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A prevention plan is established when, under certain conditions, one company operates on another's site. Its objective is to ensure employee safety by assessing the risks associated with the activities of these companies within the same workplace.
Conditions for implementing a prevention plan
A written prevention plan is mandatory in the following cases:
- Work exceeds a certain duration: The total number of work hours (external companies and their subcontractors combined), whether foreseeable or actual, is equal to at least 400 hours over a period of 12 months or less.
- Work is classified as dangerous: As soon as an operation falls into the category of dangerous work defined in Article 1 of the decree of March 19, 1993.
Outside of these scenarios, a written prevention plan is not mandatory, but a preliminary visit with the external company must be conducted to perform a risk analysis.
Joint preliminary inspection and coordination
This inspection aims to prevent risks related to interference between the activities, installations, and equipment of different companies present at the same workplace. It is implemented before and during the execution of the operation, between the User Company (EU) and External Companies (EE) (articles L. 4532-3 of the Labor Code).
Content of the prevention plan
It includes the following information:
- The definition of dangerous activity phases and associated prevention measures,
- The adaptation of equipment, installations, and devices compliant with the nature of the operations to be performed, as well as maintenance conditions,
- Instructions to be given to workers,
- The organization of first aid in case of emergency, as well as a description of the arrangements within the User Company,
- The definition of tasks to be performed, their timeline, specifying their assignment (who does what), the organization of supervision, and the coordination to be ensured between External Companies and User Company,
- The list of positions requiring enhanced individual monitoring (EE and EU),
- The provision of facilities (restrooms, changing rooms, catering area...),
- Measures to be taken by the external company (EE) in case of isolated or night work.
- Attached to the plan are the technical files related to asbestos search and identification, and, if applicable, asbestos surveys.
Who signs the prevention plan? Who is informed? Who can consult it?
Company heads (or their delegates): They are responsible for implementing this analysis and establishing the prevention plan to define the measures taken by each company, both external and user (R. 4512-6 of the Labor Code). In case of delegation, caution! It must be ensured that the worker has the necessary authority, competence, and resources (R. 5411-9 of the Labor Code).
Workers: whether they are workers from the user company or an external company, they must be informed by their employer of the dangers to which they are exposed at the work site. Similarly, they must be aware of prevention measures, particularly collective protective equipment and PPE.
The CSE/CSSCT: For the user company, the CSE is systematically informed of meeting dates by the employer as soon as they are known and no later than 3 days before the start of the visit, whether it concerns the preliminary joint inspection or periodic coordination meetings. The CSE may participate if it deems it necessary, as may the CSE of the external company, and it then issues an opinion on the prevention measures. The prevention plan is made available to them. The employer must inform the CSE of any emergency situation.
The labor inspectorate: It must be informed of the commencement of work subject to a written prevention plan. It is not necessary to send the prevention plan; a simple email informing them of the work's start date is sufficient.
And...? Finally, the prevention plan must be made available throughout the duration of the work to the labor inspectorate, social security agency representatives, and, if applicable, the Professional Organization for Prevention in Construction and Public Works.
Is signage required?
It's often forgotten, but yes! At the entry and exit points for user company personnel, the names and workplaces of CSE members from both the user company and external companies must be displayed, along with the name of the occupational physician and the location of the first-aid rooms.
What is the validity period of a prevention plan? And its retention period?
The prevention plan has no regulatory validity period, nor a retention period.
It is intended to apply for the duration of the operation. It is therefore adaptable. In reality, prevention plans rarely exceed one year, and then usually for recurring services or contracted companies. Thus, whenever necessary, companies must ensure it is updated to account for changes and the actual work situation. This is the case, for example, when new employees are brought in to work, and when new installations or equipment are used.
Regarding retention, if there's no regulatory period, an internal rule can be set based on another existing duration. For example, the one applied to General Periodic Inspection (VGP) documents is 5 years. Retaining these prevention plans remains useful, as they may be requested in the event of an accident (especially a serious one) during an operation covered by them, as well as the associated risk analysis.