What it is and what it is used for
Article 13 of Royal Decree 1627/1997 provides for an incident logbook for the control and monitoring of the health and safety plan. Its purpose is linked to prevention during execution. It is not a general production log or a record of any commercial aspects of the project.
The entries should be related to that purpose and allow for an understanding of the observed situation. Their usefulness depends on connecting facts, measures, and information to those who need to act. Writing in the logbook does not, in itself, eliminate the risk nor replace verifying that the corrective measure has been implemented.
Supply and custody
The royal decree establishes who provides the book: the professional association to which the technician who approved the plan belongs, or the project supervision office or equivalent body in public works, as appropriate. The procedure applicable to the case must be followed.
The logbook must always be kept on the construction site and in the possession of the health and safety coordinator during execution or, when their appointment is not required, the project management team. Its availability is essential for authorized personnel to perform their duties; it must not be inaccessible in an office unrelated to the project.
Who can access and record
The regulation grants access to project management, contractors, subcontractors, and self-employed workers, as well as to individuals or bodies with preventive responsibilities within the participating companies. It also includes workers’ representatives and technical staff from specialized bodies of the competent authorities, as defined in Article 13.
The entries must be related to the monitoring and tracking of the plan. The fact that different people may be involved requires clear identification of the author and the content. The right to make entries should not be confused with having the authority to make any management decisions or with an automatic modification of the approved plan.
How to write a useful note
An entry should describe specific facts: location, activity, observed condition, and its relation to preventive measures. Vague expressions that hinder identifying the problem or verifying its correction should be avoided. The indication of responsible parties and actions taken should be consistent with the roles of each person involved.
The royal decree requires specifying whether it is a new observation or a reiteration of a previous warning or observation. This distinction has implications for communications. Monitoring must maintain the connection between the initial note, the actions taken, and the subsequent verification of working conditions.
Notifications and referral to the Inspection
Once a note has been made, the coordinator or, where applicable, the project management team must notify the affected contractor and their workers’ representatives. The regulation does not stipulate that any initial observation is automatically referred to the Labor Inspectorate simply by being noted.
The copy must be sent to the Labor and Social Security Inspectorate within twenty-four hours when the entry refers to non-compliance with previously noted warnings or observations, and in the case of stoppage regulated in article 14. The specific case and the applicable communication channel must be verified, preserving evidence of what has been done.
Relationship with the work stoppage
In the event of serious and imminent risk, the coordinator during execution or a person integrated into the technical management may order the stoppage of the work site or the entire work in accordance with article 14. The protective action must not be delayed until a documentary formality is completed.
The work stoppage requires specific notification to the Labor Inspectorate, affected contractors and, where applicable, subcontractors, and workers’ representatives. This power should be distinguished from other work stoppage rights and powers provided for in the Occupational Risk Prevention Law. Resumption of work requires resolving the conditions that led to the stoppage, in accordance with applicable responsibilities.
Practical example
During a visit, a condition contrary to the plan is observed and noted, identifying the location and the required corrective measures. The intended recipients are notified, and a subsequent visit verifies whether the corrective action has been taken. The following visit detects a violation of the previously documented warning.
The new entry explicitly identifies the recurrence and triggers the submission of a copy to the Labor Inspectorate within the regulatory timeframe, in addition to the necessary preventive measures. If the situation constitutes a serious and imminent risk, action is also taken in accordance with the suspension procedure. This example demonstrates that monitoring and reporting depend on the facts, not on a single administrative routine.
Differences and common mistakes
The subcontracting log documents the chain of companies; the incident log is linked to monitoring the plan. A site visit report or an internal digital record can provide additional evidence, but it should not be assumed to replace the regulatory instrument and its communications.
Common errors include writing imprecise observations, failing to notify, forgetting the distinction between a new observation and a reiteration, and considering the risk resolved with the initial entry. Proper management keeps the logbook accessible, ensures required communications, and verifies the effectiveness of the measures on the actual construction site.
