Risk prevention plan: obligations and implementation

The risk prevention plan is the reference document that governs the activities ofexternal companies working on a construction site for a user company, in order to control the risks of simultaneous activities (interference between activities, installations and equipment). It formalises the analysis of hazards, preventive measures, the organisation of emergency services, and the cross-functional responsibilities of the parties involved. 

Developed before work begins, it applies to a wide variety of operations: maintenance, electrical work, industrial cleaning, regulatory inspections, etc. When well designed and kept up to date, it becomes a key operational tool for QHSE managers, industrial site or network operators, and external contractors working on site.

Regulatory basis for the prevention plan

The legal framework is set out in the french Labour Code, section “Work carried out in an establishment by an external company”, and more specifically Section 3: Prevention plan (Articles R4512-6 to R4512-12). Article R4512-6 requires, in light of the preliminary joint inspection, an analysis of the risks of interference and, if such risks exist, the development of a prevention plan before work commences.

In two situations, a mandatory prevention plan must be drawn up in writing:

• When the operation exceeds 400 hours over a period of less than 12 months
• Regardless of duration, when it is included among the hazardous work listed in the decree of 19 March 1993 – french legislation (ionising radiation, work involving exposure to electricity above low voltage, falls from heights exceeding 3 metres, explosive atmospheres, etc.).

Furthermore, when a written plan is required, the employer must make it available to the competent authorities, in particular the labour inspectorate, social security bodies and, where applicable, the OPPBTP (Professional Organisation for Prevention in the Construction and Public Works Industry). They must also notify the labour inspectorate of the start of work (R4512-12).

Who is affected by the prevention plan?

The prevention plan covers:

• The user company (UC): it hosts the intervention and coordinates prevention on its site. It organises thejoint preliminary inspection and shares its instructions and infrastructure. It also ensures that the measures are consistent with its own risks (processes, energies, Explosive Atmosphere zones, electrical lockouts, etc.).
• The external company (EE) (service provider or subcontractor): it analyses its own risks, informs and trains its employees, proposes appropriate measures, and co-signs the plan. The subcontractors involved also participate in the joint inspection of the premises and the system.

The logic of shared responsibilities prevails: each party remains responsible for its employees and risks, while the EU provides overall coordination to prevent interference. This approach is described by the INRS (french National Institute for Research and Safety) and clarified by DRT Circular No. 93-14.

What should a prevention plan contain?

Implementing a prevention plan requires putting a number of elements in place and incorporating a set of prerequisites.

Minimum scope of a prevention plan

A compliant prevention plan covers at least:

• Identification of the parties (the User Company, External Company, subcontractors) and the purpose of the intervention (scope, duration, provisional schedule).
• The results of the joint inspection: areas of intervention, access and traffic routes, interfaces with production. The results also include specific points such as energy sources, proximity to live power lines and confined spaces.
• Interference risk analysis and prevention/coordination measures: These are decided jointly, according to the risk hierarchy (elimination, substitution, collective protection, procedures, PPE).
• Organisation of emergency response and situations: alert procedures, contacts, instructions and resources.
• Certifications and licences: required skills such as electrical certification, safety training or driving licences.
• Traceability: signatures, distribution, procedures for updating the prevention plan during the intervention.

Risk to be taken into account in a prevention plan

A number of risks must be taken into account:

• Risks associated with working at height: lifting, handling;
• Electricity: Work in the vicinity of or in contact with exposed parts carrying a voltage higher than extra-low voltage (ELV), lockout/tagout procedures, testing.
• Chemicals and ATEX (EXplosive ATmosphere)
• Biological agents, noise, thermal
• Confined spaces with a risk of drowning/burial, demolition work, or hyperbaric conditions. Some of these categories are included in the list of 21 hazardous tasks in the decree of 19 March 1993 – french legislation, which triggers the obligation to have a written plan.

The prevention plan complements the Single Document for the Assessment of Occupational Risks (DUERP in french) without replacing it: as a supplement to a risk prevention plan, it focuses on the interference of activities.

How to draw up a prevention plan: Standard content

In general, the prevention plan includes the following sections:

• Header & identification: EU/EE, contact persons, SIRET, locations and dates.
• Description of the operation: nature of the works, site constraints, simultaneous activities, schedule.
• Joint preliminary inspection: plans, areas, access, installations, energy points (electricity, fluids, vapours, gas), specific risks and associated documents.
• Interference risk analysis (summary matrix): hazardous situation with potential damage and preventive measures (technical, organisational, PPE). 
• Identification of responsible parties with definition of deadlines.
• Lockout, authorisations and permits: electrical authorisations, fire permits, marking, energy lockout.
• Traffic plan and restricted areas.
• Organisation of emergency response: alert procedure, numbers, resources (fire extinguishers, eye wash stations, etc.), interface with occupational health and safety and occupational medicine.
• Traceability and management: mailing list, welcome briefings, checks, updates (addenda), closure and feedback.

This framework complies with INRS recommendations on form and content, and is in line with Articles R4512-6 to R4512-12. A ready-to-use template facilitates adoption and proof of compliance. For more information, see our article Prevention Plan Template, which details and provides an example of a prevention plan.

When and how should a prevention plan be updated?

This document is not set in stone. The employer must update it as soon as any technical or organisational change occurs, whether it concerns a process, equipment, a subcontractor or the sequencing of tasks, or when an event warrants it, such as a near accident, a detected non-compliance or extreme weather conditions.

He must date and trace the amendments. He keeps the current version available to the authorities during the works. For recurring operations, he may maintain a framework plan and supplement it with specific work permits.

Digitally transform the prevention plan: why use software?

A prevention plan can be complex to draft and, above all, to maintain. In these difficult cases, the use of software is essential.

The limitations of paper and Excel

The different versions circulating by e-mail, data entry errors, lack of traceability (who has read it? who has signed it?), difficulty integrating plans and photos, manual follow-ups, scattered archiving and fragile access control are all limitations to the use of paper or Excel in the management of prevention plans.

These limitations complicate compliance verification and real-time updates on site.

The benefits of a digitally transformation of a prevention plan

A dedicated software tool enables:

• Step-by-step guidance in accordance with Articles R4512-6 to R4512-12, with integrated risk and measure libraries.
• EU/EE co-authoring, including electronic signatures, time stamps, and a version log.
• The integration of external documents such as permits, authorisations, plans, specific provisions, preventive maintenance plans and various media.
• Automatic notifications and exports for authorities and regulatory bodies.

Available software tools

Specialised solutions such as Altsis‘ Pégase solution streamline the creation, validation and archiving of plans while ensuring document compliance. For an overview of features and use cases, see our article on prevention plan software.

The prevention plan: much more than just a form

The prevention plan is much more than a document: it is an operational system for managing co-activity risks. Backed by the french Labour Code, well structured and digitised, it secures interventions, clarifies roles and strengthens proof of compliance.