association has no autonomous API access alongside its central organization.

For a legally authorized competent authority, the dashboard and API shall support, subject to applicable metadata and access rights, searching or filtering for:

1° buildings with at least one inspection report whose overall conclusion is “non-compliant”;

2° buildings with a non-compliance requiring action still in effect;

3° non-compliances under documented action with approaching correction deadlines, within a configurable search window;

4° normally expected periodic inspections for which no corresponding report has been filed after the grace period set out in this section;

5° buildings with successive inspection reports concluding “non-compliant” for the same type of inspection, system or subsystem, and reference standard.

The Régie du bâtiment du Québec’s province-wide read-only dashboard, subject to administrative consultation acknowledgments, supports searches and statistics by municipality, administrative region, building category, non-compliance type, status and age of records. It separately displays “EDF_ — RBQ” records, the applicable grounds including those prescribed by regulation under section 20 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) of the Act, the relevant areas, EDF_ identifier and available administrative keys. During the 18-month initial-integration period, a provisional lack of designation alone does not mass-classify records with no actual notices; institutional conflicts and actual serious notices filed with no designated authority appear without delay in this section. The same functions are available through the API within section 20 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) of the Act. The ordinary “new notice”, “Flag seen”, “Notice consulted” and “Acknowledged” tracking flags are retained independently of the EDF_ identifier category. Filters use available metadata and reliable administrative sources without imposing additional reporting on professionals. Building-identifying information remains confidential and third-party disclosure remains subject to section 14 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) of the Act.

The missing-expected-report filter uses only a schedule that can reasonably be determined from an applicable requirement and reliable registry metadata. It flags the absence of a filing after a 30-day grace period following the normally scheduled inspection date: an annual inspection expected one year after the previous one is therefore flagged if no corresponding report is filed one year and 30 days after that inspection.

This grace period is solely for classification and display of a monitoring indicator. It does not extend the legal filing deadline in section 7 (REGULATION RESPECTING THE CENTRAL REGISTRY OF OPSI), create a new inspection requirement or by itself establish proof of a breach. Where the frequency or reference date cannot be established reliably, the registry shall not presume that an inspection is overdue.

Filters use only the reports and notices already required; they do not impose a separate individual record for each apparent anomaly or deficiency identified in a report. Building-identifiable access remains restricted to authorized competent authorities, while summary data communicated for statistical purposes is anonymized in accordance with the statutory confidentiality requirements cited above.

Administrative interfaces and APIs available to permit issuers and competent authorities allow records to be created, permit and demolition events to be transmitted, jurisdiction to be declared and triage keys to be managed without systematic manual processing, each according to applicable access rights. System-to-system exchanges are authenticated; where an application acts on behalf of a user, delegated authorization uses a three-party OAuth-type protocol with appropriate safeguards. Separate mechanisms are provided for direct exchanges between authorized systems.

Security measures include multifactor authentication for sensitive users, documented least-privilege APIs, separate reading, filing and updating permissions, and a permanent log of essential administrative events. Continuity and disaster recovery prevent the loss of mandatory notices.

The simplified systems and equipment directory may support filters, but the mere presence of equipment or an “undetermined” entry does not establish that a periodic inspection is legally required. A report is flagged as potentially missing only where the requirement, subject matter and due date can be established from sufficient reliable information, retaining the existing 30-day grace period.

API operation identity distinguishes, as applicable, the application or technical service, the organization holding access, the authorization holder, the triggering user or service, the professional who validated the document and any separate person carrying out the filing. Technical authorizations are scoped, revocable and renewable; shared credentials that prevent attribution of operations are avoided. Authentication secrets are never recorded in clear text in the audit log. These arrangements confer no additional viewing or filing rights.

The mechanisms described in sections 40 (REGULATION RESPECTING THE CENTRAL REGISTRY OF OPSI) and 41 (REGULATION RESPECTING THE CENTRAL REGISTRY OF OPSI) and in this section apply in a region only after legal activation and creates no corresponding duty in inactive regions.

On receiving a construction permit for a new covered building from an authorized issuing authority, the registry checks for an existing matching record, creates a building record, issues its EDF_ identifier and sets the state to “Authorized project”. The EDF_ identifier is returned to the permit issuer in the acknowledgement.

Upon receiving reliable administrative information confirming completion or occupancy, including an occupancy certificate where one exists, the state becomes “Active building”. Initial property taxation or entry on the assessment roll may serve as supplementary verification, not the primary trigger.

The mechanism described in this section applies in a region only after legal activation and creates no corresponding duty in inactive regions.

Transmission of a demolition authorization changes the state to “Demolition authorized” without archiving the building. Actual demolition, confirmed by the authority possessing the information, changes the state to “Demolished building — archived” and removes the building from the active inventory without deleting its EDF_ identifier or history.

Final cancellation of an authorized project or confirmed abandonment changes the state to “Cancelled project”. A EDF_ identifier assigned to a cancelled project or demolished building may never be reused.

A new building replacing a fully demolished building receives a new record and a new EDF_ identifier even if the address, owner and lots are unchanged. The registry preserves a historical link to the previous building without automatically carrying over its non-compliances.

Renovations, extensions, conversions and changes of use do not automatically produce a new EDF_ identifier. The competent authority concerned provides its administrative determination based on physical and functional building identity and on requirements within its responsibilities. The registry performs technical matching checks and implements joint decisions or, in a persistent dispute between authorities, the Régie’s limited administrative determination; it decides neither legal jurisdiction nor each authority’s applicability declarations.

Every covered professional document, whether delivered to a client or filed, displays its EDF_ identifier in the header or footer of every page, including appendices created as part of the document, fire safety plans, PDFs, revised versions and professionally approved evacuation documents. A mention only on the cover, in a filename or only in metadata is not sufficient.

The EDF_ identifier is inserted before final signing or approval. Where an original or previously signed exhibit cannot be altered without affecting its legal value or integrity, a linking sheet showing the EDF_ identifier on each of its pages and a permanent technical association are attached without changing the original content. Restrictions governing publication or disclosure of protected exhibits continue to apply.

If no EDF_ identifier exists when the document is prepared, allocation may be requested before signing. For an urgent safety filing, the registry exceptionally accepts available references and performs subsequent matching; that exception does not authorize omission of the EDF_ identifier from subsequent documents once it has been assigned.

For a report linked to several EDF_ identifiers, all concerned EDF_ identifiers remain legibly identifiable in the header or footer of every page, including appendices produced as part of that report. A compact or multi-line presentation may be used according to the number of buildings; a mapping schedule may supplement, but not replace, identification on every page.

The mechanism described in this section applies in a region only after legal activation and creates no corresponding duty in inactive regions.

