FSP or ERP: Which One Does Your Business Need in Quebec?

Both plans address evacuation and end up in the same binder, but they do not answer to the same law, the same risk, or the same inspector.

The fire safety plan is the management document that describes how a specific building responds to fire: alarm and evacuation procedures, supervisory staff and their training, fire drills, hazard control, and inspection and maintenance of facilities. It is not the drawing posted in the corridor, which is the evacuation plan. Article 2.8.1.1 of the Building chapter of the Quebec Safety Code makes it mandatory for any building containing an assembly, care, treatment, or detention occupancy, for private seniors' residences, construction and demolition sites, certain storage areas, and premises where flammable or combustible liquids are stored or handled, as well as for any building whose construction requirements already provided for a plan.

An office or store outside these categories is therefore not automatically subject to it, but a municipal by-law, an insurer, or the presence of hazardous materials may require it. The plan is reviewed at intervals of no more than 12 months, and a copy must remain accessible to the fire department. The Building chapter including the NFC 2020 has been in force since April 17, 2025, according to the Régie du bâtiment du Québec, and its 18-month transition period ends on October 16, 2026. The details of the seven mandatory elements are in our article on the fire safety plan in business; to produce it in a format that the inspector recognizes, see our page on compliant FSPs in Quebec.

The emergency response plan is based on a different logic: it does not target a building, but an organization, and all situations that may affect it. In Quebec, its foundation is the Loi sur la santé et la sécurité du travail (Act respecting occupational health and safety). Section 51 requires the employer to use methods to identify, control, and eliminate risks (paragraph 5), to take the fire safety measures prescribed by regulation (paragraph 6), and to inform and train workers (paragraph 9). The Règlement sur la santé et la sécurité du travail (Regulation respecting occupational health and safety - RSST) reflects this in Section IV, "Safety measures in case of emergency": in every establishment, an emergency evacuation plan must be established and implemented (section 34), and rescue and evacuation drills adapted to the risks must be held at least once a year (section 35). Sections 36 to 38 cover portable fire extinguishers (NFPA 10) and emergency systems. That is why one often reads "CNESST emergency response plan": the CNESST enforces these sections across all businesses, with no employee threshold or building occupancy conditions.

Since May 28, 2024, the Loi sur la sécurité civile visant à favoriser la résilience aux sinistres (Civil Protection Act to Promote Disaster Resilience) has replaced the former Loi sur la sécurité civile (Civil Protection Act). It states that every person must contribute to civil protection and exercise foresight and prudence regarding their property and activities (Section 5). It provides for a risk disclosure for persons whose property or activities may cause a disaster determined by regulation, and allows the government to impose preparedness, response, and recovery measures on them (Section 11). A municipality may also, by by-law, subject a business within its territory to these obligations (Section 12). The word "disaster" covers floods, earthquakes, hazardous materials accidents, infrastructure failures, forest fires, and pandemics: exactly what an FSP does not cover.

What hazards must the ERP cover? CSA standard Z731, "Emergency Preparedness and Response", lists ten categories, featured on the CSN (Confédération des syndicats nationaux) health and safety training portal:

CSA Z731-03 has since been withdrawn from the catalogue; its successor is standard CSA Z1600:17, reaffirmed in 2022, "Emergency and continuity management program", harmonized with the American standard NFPA 1600. Facilities that hold one of the 249 substances under the federal Environmental Emergency Regulations (2019), in force since August 24, 2019, must also prepare and test an environmental emergency plan as soon as Schedule 1 thresholds are reached. To see what an up-to-date ERP looks like, with a drill log and signatures, visit our page on emergency response plans in Quebec.

Answer in order. A single "yes" is enough to create an obligation.

Two or more "yes" answers: you need both documents, and it is simpler to keep them together. Most businesses subject to an FSP also answer "yes" to the second question.

Yes, and it is even the approach favoured by the Quebec government. The Ministère de la Sécurité publique (Ministry of Public Safety) publishes fire safety and emergency response plan templates (FSP-ERP) for residential buildings, educational institutions, and childcare services. These templates bring together in a single binder the description of the building and its facilities, the roles of the emergency team, evacuation instructions, recovery, drill history, and an appendix of potential emergencies: flooding, prolonged power outages, earthquakes, severe winds, carbon monoxide poisoning, petroleum product spills, shelter-in-place and lockdowns. In the healthcare network, the Manuel de planification des mesures d'urgence (emergency response planning manual) from the Ministère de la Santé et des Services sociaux (Ministry of Health and Social Services) plays the same role, including emergency codes.

For a business, the logic is identical: the risk assessment comes first, the ERP serves as the master plan, and the FSP serves as its fire safety chapter. A single drill log, a single emergency team, a single revision date.

The FSP ends when the firefighters leave. The ERP begins before the alarm and continues after: that is the fundamental difference. The Canadian Centre for Occupational Health and Safety (CCOHS) lists what an emergency response plan must contain:

Recovery and business continuity are also part of this. The Government of Quebec offers businesses a four-step business continuity process (analysis, design, implementation, validation through exercises) and points out that risk management, continuity planning, and insurance are part of businesses' civil protection responsibilities. Are you looking for an "emergency response plan example" or a free template? The ministry templates are public and useful for understanding the structure. They are worth nothing until they are filled in with your scenarios, your designated managers, your phone numbers, and your floor plans, and then put to the test. The CCOHS recommends a general drill and a review at least once a year, and an update with every change to facilities, processes, or key personnel. That is also what emergency response training worthy of the name verifies: that everyone knows what to do, not just that the binder exists.

On the fire safety side, notices of violation and fines fall under the Quebec Safety Code and municipal bylaws; we detail them in our article on fire safety fines and prosecutions. On the civil protection side, the 2024 law provides for a fine of $1,000 to $5,000 for a natural person and $3,000 to $15,000 in other cases for failure to submit a risk declaration or for obstructing an inspector (section 89), with these amounts doubled in the event of a repeat offence (section 93). The CNESST, for its part, can require the correction of any violation of the RSST (Occupational Health and Safety Regulation). And in court, the absence of a documented plan or drill weighs heavily in evaluating an officer's due diligence.