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🔎 Key takeaways
- There is a legal requirement to carry out a gender-differentiated assessment of occupational risks. This requirement presents genuine practical implementation difficulties, and has in fact been little applied by companies since its introduction into the Labour Code.
- Women and men are exposed differently to risk (different day-to-day work realities), and the impacts on their health also differ (specific to women/men).
- Taking a gender-differentiated approach to occupational risks is possible through a concrete methodology, applied throughout the stages of risk assessment (the guide offers keys to succeeding at each of these steps).
- The DUERP (single risk assessment document) is not an end in itself, but enables the concrete rollout of a prevention action programme (the guide offers a series of questions to ask, to ensure that differences between women and men in work situations are properly taken into account).
Please note: This article concerns French legislation. The requirements described may not apply in other countries.
“The Labour Code contains few provisions that apply specifically to women or men. Combined with the lack of sex-disaggregated accident data, this helps explain why the differentiated impact of work on the health of women and men has, until now, been little taken into account”[1].
Since 2014, the Labour Code has provided that the employer “assesses the risks to workers' health and safety [...] in the layout or reorganisation of workplaces or facilities, in the organisation of work, and in defining job positions. This risk assessment takes into account the differentiated impact of risk exposure based on sex.” (Article L. 4121-3 of the Labour Code)
Noting that this requirement has been poorly implemented, the French National Agency for the Improvement of Working Conditions (Anact) has published a 78-page guide to help employers implement a gender-differentiated approach to occupational risk assessment, set out in the single risk assessment document (DUERP).
So how can we improve understanding of, and the concrete consideration given to, these differentiated issues in risk assessment? This is the question that the guide, published in September 2025, attempts to answer, through an educational approach to understanding the issues, a proposed methodology for relevant risk assessment, and practical fact sheets.
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The guide first shows that there are two dimensions to take into account in order to better assess and prevent risks for women and men:
- the day-to-day reality of work for women and men, which differs given different occupations and career paths, as well as activities outside work – resulting in differentiated exposure to occupational risks;
FOCUS: In most cases, women and men do not hold the same positions. In female-dominated occupations, risks are often more invisible and therefore under-assessed.
> Example: Exposure to the most common risks in female-dominated occupations (e.g. musculoskeletal disorders, psychosocial risks, etc.) has delayed impacts and is therefore less often identified.
- the biological and social specificities of women and men, which lead to differentiated impacts of occupational risks on their health.
FOCUS: The same exposure to one or more work-related risks or constraints may not have the same effects on the health of women and men, given biological or social differences.
> Example: differentiated impact of chemical agents, of manual handling, of atypical working hours, of management under pressure, etc.
The guide is made up of 3 main sections:
1. Health and working conditions of women and men, the relevance of a differentiated approach
The first part of the guide explains the differences in accident rates, exposure to arduous-work risks, occupations and career paths, social differences, and factors of invisibility – all highlighted by research conducted over many years.
The first finding is that, “in most cases, occupational health policies and prevention practices are built on a model of gender neutrality for workers, whose implicit reference point is the male worker”[2].
FOCUS: The overall 11.1% decrease in the number of workplace accidents between 2001 and 2019 actually corresponds to a 27.2% decrease for the male population and a 41.6% increase for the female population[3].
> Example: In feminised service occupations (care, cleaning, teaching, retail, catering, etc.), employees are exposed to 7 out of 8 occupational risks (physical strain, lack of support, conflicting values, lack of autonomy, emotional demands, job instability, organisational constraints) – whereas masculinised blue-collar occupations are exposed to 4 out of 8 risks (physical strain, work intensity, lack of support, lack of autonomy).
Anact's “All Else Unequal” Health-Equality Model
2. Steps and methodological principles for a gender-differentiated assessment of occupational risks
The guide notes that most risk assessment methods are structured around these 5 main phases. It then proposes enhancements to incorporate the differentiated approach at each of these 5 stages of the analysis process.
