Port Security Affirmed as a Federally Regulated

Quebec Maritime Services Inc. provides security services to the port of Malbaie. It, and its employee, were charged with having contravened the provisions of the Private Security Act (“PSA”), a statute enacted by the Quebec legislature, that required them to hold a licence to carry on a private security activity. They fought that charge on the basis that they were federally regulated such
that the PSA did not apply to them.

The Supreme Court of Canada agreed with that argument, stating that:

As for the case involving QMS and F, the Court has held in its jurisprudence that dockside unloading and storage operations are integral to shipping. Even without any specific precedent in this regard, there is no doubt that the security of marine facilities and their operations is at the core of the federal navigation and shipping power under s. 91(10) of the Constitution Act, 1867. QMS’s activities at the terminal — and by extension the activities carried on by its employee, F — fall squarely within the core of this exclusive federal power. The application of the PSA to QMS and F thus constitutes an intrusion on the core of an exclusive head of power.

See more here: Opsis Airport Services Inc. v. Quebec (Attorney General), 2025 SCC 17.