Three documents with different functions
The prevention plan establishes how prevention is integrated into management. Planning specifies assessment-based measures, priorities, deadlines and resources. The report and programme organise, respectively, the review and actions for the period.
They should not operate as separate files repeating incompatible data. If an important measure remains outstanding, the report should explain why and the next programme address it, without erasing the original commitment or retrospectively changing its deadline.
The legal framework by type of prevention service
Article 15.5 of Royal Decree 39/1997 requires an annual report and programme for an internal prevention service to be prepared and kept available to the competent authorities and committee. Article 20 regulates external services’ activities and delivery of reports and programmes to client companies.
Article 39.2.d of the LPRL gives the Safety and Health Committee the right to examine and provide its views on these documents. One format or workflow should not be applied without qualification to every organisational arrangement.
What the report should explain
- Scope: period, sites, activities and disciplines included.
- Activities: assessments, reviews, training and other work completed.
- Follow-up: measures implemented, outstanding and checked for effectiveness.
- Relevant changes: processes, equipment, organisation or harm prompting new action.
- Participation: consultations and matters discussed with preventive representatives.
- Conclusions: difficulties, needs and priorities carried into the next period.
Health results must respect confidentiality. A management review is not the place for individual diagnoses or medical records.
Building an executable programme
The programme must connect each action with a specific need and define an owner, deadline and resources. Articles 8 and 9 of the Prevention Services Regulations link planning, risk magnitude, exposed people and follow-up; where activity is planned for more than a year, an annual programme must exist.
Repeating “visits, training and reviews” is not enough. What will be reviewed and the expected outcome must be clear. The company should coordinate contracted activities with those performed using its own resources to avoid gaps or duplication.
Distinguishing the company report from the service’s report
Order TIN/2504/2010 distinguishes, for accredited external prevention services, overall organisational data from specific activities at each company and site. These are different information levels.
Article 6 requires that service-wide report to be made available to the labour authority before 1 April of the following year. That date must not be presented as a universal deadline for every annual preventive document in every company.
Review, participation and practical value
The review should support decisions: whether resources were sufficient, priorities were closed and planned changes need further intervention. Committee and management review should focus on results and outstanding issues, not merely acknowledge receipt of a document.
It is useful to maintain stable indicator definitions and justify scope changes. Comparing two years without noting the addition of new sites may produce mistaken conclusions about activity or results.
Hypothetical example: outstanding measurements
A company’s report records that an assessment identified a need for certain measurements, but these were not taken because the process changed. Rather than marking them complete, it explains the situation and interim measures adopted.
The new programme sets a review of the assessment, an owner and a deadline for deciding on and carrying out the relevant measurements. The committee follows progress and the company can check whether the issue is resolved, without confusing a completed visit with risk control.
