Construction health and safety plan

From study to plan: how it fits into the preventive system of the work

Royal Decree 1627/1997 establishes a system for occupational health and safety in construction projects, with clearly defined responsibilities. During the design phase, the project owner must commission a health and safety study (mandatory when the contract budget is equal to or greater than €450,759.08, the estimated duration exceeds 30 working days with more than 20 simultaneous workers, the labor volume exceeds 500 workdays, or the project involves tunnels, galleries, underground pipelines, and dams) or, in other cases, a basic study. This study identifies the avoidable and unavoidable risks of the planned work and the associated preventive measures and protective equipment.

During the execution phase, each contractor adapts these projections to their own circumstances: their resources, construction methods, machinery, subcontractors, and schedule. The result is the health and safety plan, which may propose alternatives to the measures outlined in the study, provided they are technically justified and do not reduce protection levels. When the study includes a cost estimate, the alternatives cannot result in a decrease in that amount. The plan is not a document of the designer or the developer, but of the contractor, who assumes responsibility for its content and implementation.

The health and safety coordinator during construction approves the plan and, when there are multiple contractors, coordinates their plans to ensure consistency. Subcontractors and self-employed workers do not develop their own plans; they are integrated into the plan of the contractor who hires them, which must incorporate their activities and risks. Law 32/2006 and Royal Decree 1109/2007 complete this framework with the Subcontracting Register and limits on the subcontracting chain.

Contents of the health and safety plan

• Descriptive report. Data on the work and the parties involved, description of the procedures, technical equipment and auxiliary means that the contractor will use, and analysis of the risks of each phase and unit of work.
• Risk identification and assessment. Risks that can be avoided and measures to avoid them, and risks that cannot be eliminated with preventive measures and technical protections to control them, including the special risks of Annex II of Royal Decree 1627/1997.
• Planning of preventive activity. Collective and individual protections, signage, temporary facilities, hygiene and welfare services, first aid and emergency and evacuation measures.
• Preventive organization. Preventive resources where applicable, contractor organizational structure, safety managers on site, worker training and information, and coordination with subcontractors and self-employed workers.
• Plans, specifications and budget. Plans showing the location of protections and access points, specifications with the applicable standards and requirements for equipment and protections, and economic valuation when the study includes it.
• Procedures and annexes. Safe work procedures for critical activities (work at height, excavations, assembly of structures, use of cranes and platforms), machinery data sheets and model minutes and records.

Approval, modification and monitoring

• Prior approval. Before the start of the work, by the health and safety coordinator during the execution phase or by the project management team; in public works, by the Administration with a report from the coordinator. It must be in writing.
• Opening notification. The notification of opening of the workplace, prior to the start, is accompanied by the approved health and safety plan, in accordance with Royal Decree 337/2010 and Order TIN/1071/2010.
• Modifications. Any change of method, equipment or phases, and any incident that alters the anticipated risks, is transferred to the plan through annexes or revisions that follow the same approval process.
• Availability and consultation. Permanent copy on site available to the project management, the coordinator, the contractors and subcontractors, the workers and their representatives, and the Labor and Social Security Inspectorate.
• Incident logbook. The plan is monitored using the incident logbook, with duplicate sheets, in which the coordinator, the project management team, the contractors, the Administration technicians and the workers’ representatives can make notes on its compliance.
• Stoppage. The coordinator or the project management team may order the stoppage of work areas or the entire project in the event of serious and imminent risk, recording it in the incident log and communicating it to the Inspection.

Organizational application: how to develop and manage the health and safety plan

1. Analyze the project’s basic health and safety study and compare it with the planned execution system: methods, machinery, auxiliary means, subcontracting and deadlines.
2. Draft the plan with the participation of production managers and the prevention service, incorporating the activities of subcontractors and self-employed workers and safe work procedures for activities with special risks.
3. Provide a technical justification for any alternative to the measures in the study and verify that it does not reduce the levels of protection or, where applicable, the economic valuation.
4. Submit the plan to the health and safety coordinator or the project management team well in advance and obtain the approval document before starting work.
5. Attach the approved plan to the notification of opening the workplace and keep a copy at the construction site.
6. Disseminate the plan to managers, workers, subcontractors and self-employed individuals through documented training and information and coordination meetings.
7. Review the plan in response to changes in phase, method or equipment, in response to incidents and based on the entries in the incident logbook, processing the annexes through the same approval procedure.
8. Verify compliance through periodic inspections and the presence of preventive resources in activities that require it.

Preventive management software allows you to keep the plan and its annexes versioned, record approval and dissemination, link procedures to each work site, and control the documentation of subcontractors and self-employed workers integrated into the plan.

Limits and common mistakes

1. Copying the health and safety study without adapting it to the contractor’s actual execution system, turning the plan into a generic document.
2. Starting work without a plan approval document, or approving it after work has already begun.
3. Propose alternatives to the study that reduce the levels of protection or the economic value.
4. Do not integrate the activities of subcontractors and self-employed workers, nor disseminate the content of the plan to them.
5. Do not update the plan in response to changes in method, new phases, incidents, or entries in the incident log.
6. Confusing the health and safety plan with the company’s risk assessment or with the prevention plan, which are different but related documents.

The detailed obligations of the promoter, designer, coordinators, contractors and subcontractors are set out in Royal Decree 1627/1997 and in the INSST technical guide; this sheet is for informational purposes.

Regulatory and reference framework

• Royal Decree 1627/1997, of October 24. Minimum safety and health provisions in construction works; articles 4 to 7 on the safety and health study and plan, article 13 on the incident book.
• Law 31/1995, of November 8. Law on the Prevention of Occupational Risks; duty of protection, evaluation and planning and coordination of business activities.
• Law 32/2006, of October 18. Regulation of subcontracting in the construction sector.
• Royal Decree 1109/2007, of August 24. Development of Law 32/2006: Register of Accredited Companies and Subcontracting Book.
• Technical guide for the assessment and prevention of risks related to construction works (INSST) . Criteria for the application of Royal Decree 1627/1997, including the content and procedure of the plan.

Royal Decree 337/2010 amended Royal Decree 1627/1997 regarding the notification of opening and the incident book, and Directive 92/57/EEC constitutes the European origin of the regulation of temporary or mobile works.