The Government of Quebec has adopted Decree 815-2026 amending the Regulation on Occupational Health and Safety in Mines. The changes primarily affect mine rescue, autonomous machines, emergency exits, and explosives management.
Among the most significant changes, employers will now be required to have a minimum team of 18 rescuers available to respond to a major incident requiring a prolonged rescue operation. New rules are also being introduced for mines in the process of opening or closing.
The regulations also provide greater oversight of the use of modern mining technologies. Employers who use autonomous or semi-autonomous machines must implement a structured approach to risk assessment and mitigation and retain relevant information demonstrating compliance.
In terms of prevention, emergency exits must remain accessible and be subject to a risk assessment based on recognized principles. The regulation also requires the installation of protective devices to ensure their integrity.
Changes have also been made to the management of explosives. The maximum capacity of certain storage safes has been increased from 75 kg to 227 kg, and new requirements apply to the identification of storage safes and the demarcation of explosive loading areas.
Finally, the regulation specifies certain obligations regarding the training of mining equipment operators, rail-guided remotely operated vehicles, and the qualifications required to perform electromagnetic testing on certain cables used in mining facilities.
Our Recommendations
Beyond regulatory compliance, these changes reflect a fundamental trend: several new obligations now hinge on the employer’s ability to demonstrate that it has identified, analyzed, and controlled the risks. In the context of an inspection, an accident, or an investigation, the question will often be less about whether a measure existed and more about whether the organization is able to prove it.
Employers would therefore be well advised to conduct a comprehensive review of their risk assessments, emergency procedures, training programs, staff qualifications, and control mechanisms affected by the decree. In many organizations, the main challenge will not be the absence of safety measures, but rather the fact that these measures are scattered across different departments and difficult to demonstrate when needed.
The new provisions regarding autonomous and semi-autonomous machines also deserve special attention. The risks associated with this equipment often stem less from the technology itself than from its integration into operations, work procedures, and interactions with workers. A targeted review of the interfaces between automated systems and daily operations could prove just as important as the equipment’s technical compliance.
Finally, the requirements for emergency exits serve as a reminder that risk management no longer relies solely on the presence of adequate infrastructure. Organizations will need to be able to demonstrate the quality of their risk assessment and control processes. Risk governance is thus becoming almost as important as the equipment itself.