The page-by-page display requirement applies to the principal professional-document PDF and its paginated documentary appendices. It does not require altering the original photograph, audio or video recording or other separate DPJ_ exhibit: permanent electronic linkage through DPJ_ metadata and EDF_ identifiers identifies those files. This exception must not be used to artificially extract pages or documentary appendices forming part of the principal PDF.

For the purposes of the functions under section 16 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) of the Act establishing the Order, the following requirements supplement this Regulation:

Professional documents governed by the Act establishing the Order are associated with the record of the building or buildings concerned in accordance with the requirements prescribed by the regulation respecting the central registry of OPSI. This association must reliably link documents, their documentary appendices and versions to each building record.

Regulatory procedures safeguard the integrity of previously signed originals, permit subsequent reconciliation where the initial association cannot be established and distinguish the principal professional PDF from separate supporting exhibits. They may not prevent receipt of an urgent notice or require an original supporting exhibit to be altered to add a technical marking.

The registry permanently retains each building’s administrative identity, EDF_ identifier, essential lifecycle events, changes of address and lot, historical references, jurisdictional affiliations and links between successive buildings. These data are protected against retroactive rewriting and correction leaves a trace.

The 15-, 25- and 10-year minimum periods applying to ordinary documents, non-compliance notices and technical logs respectively do not guarantee permanent document retention. Personal-information retention, deletion and anonymization comply with applicable law; the registry distinguishes necessary permanent metadata from records no longer lawfully required to be retained.

Permanent history also covers each filing's links to the affected EDF_ identifiers and any expressly declared changes to those links, requests and decisions concerning record mergers or subdivisions, each authority's applicability declarations and administrative determinations of the Régie. No event rewrites prior documents or identifiers.

Each document’s metadata include the field “Contains personal information: Yes / No / To review”. “To review” requires an assessment before any extended-retention or disclosure decision, without blocking a filing or access expressly required by law. Retention, use, access, destruction and anonymization of personal information comply with applicable purposes, time limits, safeguards and legal requirements, including the framework modernized by Law 25 and the anonymization rules. Restrictions on access to sensitive information remain in force.

DPJ_ exhibits and their metadata are subject to the same necessity, confidentiality, access-restriction and logging principles as the related record, assessed separately for each file. Authorization to view a principal document does not automatically authorize access to every supplementary exhibit; applicable permissions are checked before any disclosure, including through the API.

The regulation distinguishes permanent retention of essential identifiers and administrative events from minimum retention periods for documents and logs. It provides confidentiality, security and personal-information safeguards consistent with applicable law. Permanent institutional memory includes non-personal technical and historical data and, where lawful, properly anonymized data; it does not justify indefinite retention of originals containing personal information.

When a professional report covers one or more buildings, the filer designates the corresponding EDF_ identifiers in a single filing operation. Those EDF_ identifiers define only the buildings to which that report is linked.

The linkage is specific to the filing and creates no permanent building grouping, collective identity, merger or subdivision. The buildings' EDF_ identifiers and each authority's jurisdiction and applicability declarations remain unchanged.

The mechanism described in this section applies in a region only after legal activation and creates no corresponding duty in inactive regions.

The registry retains one official document for a filed report and assigns a single DEP_ identifier regardless of the number of affected EDF_ identifiers. No additional physical copy or separate report identifier is created for each building.

Subject to existing access rights, each affected building record gives access to that same official document and DEP_ identifier through a technical link to the single registry record. The metadata specifies the scope covered for each EDF_ identifier where relevant.

Where a report concerns several buildings, a person authorized to consult one building’s record may access only information within that person’s legally authorized scope. Where necessary, the registry presents a view or extract in which inaccessible portions are redacted, without granting access to information relating to another building. The official signed report remains preserved in its entirety, together with its integrity, versions and history, for the legally applicable retention periods. That view or extract is neither a new professional report nor a new filing. Persons legally entitled to consult the complete report retain access within the limits of their rights.

The mechanism described in this section applies in a region only after legal activation and creates no corresponding duty in inactive regions.

For the purposes of the functions under section 16 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) of the Act establishing the Order, the following requirements supplement this Regulation:

Each intervention subject to a standalone requirement directly imposed by the Safety Code, the fire prevention code it incorporates or an applicable municipal by-law produces its own professional report. Checks under a standard incorporated by reference in the directly required standard may be included in that report, without a separate report or filing fee solely because of that reference.

The report may be filed in one operation and linked to several covered buildings. These links and incorporated technical references do not, by themselves, create additional reports; reports responding to independently and directly imposed requirements each retain their own filing.

Separate reports remain necessary where a legally applicable requirement or the actual independence of the interventions and professional conclusions requires them. An overall integrated testing report may attach or refer to relevant independent reports without artificially duplicating them or requiring a second filing of the same document.

Where several lots are directly concerned, each relevant lot must be indicated.

The registry assigns a unique number to each filing.

On receipt of a professional report, the registry automatically verifies, using lawfully accessible information on the signatory’s authorization and its history, that the person had the legal right to perform and sign the act on the dates those acts actually occurred. The dates of the act, signature and filing are distinguished. A document for which the required authorization is not established cannot be recognized as a valid professional report; any refusal and its reasons are recorded without erasing the received document or event. A subsequent permit expiry does not retroactively invalidate a lawfully performed act. Difficulty with administrative verification must not prevent the preservation or routing of an urgent report. This documentary check is not a design or technical-compliance review and creates no new authorization for members of other orders.

It preserves the traceability of corrections, replacements and versions.

Filing does not constitute approval, certification or validation of the document by the Order.

A report’s overall “non-compliant” conclusion is tracking metadata. It does not, by itself, create a separate record for each apparent anomaly or an individual non-compliance notice: any separate reporting obligation remains governed by the Act establishing the Order.

The report precisely identifies the buildings, systems, subsystems, equipment or installations covered and their EDF_ codes; where an installation serves several buildings, the same filing may be linked to each code. The distinction between a directly imposed requirement and standards incorporated by reference follows section 49 (REGULATION RESPECTING THE CENTRAL REGISTRY OF OPSI). The filing fee remains governed by the funding regulation; linking several EDF_ codes does not artificially multiply the filing.

A correction, revised version or new iteration of a report retains its EDF_ identifier links by default. Each addition or removal of an EDF_ identifier must be expressly declared; the registry logs the date, author and history without altering earlier filings or versions.

A non-compliance recorded in a report linked to several EDF_ identifiers may affect one building or several of them. The notice identifies the EDF_ identifiers actually affected by that non-compliance and retains a single notice identifier, with the necessary links to prevent duplicates.

