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A prevention plan is drawn up when, under certain conditions, one company works on the site of another. Its aim is to guarantee employee safety by assessing the risks associated with the activities of these companies in the same workplace.
Necessary conditions for setting up a prevention plan
A written prevention plan is mandatory in the following cases:
- Work exceeds a certain duration: The total number of foreseeable or actual working hours (including outside contractors and their subcontractors) is 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.
Apart from these cases, a written prevention plan is not mandatory, but a prior visit with the external company to carry out a risk analysis is required.
Joint pre-inspection and coordination
The aim of this inspection is to prevent risks arising from interference between the activities, installations and equipment of different companies present on the same site. It is carried out before and during the execution of the operation, between the User Company (EU) and the External Companies (EE) (articles L. 4532-3 of the French Labor Code).
Contents of the prevention plan
It contains the following information:
- Definition of hazardous activity phases and associated preventive measures,
- Adaptation of equipment, installations and devices to the nature of the operations to be carried out, as well as maintenance conditions,
- Instruction for workers,
- First-aid organization in the event of an emergency, as well as a description of the EU's first-aid system,
- The definition of tasks to be carried out, their timing, specifying their allocation (who does what), the organization of command, the coordinates to be ensured between the ES and EU,
- The list of workstations with enhanced individual monitoring (EE and EU),
- Provision of facilities (toilets, changing rooms, catering facilities, etc.),
- Arrangements to be made by EE in the event of working alone or at night.
- Attached to the plan, the technical files relating to the search for and identification of asbestos, and where applicable the asbestos survey.
Who signs the prevention plan? Who is informed? Who can consult it?
Company managers (or their delegates): They are responsible for implementing this analysis, and draw up the prevention plan to define the measures taken by each company, whether external or user (R. 4512-6 of the French Labor Code). In the event of delegation, take care! Care must be taken to ensure that the worker has the necessary authority, skills and resources (R. 5411-9 of the French Labour Code).
Workers: whether they work for the user company or for a subcontractor, they must be informed by their manager of the hazards to which they are exposed at the work site. They must also be familiar with preventive measures, in particular collective devices and PPE.
The CSE/CSSCT: For the user company, the CSE is systematically informed of meeting dates by the company manager as soon as he is aware of them, and no later than 3 days before the start of the visit, whether it concerns the joint preliminary inspection, or periodic coordination meetings. The CSE may participate if it considers it necessary, as may the CSE of the external company, and then issue an opinion on the prevention measures. The prevention plan is made available to them. The company manager must inform the CSE of any emergency situation.
Labour inspectorate: The inspectorate must be informed of the start of any work requiring a written prevention plan. It is not necessary to send the prevention plan; a simple e-mail informing the inspectorate of the start date of the work is sufficient.
And...? Last but not least, the prevention plan is kept available for the duration of the work for the Labour Inspectorate, social security officials and, where applicable, the Organisme Professionnel de Prévention du Bâtiment et des Travaux Publics.
Do I need to put up a sign?
It's often forgotten, but yes! The names and workplaces of CSE members from both the user and external companies, as well as the name of the occupational physician and the location of infirmary facilities, must be posted at the entry and exit points of user company personnel.
How long is a prevention and conservation plan valid?
The prevention plan has no statutory period of validity, and no retention period.
It is intended to apply for as long as the operation lasts. It is therefore open-ended. In reality, prevention plans rarely last more than a year, and are more likely to be drawn up for recurring services or for companies under contract. So, whenever necessary, companies must update their plans to take account of changes and actual work situations. This is the case, for example, when new employees are brought on board, or when new installations or equipment are used.
In the absence of a statutory retention period, an internal rule can be based on an existing retention period. For example, the retention period for Periodic General Inspection (VGP) documents is 5 years. The retention of these prevention plans remains useful, as they may be requested in the event of an accident (particularly a serious one) during an operation governed by them, as may the associated risk analysis.