An example of a DUERP is then provided to concretely illustrate how these elements can be taken into account. Finally, the guide addresses the development of the occupational risk prevention and working-conditions improvement programme (PAPRIPACT), or, for companies with fewer than 50 employees, the list of prevention actions. Indeed, Circular No. 6 DRT of 18 April 2001 reminds us that “risk assessment is not an end in itself” and that the DUERP must contribute to the development of the programme. It envisages the possibility for labour inspectors to note the failure to use single-document data in developing this programme[1].
💻 Regulatory reminder: An enhanced DUERP to be archived digitally
Incorporating this gender-differentiated approach is essential for your single risk assessment document to be compliant. As a reminder, once your DUERP has been updated with Anact's criteria, it must be filed – along with all its successive versions – on the official national digital portal. This requirement to digitise and centralise records at national level, which has come into force in stages, now applies to all companies regardless of size (with a final deadline of 1 July 2026 for those with fewer than 150 employees). Make sure your sex-disaggregated analyses are properly formalised before filing, to guarantee the compliance of your 40-year traceability record.
3. Practical fact sheets to help question the differentiated exposures and impacts of risks by sex within the DUERP
“Thinking about occupational health for women: differentiating is not discriminating”[2]
The third part of the guide first offers 25 questions to check that the differentiated approach has been taken into account at the various stages of building the risk assessment.
Example: Is the DUERP regularly updated to incorporate newly identified risk situations? Are the measures put in place assessed together with the women and men concerned, to check their effectiveness?
The guide also presents a table containing a series of points to question, in order to enrich the risk assessment process. These questions cover the following topics:
· The physical work environment (e.g. adapting equipment and workstations to differences in height, weight, strength and body shape)
· The organisation of work and processes (e.g. organisational constraints: working under time pressure, under stress, etc.)
· The organisation and balancing of time (e.g. balancing work life and personal life)
· Workplace relationships and management (e.g. relationships within teams with little gender mix)
· Career paths and skills (e.g. more limited career advancement prospects for women, which increase phenomena of occupational burnout)
· Risks affecting the reproductive health of women and men (e.g. pregnancy and breastfeeding situations)
Example for the first topic:
| Points to question | Why? Examples |
What questions to ask or raise? Examples |
|---|---|---|
| Separate men's/women's changing rooms and toilets | For employees working shifts, mobile roles, off-site roles, on temporary sites or construction sites, the question of women's access to toilets often arises. Specific needs may need to be taken into account (menstruation, pregnancy-related urinary issues, menopause, etc.). |
|
| Adapting equipment and workstations to differences in height, weight, strength and body shape. |
Height: Workstations are generally designed for an “average” man (average height of 1.75 m in France³³). People who are short (average height of women is 1.62 m) or tall may be forced into awkward postures (e.g. arms raised) or additional manoeuvring. Muscular strength: Muscular strength is on average higher in men³⁴ than in women. Failing to take into account differences in muscle mass and anthropometry can lead to equipping workplaces with tools, equipment and workstations that are poorly suited (e.g. handling crates that are too heavy, too large, arm movements with too great a reach). Manual handling: Women at work most often carry “living” loads (children, elderly people, sick people, animals) or fragmented loads (small loads carried repeatedly, such as at a checkout position, for example). The maximum unit loads set out in Art. L.4541-9 of the Labour Code differ for men and women, but both remain too high. Standard NF X 35-109 sets the maximum acceptable reference value for everyone at 15 kg (beyond this, further analysis is required). Any manual handling of a load exceeding 25 kg is considered harmful³⁵. Failing to take differences between women and men into account when designing work equipment can create risks during adjustment, maintenance or cleaning phases: for example, when access to a control or safety device, or machine maintenance, becomes complicated or difficult (e.g. a cover that is too heavy or a control that is too far away). |
Tip:
These subjects generally require direct observation of the work situation. |
[1] Excerpt from the Anact guide, September 2025, page 2.
[2] The Brussels-based ETUI organisation has highlighted this finding since 2003, with Laurent Vogel. Excerpt from the Anact guide, September 2025, page 8.
[3] Excerpt from the Anact guide, September 2025, page 9.
[4] Excerpt from the Anact guide, September 2025, page 22.
[5] French Senate report “Women's health at work: invisible ailments” – 2023, referenced in the Anact guide, September 2025, page 4.