Notices and their follow-ups are routed to each legally entitled recipient authority according to the declared areas of the buildings concerned. For each EDF_ identifier classified as “EDF_ — RBQ”, the Régie du bâtiment du Québec receives, for the areas giving rise to that classification, the same notices, reports, status changes, follow-ups and corrections that a competent authority would receive, without creating a new professional notice. In an institutional conflict the authority concerned continues to receive them simultaneously. Classifications, deadlines, tracking flags and action procedures remain unchanged.

The registry may maintain a simplified directory for the main families of fire safety systems and equipment in a building identified by its EDF_ identifier, with each entry marked “present”, “absent” or “undetermined” and showing the source and date of the last reliable information.

Directory data are obtained primarily from competent authorities, administrative references and sufficiently reliable information already contained in professional documents normally filed in the registry. Their source, date, accuracy and verification status are retained. Maintaining this directory does not require any standalone system-identification filing by an engineer, a professional technologist or anyone else. Uncertain data are marked as such and may not be presented as a complete inventory or compliance certificate.

The presence of equipment creates no inspection obligation. A report is flagged as potentially missing only where the applicable requirement, subject matter and due date can be reliably established; missing or uncertain equipment information does not create a new non-compliance notice.

A legally authorized professional who actually observes, within the scope of a mandate, a system not listed in the simplified directory may have that observed presence added, stating the source, date and scope of the observation, without producing an additional professional report or inventory. This documentary entry is neither approval of design or installation, nor a compliance attestation, nor certification of a complete inventory. This optional administrative update creates neither an additional professional report nor a filing fee.

The mechanism described in this section applies in a region only after legal activation and creates no corresponding duty in inactive regions.

Competent authorities submit requests to correct identity, merge or subdivide building records and their administrative associations through a logged procedure. The registry checks duplicates and effects on identifiers without replacing the authorities in determining applicability or legal jurisdiction.

Where a change affects the shared identity of a building attached to several authorities, their documented agreement is required. Without consensus, the existing usable record is maintained and the matter may be referred to the Régie du bâtiment du Québec under the Government Regulation and proposed section 111.1 of the Building Act.

A genuinely new identity may be assigned a new EDF_ identifier; replaced or historically linked EDF_ identifiers remain preserved and may not be reused. A mere administrative association or linking a report to several EDF_ identifiers does not cause the issuance of a new EDF_ identifier.

Authorized mergers, subdivisions, rectifications and reconciliations are carried out as controlled, historized operations. Previously assigned EDF_ identifiers and their earlier mappings, as well as links between buildings, documents, notices, authorities and decisions, are preserved without overwriting them. Affected computed indicators are recalculated from applicable data after the operation; no physical merge makes a historical EDF_ identifier untraceable.

The mechanism described in this section applies in a region only after legal activation and creates no corresponding duty in inactive regions.

As an express exception to the signatory’s personal consultation right under section 19 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) of the Act, a retired “PSI ret.” member has no permanent, general or search access to the registry, including reports previously signed by that member. The member may not file, amend, sign, approve or authenticate professional documents as a practising PSI or perform reserved activities, even without pay. Personal consultation rights of other legally authorized non-retired signatories remain unchanged. The retired member’s historical SGN_ identifier remains preserved and non-reassignable so that previous acts and consultations remain attributable; this retention authorizes no new professional signature or registry operation by virtue of retired PSI status.

An exceptional request identifies the protected right or proceeding, the precise necessary documents, purpose and requested duration. A competent authority authorizes only narrowly scoped, temporary, normally read-only, logged access that expires automatically and may be revoked when its purpose ends. Privilege, professional secrecy, privacy rules, mandatory statutory disclosure and court orders prevail. Where exceptional access is authorized, the person may use the interface or API within the same targeted scope; channel choice confers neither general search rights nor permission to file professional documents. Where the law exceptionally permits a retired member to consult records, the consultation is authenticated and signed as an operation under that person’s SGN_ identifier, with an EDJ_ entry, without making the person a professional signatory of the viewed document.

Pursuant to section 75 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) of the Act, sections 5 (REGULATION RESPECTING THE CENTRAL REGISTRY OF OPSI) and 6 (REGULATION RESPECTING THE CENTRAL REGISTRY OF OPSI) of this regulation are repealed upon completion of mandatory regional deployment.

The repeal has no retroactive effect and does not erase any file, vested right, payment or earlier act lawfully established.

This regulation is made by the Minister responsible for the administration of the Fire Safety Act under section 35 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) of the Fire Safety Practitioners Act, after consulting the Order and the Office des professions du Québec and in accordance with legally prescribed formalities, including the Regulations Act (chapter R-18.1). It fixes the central-registry and pre-registry establishment, filing and access charges, amounts, conditions for payment, exemptions, collection and refund procedures, and indexation rules. The Order only administers and collects those amounts within the prescribed limits. Members’ dues continue to be determined by the board of directors under the Professional Code.

This Regulation promotes simplicity, predictability, transparency, proportionality and the absence of private enrichment. Transitional and ordinary fees apply only to the eligible acts and documents prescribed by the Act; their proceeds support the Order’s integrated regulatory scheme without being financially earmarked for the registry function alone. Tariff-supporting records document the purpose and fee base, direct and shared costs, and reasonable needs of the integrated regulatory scheme; pooling does not authorize fees without a legal basis or excessive collections. No personal financial benefit is distributed to members.

The transitional establishment fee applies before regional documentary activation only to eligible reports; the ordinary filing fee replaces it after activation for eligible standalone professional documents. The same report may not incur both fees merely because it is later entered into the registry.

Basic dues, transitional and ordinary registry fees and legally available access charges are paid into the Order’s single general operating fund. Analytical records identify each revenue category and the corresponding costs for accountability and fee review without mandating ring-fenced accounts, source-based reserves or a general prohibition on transfers between the Order’s functions. Amounts legally subject to particular purposes remain separate, including trust funds and legally constituted insurance or compensation fund assets. Net income from general trust accounts is not part of the operating fund and is governed by section 40 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) of the Act.

Members’ annual dues are set by the board of directors in accordance with section 85.1 of the Professional Code, following consultations under sections 103.1 and 104 and subject to approvals required for special assessments. This regulation made by the Minister responsible for the administration of the Fire Safety Act neither fixes nor changes professional dues. Solely for the proposed scheme's financial planning assumptions, the envisaged basic annual dues for an active member are $250; this assumption neither imposes dues nor binds the board of directors in exercising its statutory authority.

Professional dues are separate from the mandatory contribution toward the Office des professions du Québec, other legally required contributions and, where applicable, a separate contribution to the group professional liability insurance scheme.

