What are the mandatory occupational health and safety (OHS) registers and documents?

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To protect worker health and safety and ensure ongoing risk prevention within the company, employers must establish and regularly complete several registers. In this article, you will find the mandatory Occupational Health and Safety (OHS) registers and documents:

• the safety register;
• the single occupational risk assessment document (DUERP);
• the register of serious and imminent dangers;
• work accident reports;
• the occupational physician's documents;
• observations and formal notices from the labor inspectorate.

What is an OHS register?

OHS registers are documents that contain a wealth of information for risk prevention within a company.These documents are compiled by the employer and include, for instance, the risks workers are exposed to, risk prevention actions implemented within the company, general periodic inspection (VGP) reports, work accidents, and so on.

These registers are essential tools for monitoring risk prevention and demonstrating the company's compliance.

🔍 Focus : According to the Labor Code, OHS registers can be maintained in various formats, such as paper or digital.However, the chosen medium must allow for all mandatory information to be accessible without difficulty in use or understanding, and without risk of altering the information contained (Article D8113-2 of the Labor Code).

Furthermore, proper maintenance of OHS records is mandatory to demonstrate the company's compliance with occupational health and safety regulations.

Indeed, during their visits, labor inspection officers must have access to records, certificates, instructions, results, and reports related to OHS (Article L4711-3 C.trav.).

Safety Register

The safety register combines several registers related to the safety of workplaces, work installations, and equipment within the company (Article L4711-5 C.trav.). It notably includes:

• the fire register;
• the electrical register;
• the register of work equipment verifications.

The safety register is not an obligation in itself (Article L4711-5 C.trav.). Nevertheless, it allows the employer to combine several mandatory registers into a single register to facilitate the storage and consultation of this information.

⚠️ Important : The certificates, instructions, results, and reports related to the verifications and controls present in the safety register must be dated and state the identity of the person or organization responsible for the control or verification (Article D4711-2 C.trav.).

Electrical Register

The electrical register documents the conformity of the company's electrical installations. It mentions the results of the initial and periodic verifications of these installations and contains documentation of the work and modifications carried out (Article R4226-19 C.trav.). Its maintenance is mandatory for all companies that have electrical installations.

This register must also contain the reports prepared by the accredited body that carried out the inspections, where applicable.

Fire Safety Register

The fire safety register is a document that records fire risk prevention within the company. All companies must establish this register as soon as they use premises or buildings.

The fire safety register includes, among other things, the dates of periodic drills carried out, observations made during periodic inspections of fire-fighting equipment, the names of the individuals responsible for fire safety services, fire safety instructions or evacuation instructions (Article R4227-39 Labor Code).

Register of periodic and initial inspections

The register of periodic and initial inspections contains the results of mandatory inspections for work equipment and installations (Article R4323-25 Labor Code).

All companies that use work equipment subject to such inspections must maintain this register.

Other registers

The safety register may also include other less common registers depending on the company's sector of activity.

For example, it may contain examinations concerning the walls and roofs of shafts and underground galleries (Article R4534-41 Labor Code).

Note: in practice, these registers often consist of digital documents (e.g., inspection reports, tracking of discrepancy resolution via spreadsheet or CMMS, fire reports, etc.)

Single Professional Risk Assessment Document (DUERP)

The DUERP is the reference document for implementing a professional risk prevention approach. It serves as a guide and allows for clear monitoring of prevention progress within the company.

The DUERP notably includes (Article L4121-3-1 C.trav.) :

• the results of the occupational risk assessment;
• the action plan and prevention measures;
• for companies with at least 50 employees, the annual program for the prevention of occupational risks and the improvement of working conditions (PAPRIPACT).

The preparation of the DUERP is mandatory for all companies and it must be updated (Article R4121-2 C.Trav.) :

• at least annually in companies with at least eleven employees;
• with every significant change in working conditions;
• when the employer awareness of additional information regarding an occupational hazard within the company.

🔍 Focus : The DUERP must be retained for a period of 40 years and must be made available, in particular, to employees and former employees, members of the CSE, the occupational health and safety service (SPST), and the labor inspectorate (Article R4121-4 C.trav.).

Workplace accident documents

Workplace accident declaration

When a workplace accident results in either a work stoppage or medical treatment, the employer must report it to the Primary Health Insurance Fund (CPAM) within 48 hours (Article R441-3 CSS) or MSA (Agricultural Social Mutual Fund) for the agricultural scheme.

⚠️ Please note : Copies of these work accident declarations must be kept by the employer for at least five years (Article D4711-3 C.trav.).

Furthermore, the employer must provide the victim with an accident report form so that they can receive compensation (Article L441-5 CSS.).

Minor Accident Register

The minor accident register lists all accidents that do not result in time off work or medical treatment.

Employers authorized to maintain this register must meet the following conditions (Article D441-1 C.trav.) :

• permanently have on staff either a doctor, a pharmacist, a state-certified nurse, or a person responsible for health and safety duties;
• have an emergency first aid station;
• have a CSE.

For these employers, when a work accident occurs but does not result in time off work or medical treatment, they can then replace the declaration of this accident with an entry in the register of minor accidents (Article L441-4 CSS). The employer must nevertheless inform the CSE.

🔍 Focus : When an accident recorded in the register of minor accidents subsequently results in a work stoppage or medical care, the employer must then declare the accident to the CPAM.

Register of serious and imminent dangers and public health and environmental alert register

Register of serious and imminent dangers

The register of serious and imminent dangers lists the hazards reported to the employer by a member of the Social and Economic Committee (CSE) (Article L4132-2 C.trav.). The CSE member's notice must be dated and signed and must indicate (Article D4132-1 C.trav.):

• the workstations affected by the identified hazard;
• the nature and cause of this hazard;
• the names of exposed workers.

The register pages must be numbered and authenticated by the CSE's stamp.

Public Health and Environmental Alert Register

The public health and environmental alert register contains alerts reported either by a worker or by a CSE member (Article D4133-1 C.trav.).

The pages of this register must be numbered.

The alert recorded in this register must be dated and signed and must indicate:

• the products or manufacturing processes that pose a serious risk to public health or the environment;
• where applicable, the potential consequences for public health or the environment;
• any other information useful for assessing the recorded alert.

Occupational Physician Documents

The documents prepared by the occupational physician allow for monitoring workers' health status and better prevention of occupational risks. They are thus among the essential documents in OHS.

Medical Monitoring Documents

Individual health monitoring certificates are issued by the health professional of the occupational health and prevention service after any information and prevention visit (VIP) for workers (Article R4624-14 C.trav.). For employees undergoing individual health monitoring, the occupational physician may issue an opinion on fitness or unfitness for work.

Occupational physician's company health record

The company health record is drawn up by the occupational physician (Article R4624-46 C.trav.). It notably includes occupational risks and the number of employees exposed to them. It is sent to the employer and presented to the CSE along with the annual report.

Observations and formal notices from the labor inspectorate

The employer must retain the observations and formal notices from the labor inspectorate regarding OHS (Article L4711-2 C.trav.).

The employer must also retain observations and formal notices concerning checks and inspections from the last five years (Article D4711-3 C.trav.).

In brief:

❖   Employers must maintain several mandatory registers to ensure worker health and safety.

❖   Specifically, the employer must establish and keep up-to-date the DUERP, the safety register, and the register of serious and imminent dangers.

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