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Obligations to post notices in companies and communicate documents to the administration have been simplified by Decrees no. 2016-1417 and no. 2016-1418 of October 20, 2016. This simplification allows modern means of communication to be taken into account.
We propose an update on the posting of documents relating to occupational health and safety. We'll start with information on the simplification released in 2016.
Simplification of company signage requirements
Internal regulations (article R. 1321-1 of the Labor Code)
Internal regulations are mandatory for companies with 20 or more employees.
Prior to the simplification, they had to be posted in the workplace, as well as on the premises and at the door of the premises where employees were hired. From now on, internal regulations must be communicated by any means to all persons with access to the workplace or to the premises where the employee is hired.
Modern means of communication such as e-mail or intranet can be used to meet this communication obligation.
Displaying the list of CSE members (article R.314-22 of the Labor Code)
The nominative list of the members of each social and economic committee is posted in the work premises.
It must indicate the Committee members' usual place of work and, where applicable, their participation in one or more Committee commissions.
Occupational health and safety signage in companies
As a reminder or for information purposes, the following information in particular must be displayed in companies (*):
- contact details for the occupational physician, emergency services and labor inspector in premises normally accessible to workers (article D. 4711-1 of the French Labor Code);
- a notice indicating how workers can access the single document (article R. 4121-4 of the French Labor Code);
- the ban on smoking in enclosed and covered workplaces (article R. 3512-7 of the French Public Health Code and the Order of December1, 2010 setting out the signage models provided for in article R. 3511-6 of the French Public Health Code);
- fire safety instructions in establishments with more than 50 employees and those where flammable materials are used (articles R. 4227-37 to R. 4227-41 of the French Labour Code);
- collective working hours
- panels for displaying union communications for each union section present in the company
The posting obligation can sometimes be replaced by a "simple" obligation to provide information by any means:
- Articles 225-1 to 225-4 of the French Criminal Code: combating discrimination in recruitment
- notices containing the titles of agreements applicable in the plant
- Articles L3221-1 to L3221-7 of the French Labor Code on equal pay for men and women)
- Text of article 222-33-2 of the penal code (moral harassment) and text of article 222-33 of the penal code (sexual harassment)
- Information on the existence and content of a profit-sharing agreement
(*) Here we have selected those regulatory requirements where the term "Display" clearly appears. In some other cases, documents are mandatory and, although not formally required, should be posted. For example: fire instructions in establishments with 50 or fewer employees - article R. 4227-37 of the French Labor Code.
Conclusion
We invite you to examine or re-examine the displays used in your company. This will help you to ensure compliance. We also recommend that you set up periodic checks to ensure that your company's signage obligations are being met.