Before each financial year, the board reviews consolidated financial needs and prepares member consultation on dues in accordance with sections 85.1, 103.1 and 104 of the Professional Code. It considers revenues and expenses across all functions of the Order, including the registry, the roll, professional inspection, the syndic, discipline and professional liability insurance, along with commitments, justified reserves and legally unavailable amounts. Registry fees are tracked analytically to support proportionality and any review of the fee schedule by the Minister responsible for the administration of the Fire Safety Act without prohibiting the common use of revenues paid to the general fund. Any payment to the Foundation remains subject to statutory conditions and the Order’s obligations.

Any adjustment of annual dues may consider changes in costs, authorized revenues and the financial capacity of the Order. The amount determined by the board and its financial reasons are published in accordance with statutory duties after the required consultations. Any special assessment is subject to the approvals prescribed by the Professional Code.

In a legally activated region, the ordinary electronic filing fee is initially $10 per eligible standalone professional document, before any legally applicable taxes, for the categories exhaustively listed in section 5 (MINISTERIAL REGULATION RESPECTING FINANCING OF THE ORDER AND REGISTRY FEES). Before activation, the transitional establishment fee is prescribed at the same rate but applies only to eligible professional verification, inspection or testing reports. The same report cannot be subject to both fees merely because it is later integrated into the registry.

The initial $10 rate remains in force before the first regional documentary activation of the central registry and through 31 December of the calendar year of that first activation, including in regions not yet activated. Beginning the following 1 January, the rate in effect on the preceding 31 December is multiplied by the ratio of Québec’s all-items CPI for July of the preceding year to the CPI for July of the year before that, using unadjusted monthly figures published by the Institut de la statistique du Québec. If that ratio is one or less, the rate remains unchanged. The resulting amount is rounded to the nearest cent, with half a cent rounded up. Both fees have the same annual rate. Before any collection, the Order publishes the index figures, calculation, effective date and applicable rate, without power to change them. This regulatory indexation allows neither an additional charge nor a discretionary increase.

No separate fee is payable for a technical operation correcting a transmission error attributable to the registry.

After legal activation of the relevant region, only professional documents produced or approved for a covered building under paragraphs 1 to 5 of section 15 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) of the Act are eligible for the ordinary fee: 1. an verification, inspection or testing report under section 8 (ACT RESPECTING FIRE SAFETY PRACTITIONERS); 2. a fire safety plan (PDSI) approved under section 10 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) by a fire safety practitioner (PSI) or another legally authorized person; 3. independently approved professional evacuation directives, procedures or documents, together with their integrated diagrams; 4. a legally required professional exercise evaluation, report or attestation; and 5. a legally required professional attestation concerning building staff training or competence. Before activation, only the report in item 1 attracts the transitional fee. Non-compliance notices and disclosures and their follow-ups and closures, individual certificates not subject to mandatory filing, ordinary exercise reports, purely administrative documents and buildings outside the scheme remain excluded. A preliminary and final report for the same verification, inspection or test together form one chargeable filing.

Each genuinely standalone professional document under the preceding paragraph attracts only one fee regardless of the number of buildings, owners, pages, attachments, diagrams or systems concerned. Diagrams and procedures integrated into an approved PDSI attract no separate fee. Evacuation directives are separately chargeable only if they have been separately professionally approved and filed as a genuinely distinct document, rather than through artificial splitting of the PDSI. Corrections, modifications, partial reviews and retransmissions of the same current document already charged do not give rise to an additional fee. Later integration of a report already subject to the transitional fee creates no second charge. The fee is not based on floor area, property value or commercial category.

A photograph, video, audio recording or other supporting file bearing a DPJ_ identifier supplements an official filing and is not a separate professional document subject to the unit fee. The Order may not create a charge per exhibit, file, addition, legally free consultation or regularization; obligations applicable to a genuinely separate professional document remain unchanged.

Before a region’s legal activation date, and only after the Order has been legally constituted and authorized to operate, the transitional fee at the applicable annual rate is collected for each new eligible professional report. It falls under the general designation “Fee for establishment and operation of the Order and the central registry of OPSI” in section 35 (ACT RESPECTING FIRE SAFETY PRACTITIONERS), without requiring PDFs or EDF_ identifiers to be filed in the pre-registry.

An eligible professional report already subject to the transitional charge incurs no second charge upon official voluntary filing, transfer or continued retention after regional activation. Evidence of payment is reconciled with the document’s permanent identifier without treating the pre-registry declaration as a complete filing.

Voluntary filing of another eligible document before activation does not trigger the ordinary charge, and keeping it after that date creates no retrospective charge. A new standalone professional revision remains subject to any charge lawfully applicable to it.

Fictitious tests and pilot access are free of charge. The tariff rules in sections 4 (MINISTERIAL REGULATION RESPECTING FINANCING OF THE ORDER AND REGISTRY FEES) and 5 (MINISTERIAL REGULATION RESPECTING FINANCING OF THE ORDER AND REGISTRY FEES) remain unchanged.

The initial $10 fee and its indexation apply only to the eligible professional reports and documents described in section 5 (MINISTERIAL REGULATION RESPECTING FINANCING OF THE ORDER AND REGISTRY FEES), never to danger disclosures, reportable non-compliance notices, outside-mandate communications, updates, supplements, follow-ups or administrative closures relating to a report. A disclosure remains free even if the same facts appear in a PDSI, report or other professional document otherwise subject to a fee. An outside-mandate report cannot be artificially turned into a chargeable professional filing or trigger the transitional fee.

At the annual rate then applicable, a separate filing of a document in one of the five eligible categories after the professional work has been fully repeated and approved under section 15 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) of the Act is a new chargeable filing, even before the previous due date or without substantive changes. A correction, modification or partial review of the current document creates no new fee.

The registry retains the cycle reference date, the periodic due date, the original filing and every version. The next due date is calculated under section 15 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) of the Act, independently of invoicing.

The applicable fee must be shown on its own line on every invoice, payment request or collection document, stating the prescribed label, the applicable annual unit rate, initially set at $10, the number of eligible professional filings and the resulting amount. It may appear on the same invoice as professional services but must never be absorbed into or concealed within professional fees, commercial charges or any lump-sum or all-inclusive service price. It remains itemized even where a summary amount payable is shown.

Whenever a written quotation, estimate, offer of service or contractual proposal is given before service that may result in an eligible professional document, the fee must also appear on a line separate from the services. The document specifies the applicable annual rate per standalone document, the expected number and separate estimated amount when reasonably ascertainable. If the final number is not yet known, it must clearly state that the fee total depends on the actual number of eligible professional filings and explain the calculation method, without bundling the fee into a fixed service price. An unknown final total does not excuse omission of the unit rate.

