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The annual program for the prevention of occupational hazards and improvement of working conditions (PAPRIPACT) is mandatory for companies with 50 or more employees, and is a key component of risk prevention in the workplace. In this article, you'll find everything you need to know about its implementation and development!
What is PAPRIPACT?
The PAPRIPACT is a document which brings together all the risk prevention actions to be implemented in the company over the coming year. It is compulsory for companies with 50 or more employees(article L4121-3-1 C. trav.).
ℹ Note : This threshold does not apply to the civil service. Thus, the implementation of the PAPRIPACT is mandatory there regardless of the structure's headcount (source: circular of June 11, 2024).
Formalizing the PAPRIPACT has been mandatory since the so-called "occupational health" law of August 2, 2021, which aims to strengthen occupational health prevention in companies. Its main aim is to structure and energize occupational risk prevention by requiring companies to implement concrete actions and measure their effectiveness as part of a continuous improvement process.
What is the link between the PAPRIPACT and the DUERP?
The PAPRIPACT must be the subject of a specific document. Nevertheless, it is closely linked to the DUERP (document unique d'évaluation des risques professionnels). Indeed, its content must be based directly on the results of the risk assessment recorded in the DUERP.
The PAPRIPACT and the DUERP are therefore two complementary risk prevention tools :
- the DUERP is used to transcribe the results of the assessment of physical and psychosocial psychosocial risks ;
- PAPRIPACT intervenes upstream to respond to problems identified in the DUERP, listing the preventive measures to be put in place and monitoring their effective implementation within the framework of a precisely established schedule.
What does PAPRIPACT contain?
The regulations lay down precisely what must be included in the PAPRIPACT. The PAPRIPACT must include(article L4121-3-1 C. trav.) :
- a detailed list of preventive measures (*) to be taken over the coming year. Each measure must be accompanied by at least the conditions under which it is to be carried out, result indicators and an estimate of its cost;
- identification of company resources that can be mobilized (people in charge, potential contributors, etc.);
- an implementation schedule.
(*) including, in particular, measures to prevent the effects of exposure to occupational risk factors (formerly known as hardship factors).
As mentioned above, the PAPRIPACT must be drawn up using the information contained in the DUERP. But other resources can also be used, such as :
- analyses and feedback from incidents and accidents in the workplace ;
- observations contained in the various occupational health and safety registers (safety register, documents from the occupational physician, observations and formal notices from the labor inspectorate, workplace accident declarations and register of minor accidents, etc.).
Regulations do not require employers to comply with any specific formalities for the PAPRIPACT. It is therefore up to the employer to choose the most appropriate format, depending on the company's size, activities and specific health and safety issues.
In general, the PAPRIPACT is presented in the form of an Excel file with a table showing one row for each action, and important information in the columns. Here are a few examples of items to be indicated:
- action reference (number) and title ;
- the work unit concerned ;
- the identified hazard ;
- occupational risk (chemical risk, road risk, etc.) noise risketc.);
- the staff concerned ;
- a brief description of the situation before implementing the action;
- type of measure (technical, organizational, etc.) ;
- action status (to be processed, in process, processed, postponed, etc.);
- conditions of performance ;
- performance indicators ;
- the person responsible ;
- the planned completion date of the action ;
- the estimated budget allocated to the project.
Example of prevention actions:
⚠️ Attention : The choice of preventive actions must take into account the general principles of risk prevention. Thus, collective protection measures must be given priority over individual protection measures.
If necessary, training and information measures for workers must be planned to ensure safe and effective implementation of the various preventive measures.
Finally, it is essential to prioritize preventive measures according to the most important issues at stake , in order to guarantee rapid action on the most urgent problems.
How do you draw up a PAPRIPACT?
The employer is responsible for drawing up the PAPRIPACT in the same way as the DUERP. In practice, the PAPRIPACT is generally drawn up by a person whose job requires him/her to deal with OHS issues in the company on a regular basis, such as the QSE or EHS manager. Any other useful person can also be involved in drawing it up (occupational physician, managers, workers, OHS preventionists, human resources, etc.).
ℹ Please note : Article L4121-3-1 specifies that the organizations and bodies set up by the branch can also support companies in drawing up the PAPRIPACT. Indeed, OHS issues can be quite similar from one company to another in the same business sector.
The social and economic committee (CSE) also plays a central role in the development of the PAPRIPACT. The Labor Code stipulates that, as part of the annual consultation on the company's social policy, the PAPRIPACT must be submitted to the CSE for its opinion (article L2312-27 C. trav.).
Within the framework of this opinion, the CSE can, in particular, propose an order of priority for the actions defined in the PAPRIPACT, as well as the adoption of additional measures.
🔎 Focus : As a reminder, the "health at work" law has strengthened the role of the CSE in occupational risk prevention. Thus, since March 31, 2022, the CSE - and, where applicable, the CSSCT - can contribute to the assessment of occupational risks in the company. It must be consulted on the DUERP and its updates (article L4121-3 C. trav.).
Article R4121-2 of the French Labor Code stipulates that the PAPRIPACT must be updated "each time the occupational risk assessment document is updated, if necessary". As a reminder, the DUERP must be updated :
- at least once a year in companies with at least 11 employees;
- whenever a decision is made to carry out a major project that will modify health and safety conditions or working conditions ;
- wheneveradditional information relevant to risk assessment is brought to the employer's attention.
ℹ Please note : annual updating of the DUERP is not mandatory for very small businesses (companies with fewer than 10 employees).
While PAPRIPACT should therefore be updated at least once a year, in practice and with a view to continuous improvement, it may be more appropriate to update more frequently, so that the document reflects the state of progress of the various actions and can fully fulfill its role.
PAPRIPACT: what does an employer risk in the event of non-compliance?
PAPRIPACT is a major occupational risk prevention tool for companies with over 50 employees. Consequently, failure to comply with the associated obligations may render the employer liable for breach of his safety obligation towards his employees, particularly in the event of an accident in the workplace.
It is important to remember that this safety obligation is an obligation of result. Thus, the employer's inexcusable fault may be recognized in the event of failure to implement preventive measures , even if these had been provided for in the PAPRIPACT.
ℹ Please note : This inexcusable fault is recognized by law when an elected member of the CSE had previously reported a risk to the employer and the latter has taken no steps to remedy the situation (article L4131-4 C. trav.).
Finally, it should be noted that the PAPRIPACT, like the DUERP, is an essential tool for the proper functioning of the CSE , which must be able to consult on its content. Consequently, its absence may constitute an offence of obstruction punishable by a fine of 7500 euros (article L2317-1 C. trav.).
To remember:
❖ PAPRIPACT is compulsory for companies with 50 or more employees;
❖ It establishes the preventive actions to be implemented for the coming year, based on the results of the occupational risk assessment recorded in the DUERP ;
❖ The CSE must be consulted on its content and may propose modifications or additional measures ;
❖ Employers who fail to meet their obligations may be held civilly and criminally liable in the event of a workplace accident due to insufficient preventive measures.