Where work is arranged without a written quote, the professional, employer or authorized collector shall give the customer written notice before the work of the applicable annual rate per eligible professional document and of its separate appearance on the invoice. Any known change to the expected number of eligible filings must be communicated to the customer in writing as soon as reasonably ascertainable and before the corresponding invoice. These disclosure requirements neither authorize artificially multiplying documents or their annexes nor permit collection outside the scheme’s legal scope.

Before regional activation, the label is “OPSI central registry establishment fee — [current annual amount]”. After activation, it is “Filing fee — Central registry of OPSI — [current annual amount]”. On an actual document, the bracketed expression is replaced by the published rate in dollars and cents effective when the fee becomes payable, and is not printed literally. Both forms are part of the funding scheme defined in section 35 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) of the Act.

A professional, employer or other legally appointed collector acting for the Order may not add a markup, margin or disguised administrative surcharge. The sum is not the collector’s professional or commercial revenue.

The fee is borne by the owner of the covered building even if the service contract is with a third party. Where several covered owners are concerned by a single standalone professional document, allocation and collection follow legally enforceable rules without multiple charges. An owner of a building outside the scheme is not liable for this fee on that account.

No regulatory-fee line or processing surcharge is issued for a free disclosure. Where a separate eligible professional document exists, only that report's own filing fee may be invoiced; disclosure of the dangers described in it never produces a second line item or surcharge.

Where applicable, the invoice or receipt indicates whether the transaction is an original filing, a fee-free correction linked to the original filing, or a new chargeable professional or periodic revision, without charging twice for the same operation. The documentary linkage and validity period are preserved. A correction neither incurs a new unit fee nor postpones the next due date.

GST, QST or any other tax is added to the filing fee only to the extent required by applicable tax legislation.

Taxes collected in respect of the filing fee are accounted for separately and are not revenue of the Order for purposes of calculating the reserve or surpluses.

This Regulation creates no tax exemption that does not otherwise exist in law.

Tax treatment of the fee is determined by applicable tax law; characterization as a regulatory fee does not relieve anyone from collecting a tax legally payable.

No disclosure of reportable non-compliance, eligible preventive report, substantiated report requiring verification, or supplement, follow-up, correction or administrative closure may depend on advance or later payment of a charge. The registry immediately receives and routes these free communications. Where a separate eligible professional report is also required, a payment dispute that may endanger public protection cannot delay its filing; the fee applicable solely to that report may then be invoiced, but never extended to the disclosure.

Full or partial exemptions from the filing and transitional fees are exclusively those prescribed by this regulation made by the Minister responsible for the administration of the Fire Safety Act, subject to the protections provided by the Act. The Order applies the published objective exemptions and criteria; it may not create, withdraw or change their conditions by resolution, directive or administrative decision. Any amendment requires a regulation made by that Minister after consulting the Order and the Office des professions du Québec and observing required procedures.

Exemption criteria are applied uniformly and published in an accessible manner.

These exemptions and protections must also be observed during transitional reporting: no new fee may be charged for a document excluded from the scheme or for a correction already billed.

Free disclosure and related follow-up operations are mandated directly by the Act and are not discretionary exemptions from fees for eligible reports. Administrative amendment of this regulation cannot reduce that protection. Free receipt of a danger report never waives amounts normally due for a separate eligible professional report.

The annual fee for authorization and use of an individual professional account is $50 for a person legally authorized to file documents in the registry who is not a member of the Order and does not exclusively use an organizational account under the following paragraph. This individual fee is not charged to Order members merely because they use the registry in their professional capacity; their membership dues are governed by the board of directors under the Professional Code.

For an organization authorized to hold an organizational registry account, the annual fee is $500 plus $25 per individually authorized natural person who acts through that account during the annual period. The organization pays these amounts. Use covered exclusively by this account does not incur the $50 individual fee for the same person and period; any Order membership dues remain separate and payable under their own rules. Each person's identity and actions remain individually recorded and auditable.

Annual fees under this section become payable only once the corresponding accounts are actually available, authorized and secure. They are neither per-view charges nor a price for information retrieved from the registry. The Order cannot create or increase any additional fee. Consultations and communications expressly free or guaranteed by the Act remain so, including danger disclosures, their follow-up, and access by competent authorities, the RBQ, police, coroners and other statutory officials to the extent of their respective authorizations.

Published, objective rules govern billing, renewal, refunds and adjustments for authorization changes, without multiplying accounts or fees for a single person. Any other fee category, change in amounts or indexation specific to these fees requires amendment of this regulation made by the Minister responsible for the administration of the Fire Safety Act under the applicable statutory powers. The Order may not sell registry data or impede filings or reports whose receipt is guaranteed by the Act.

Registry fees are paid into the general fund and tracked, together with the Order’s surpluses and reserves, through auditable analytical accounts. This identification creates no separate fund, non-transferable envelope or financial restriction based on the origin of revenues. Shared-function expenditures are allocated on a reasonable, consistent and documented basis to support proportionality of regulatory fees.

Costs of the integrated regulatory scheme that may be considered in this justification include in particular:

1° legal establishment and administrative and operational organization of the Order, supported by documentation;

2° design, development, commissioning, operation, maintenance and renewal of the pre-registry and central registry;

3° professional inspection, practice oversight, the syndic, discipline and the roll, insofar as their costs are attributable to the integrated scheme;

4° cybersecurity, audit, document and data preservation, technological continuity and renewal of necessary infrastructure;

5° the Order’s other legally mandated public-protection functions, including professional liability insurance expenses paid under section 39 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) of the Act.

Unjustified expenses, those unrelated to the Order’s legal mission and private benefits remain excluded from tariff justification. Sustained fee surpluses trigger review of the fee schedule by the Minister responsible for the administration of the Fire Safety Act through the applicable legal process. Transitional and ordinary fees are tracked separately for analysis without ring-fencing or a second fee when a previously paid report is integrated.

The Order may establish a reasonable consolidated reserve within the general fund to ensure continuity of all its functions, registry security, professional obligations and approved technology commitments. The accounting origin of revenue does not earmark a reserve, subject to legally separated funds or assets.

The purposes, commitments and risks supporting the reserve are documented and its changes reported annually. Unless a duly substantiated exceptional commitment warrants otherwise, the free reserve should not exceed twelve months of the Order’s budgeted consolidated operating expenses. Review of the reserve does not displace justification of regulatory fees against the integrated scheme.

After year-end closing and approval of audited financial statements, the Order determines the general fund’s consolidated balance and net surpluses after debts, refunds, mandatory expenses, commitments and necessary reserves. Analytical records distinguish sources and costs for tariff justification without ring-fencing surplus amounts according to their source.

A net general-fund surplus may be paid to the Fondation de l’Ordre des praticiens en sécurité incendie designated in section 38 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) and identified under section 58 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) of the Act only if that Foundation is entitled to receive it and the payment is authorized by law and compatible with the Order’s obligations. Such a payment may not divert legally protected amounts or support unreasonable regulatory fees; the board and the Minister responsible for the administration of the Fire Safety Act shall undertake any fee review required by the Act. No amount owing to a client or creditor is a surplus.

Net interest on general trust accounts is remitted directly to the Foundation, once it can lawfully receive it, under section 40 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) of the Act and its implementing regulations; it is included neither in the single fund’s receipts nor in the calculation of its surpluses. Pending lawful remittance, interest is held separately under the applicable trust-account scheme. Each year the Order separately publishes single-fund surplus transfers and amounts remitted directly from trust interest with relevant supporting information.

No revenue of the Order’s general fund may be distributed to members as profit, rebates, dividends, practice-volume discounts or other personal financial benefits. This does not bar legally authorized public-protection expenses, including payment for a group professional liability plan under section 39 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) of the Act. Any transfers to the Foundation remain subject to section 38 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) of the Act and section 17 (MINISTERIAL REGULATION RESPECTING FINANCING OF THE ORDER AND REGISTRY FEES) of this Regulation.

This section does not prevent normal reimbursement of an expense incurred on behalf of the Order or payment of reasonable compensation for work actually performed in accordance with applicable governance rules.

Premiums, contributions, administration expenses and other eligible costs of the group professional liability plan may be paid in whole or in part from the general fund, regardless of the accounting source of revenues paid into that fund, under section 39 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) of the Act and its targeted derogation from section 85.2 of the Professional Code.

The board documents the plan’s full cost, the portion paid by the Order and, where applicable, the portion apportioned among members or classes under the Professional Code. Amounts charged directly to members are shown separately from annual base dues. Assets and reserves of any legally separate insurance fund remain protected by applicable law and do not become general assets of the Order.

The Order’s annual report presents the consolidated general-fund statement, analytically breaking down professional dues, insurance contributions, transitional fees, ordinary filing fees, legally available access charges and other revenues. Expenses are classified by function, including the roll, inspection, syndic, discipline, pre-registry, registry, administration and insurance. Legally protected resources and commitments, provisions, reimbursements and surpluses are identified without treating registry fees as a separate treasury.

For registry fees, the report provides the direct and shared costs of the integrated regulatory scheme and the allocation method, volumes of billable reports and documents, refunds, consolidated reserves, variances and steps taken to maintain tariff proportionality. Persistent discrepancies are referred to the Minister responsible for the administration of the Fire Safety Act, the only authority empowered to revise the fee. Any permitted Foundation payments and net income paid directly from general trust accounts are separately reported, without including the latter in general-fund revenue.

The annual statement distinguishes inactive and activated regions and genuinely available access services without counting the same report twice.

During the transitional period, the responsible professional or legally authorized employer submits a secure written monthly administrative declaration identifying the person, period, report categories and count, references preventing duplicates, amounts invoiced, received and remitted, and adjustments. The pre-registry reconciles declarations, fees and receipts without requiring complete report PDFs or fictitious EDF_ identifiers.

The procedure governs omitted declarations, corrections, cancellations, refunds and verification under confidentiality safeguards.

The annual report publishes the unit rate applicable to each eligible filing and, during the transition, each report, for each year, the first regional documentary activation date, the Québec all-items CPI for the two relevant July months, the indexation formula, rounding and effective date. It distinguishes automatic indexation under this regulation made by the Minister responsible for the administration of the Fire Safety Act from any legislative or regulatory change creating a new fee; it publishes the costs of the integrated regulatory scheme and the methods of allocation used to establish proportionality without source-based earmarking.

The annual accounting distinguishes the number of eligible professional reports and other documents charged, broken down by category from free disclosures, reports requiring verification, formal notices, supplements and administrative closures. No free disclosure volume may be counted as a chargeable professional filing. Processing costs for those communications are eligible regime expenses only to the extent permitted by law, without creating a separate reporting fee.

The report separately identifies original filings, free corrections, new chargeable professional revisions and periodic reviews resulting in a new filing. It publishes the method used to track regulatory due dates without treating mere corrections as renewals of validity. No disclosure charge may be included in fee revenue.

A member registered in the “retired member” category pays $0 in base annual Order dues. This exemption is accounted for within the Order’s general budget without creating a separate fund or reserve. It does not remove the contribution to the Office des professions under section 196.2 of the Professional Code or any other mandatory statutory levy unless expressly exempted by law.

Pursuant to section 75 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) of the Act, sections 6 (MINISTERIAL REGULATION RESPECTING FINANCING OF THE ORDER AND REGISTRY FEES), 21 (MINISTERIAL REGULATION RESPECTING FINANCING OF THE ORDER AND REGISTRY FEES) of this regulation are repealed upon official closure of the pre-registry.

The repeal has no retroactive effect and does not erase any file, vested right, payment or earlier act lawfully established.

This regulation is made by the board of directors under paragraph d of section 93 of the Professional Code, following communication to members under section 95.3, and approved by the Office under section 95.2. Premium funding remains governed by the Act’s express derogation.

Every member who practises the profession participates in the group professional liability insurance contract entered into by the Order, providing coverage for liability arising from faults or negligence committed in professional practice.

A member who declares that they perform no professional activities may be exempted from participation while that declaration remains accurate, subject to conditions established by the Order.

The member notifies the Order before resuming practice and joins the plan before performing a professional act.

The basic group policy provides, for each individually insured member, coverage of at least $_____ per claim and at least $_____ for all claims covered over a twelve-month coverage period. The minimum coverage applies separately to each member and may not be reduced by an aggregate limit shared among several professionals merely because they work in the same building, project or property complex. A single group policy remains permitted.

Defence costs are covered in addition to the limit where commercially reasonable terms are available.

The group insurance contract provides coverage for any claim made against a member arising from professional faults during the five years following the time at which the member is no longer required to maintain liability coverage or ceases to be a member of the Order. This minimum coverage is not conditional on insurance being available on commercially reasonable terms, in accordance with paragraph (d) of section 93 of the Professional Code.

The board of directors may determine categories of practice requiring complementary coverage having regard, in particular, to private practice, volume of acts, the nature of the systems involved, the value or complexity of buildings or reasonably foreseeable risk exposure.

Complementary coverage may, in particular, increase the limit to $_____ or more per claim where warranted by the risk.

The costs of the basic group plan, including premiums and eligible expenses, may be paid in whole or in part from the Order’s general operating fund, regardless of the source of revenues, in accordance with section 39 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) of the Act and the applicable provisions of the Professional Code.

The board determines the full cost of the plan and, where applicable, apportions the remaining portion payable by members or classes pursuant to section 85.2 of the Professional Code, subject to the express statutory adaptation in the Act. Assets of a separately constituted insurance fund remain subject to their legal regime.

Any insurance contribution payable directly by a member is shown separately from base annual dues.

The Order provides each member with a certificate or evidence of participation stating at least the coverage period, applicable limits, deductible, principal exclusions and contact information required to report a claim.

The member provides the Order with information necessary to administer the plan and promptly reports any change that may affect the member’s risk category or eligibility for an exemption.

Practice through a firm does not excuse a member from maintaining the individual coverage required. Separate coverage for liability that the firm may incur is maintained where required under the Professional Code and applicable regulations, without diminishing individual protections.

A retired member is exempt from insurance for new acts while performing no reserved professional activity. Statutory run-off coverage for earlier acts remains applicable under the Code and policy. Resumption requires active coverage before the first professional act.

A member promptly reports claims and potentially claim-producing events under the policy. The Order publishes clear procedures for reporting, follow-up and reviewing coverage complaints; no exclusion may remove protection mandated by law.

This regulation is made by the board of directors under section 30 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) of the Act and submitted for examination by the Office and government approval under section 95 of the Professional Code.

This regulation establishes the criteria for distinguishing:

1° a reporting-exempt non-compliance;

2° a non-compliance requiring action;

3° a non-compliance under documented action.

Non-compliances requiring action and non-compliances under documented action are subject to mandatory filing in the registry.

It also establishes the rules governing the recording of apparent anomalies referred to in section 27 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) of the Act.

The registry declaration requirement in this regulation takes effect only in legally activated regions. It never suspends hazard notices or other reporting obligations already imposed by another law.

A substantiated report requiring verification is a preventive mechanism separate from the three categories in this section. It changes neither the technical serious-risk threshold nor non-compliance classification criteria. An authorized person may issue a formal notice only after sufficiently establishing the necessary elements within their competence and legal authority; an outside-mandate report lacking them remains a report requiring verification. All disclosures are free.

For the purposes of the functions under section 30 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) of the Act establishing the Order, the following requirements supplement this Regulation:

The classifications “non-compliance under documented action” and “non-compliance requiring action” do not represent two intrinsic degrees of severity. They apply to non-compliances reaching the same serious-risk threshold and primarily distinguish the state of their handling. Both categories are subject to mandatory filing in the registry in accordance with sections 28 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) and 29 (ACT RESPECTING FIRE SAFETY PRACTITIONERS).

Every formal notice of reportable non-compliance, whether classified as 'under documented action' or 'requiring action', includes a separate metadata field stating whether the condition may materially affect firefighter operations, including firefighter safety, access to the premises or the availability of firefighting resources. This assessment is independent of classification by handling status; it changes neither the serious-risk threshold nor any other emergency duty.

Every disclosure resulting in a formal notice of reportable non-compliance, whether 'under documented action' or 'requiring action', and every substantiated report 'requiring verification' includes a mandatory 'Origin of finding' metadata field, with either 'within the scope of the mandate or legally assigned activity' or 'incidental discovery'. The latter applies to a finding outside the assigned verification scope, including one made during a different mandate or without any mandate. This field establishes neither severity nor adequate handling and creates no new duty to inspect or to contact the owner.

An express commitment by the owner or responsible person to carry out the correction may be considered in assigning or maintaining status “non-compliance under documented action” where the authorized person considers the commitment serious, credible, sufficiently specific and compatible with the applicable period. Where the nature of the risk requires immediate control or compensatory measures, a future commitment alone is insufficient in the absence of such measures.

Ordinary reporting of an apparent anomaly remains discretionary where there are no serious and objectively grounded reasons to suspect a reportable danger. It creates no general duty to actively search for conditions beyond a mandate's scope and is not, by itself, a definitive determination of non-compliance.

However, a member of the Order who, within the reasonable limits of their competence, incidentally observes a danger meeting the reporting criteria or has serious, objectively grounded reasons to believe it exists must make the appropriate disclosure, even without a mandate, current employment duties, a report or a contractual relationship with the owner. Where a non-compliance and its classification can be sufficiently established by an authorized person, the corresponding formal notice is filed. Otherwise, the member files a separate substantiated report marked 'requiring verification', without presenting unverified non-compliance as confirmed. This rule requires no inspection, procurement of a mandate, unauthorized entry, or diagnosis beyond professional competence or legal authority. A rumour, unsupported hypothesis or unverifiable information alone does not trigger the duty. In an immediate emergency, emergency services or the competent authority are contacted first as applicable, without waiting for the registry.

Compliance with a requirement and the level of risk associated with non-compliance are two distinct questions.

A non-compliance is not a non-compliance under documented action or a non-compliance requiring action solely because the code, standard or regulation makes the requirement mandatory.

The classifications “non-compliance under documented action” and “non-compliance requiring action” correspond to the same serious-risk threshold. They are distinguished mainly according to whether immediate, serious, credible and documented handling exists.

For the purposes of the functions under section 30 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) of the Act establishing the Order, the following requirements supplement this Regulation:

The mere failure to comply with a provision of an Act, regulation, code, technical standard or other technical document is not, by itself, sufficient to classify a non-compliance as a non-compliance under documented action or a non-compliance requiring action.

Refusal to award corrective work to the person who identified or classified the non-compliance, selection of another provider, negotiation of the price or scope of a mandate, or any other commercial interest may not, alone, justify classification as a non-compliance under documented action or a non-compliance requiring action, maintenance of such status or a correction period shorter than the actual risk requires.

Classification results from applying regulatory criteria to the concrete circumstances.

The requirement that is not complied with must be identifiable.

Where that requirement results from a chain of references, the provision and chain of references must be identifiable.

Several non-compliances may be considered together where their combination increases the risk.

The preparation, signature or authentication of a professional reportable non-compliance notice and the other professional conclusions covered by section 27 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) of the Act are activities reserved directly by that Act, subject to the authorizations and exceptions in its section 9 (ACT RESPECTING FIRE SAFETY PRACTITIONERS). This regulation specifies their exercise without itself creating the reservation.

For the purposes of the corresponding chapter of the Act establishing the Order, any person authorized to identify a non-compliance is also authorized, within the limits of that authorization and competence, to classify it, change its classification, reclassify it and verify its correction.

The Act’s incidental disclosure duties outside a mandate apply to PSI members, engineers and professional technologists authorized by its section 9 (ACT RESPECTING FIRE SAFETY PRACTITIONERS), under the same conditions and competence limits. Other persons remain subject to their legally applicable duties. Each professional remains under their own order for ethics and discipline. The serious-risk threshold and the two classifications remain identical; a report requiring verification creates neither a third non-compliance category nor a presumption of severity or territorial jurisdiction.

Classification involves two distinct and documented assessments:

1° determine whether the actual risk, in the concrete circumstances, reaches the serious-risk threshold justifying the regime for non-compliances under documented action or requiring action;

2° where that threshold is reached, determine whether immediate, serious, credible and documented handling justifies classification as a non-compliance under documented action or whether the absence, cessation or insufficiency of such handling justifies classification as a non-compliance requiring action.

For every reportable non-compliance, a separate assessment identifies the potential impact on firefighter operations using one of the values 'yes', 'no' or 'undetermined'. 'Yes' means that a material impact is reasonably plausible on the known facts; 'no' means that no such impact emerges from reasonably available facts; 'undetermined' applies where the available information does not support a conclusion. Silence or lack of verification must never be treated as 'no'.

Where the value is 'yes' or 'undetermined', the notice briefly identifies the function potentially affected and the limits of the assessment, to the extent supported by known facts. Examples include water supply, emergency access, equipment used for firefighting, and communication or control devices. This assessment creates no duty to perform an additional inspection beyond the mandate. Any later amendment of the metadata is dated, justified and retained with its history.

For the 'Origin of finding' field under section 29 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) of the Act, the filer distinguishes a finding made within the assigned verification scope from an incidental discovery outside that scope. An incidental discovery requires neither prior communication with the owner or responsible person nor proof of an attempt to contact them. It does not, by itself, establish that non-compliance has been corrected or that serious handling exists.

Professional judgment remains based on protection of the public and may not be influenced by the commercial interest of the person carrying out the classification.

For the purposes of the functions under section 30 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) of the Act establishing the Order, the following requirements supplement this Regulation:

The regulation made under section 30 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) may also determine:

1° the content of notices;

2° filing and transmission procedures;

3° elements required as proof of correction;

4° documentation of a verification;

5° conditions and grounds for a change of classification or reclassification;

6° follow-up reports;

7° procedures applicable where verification is impossible.

It may not determine the measures a competent authority must take after a notice becomes available in its dashboard.

Section 30 (ACT RESPECTING FIRE SAFETY PRACTITIONERS), section 31 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) and this section apply to central-registry operations in the region concerned only from its legal activation; it neither suspends nor replaces hazardous-situation reporting duties or public-authority powers arising under other laws.

Without raising or lowering the technical serious-risk threshold, the regulation specifies the contents and routing of substantiated reports marked 'requiring verification', their separation from formal notices, later verification solely by legally authorized persons, correction and administrative closure, and safeguards preventing unverified facts from being represented as confirmed. These procedures create no general outside-mandate inspection duty and grant no new right of entry to buildings.

In assessing the serious-risk threshold, the following are considered in particular:

1° the safety function affected;

2° the importance and extent of the loss of function;

3° whether the loss is total or partial;

4° redundant systems;

5° compensatory measures;

6° the type of occupancy;

7° the number of occupants;

8° their ability to evacuate;

9° their vulnerability;

10° available means of egress;

11° the reasonable probability of fire or aggravation;

12° reasonably foreseeable consequences;

13° the duration of the situation;

14° the accumulation of several non-compliances;

15° the age of a document, inspection, review or situation where that age has a real effect on safety;

16° changes to the building, occupancy, systems or occupant characteristics since the last relevant verification.

None of these factors, including the mere passage of time, creates an automatic classification by itself.

A non-compliance is reporting-exempt where it does not meet the criteria of Chapters IV or V.

It is recorded in the professional report where it falls within the mandate.

It is not filed in the registry or transmitted to the competent authority solely because it exists.

An apparent anomaly within the meaning of section 27 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) of the Act is not a reporting-exempt non-compliance.

Where a professional report is produced following a verification, inspection or test referred to in section 8 (ACT RESPECTING FIRE SAFETY PRACTITIONERS) of the Act, it distinguishes non-compliances from apparent anomalies under separate headings.

The non-compliance heading contains results arising directly from the elements the applicable requirement required to be verified. Any element that was required to be verified and does not meet the applicable requirement is treated as a non-compliance, not as an apparent anomaly.

The apparent-anomalies heading may contain conditions incidentally observed outside that scope. Ordinarily, recording them is discretionary and does not, merely because they appear in the report, give rise to a notice of non-compliance under documented action or requiring action or to a separate registry entry.

This discretion does not limit a member of the Order's duty to report, including outside a mandate, sufficiently reliable facts giving serious and objectively grounded reasons to believe that a reportable danger exists under the reporting duties in Chapter IV of the Act. Facts and steps taken are documented without presenting an outside-mandate anomaly as definitively established non-compliance. Without sufficient elements for a formal notice, the filing is a separate and free substantiated report 'requiring verification'; an isolated or unverifiable rumour is not enough to trigger the duty.

An apparent anomaly may not be presented as a definitive determination of non-compliance with a design, construction, installation or modification requirement unless the person has sufficient information to reach that conclusion, has the necessary knowledge and competence, and is legally authorized to perform the analysis or give the opinion concerned.

Where the person validly reaches that conclusion, the finding is treated as a non-compliance and classified in accordance with this Regulation.

The person may recommend that further verification be carried out by a legally authorized person.

A non-compliance that reaches the serious-risk threshold is a non-compliance under documented action where all the circumstances demonstrate immediate, serious, credible and documented handling by the owner or responsible person.

This classification records the existence of credible and documented handling; it does not mean that the non-compliance has been corrected. The handling must reasonably support the belief that correction will occur within the granted period and that, during that period, the risk is managed in a manner compatible with protection of the public.

An express commitment by the responsible person may be sufficient to establish handling where the authorized person considers it credible, sufficiently specific and proportionate to the situation. Material corrective work need not already have begun in every case.

Where the nature of the risk requires immediate control, classification as a non-compliance under documented action nevertheless requires that necessary temporary or compensatory measures actually be in place.

In assessing whether handling is immediate, serious and credible, the authorized person may consider in particular:

1° a clear and documented commitment by the responsible person;

2° the existence of a reasonable timetable;

3° steps already undertaken, including scheduling, ordering equipment, seeking or awarding a mandate, or planning work, where relevant;

4° work already undertaken and its progress, where applicable;

5° temporary or compensatory measures in place;

6° compliance with commitments already made in the file.

The authorized person retains professional judgment. The person may not require that the corrective mandate be awarded to them, their employer or a related person as a condition of status “non-compliance under documented action”.