Health and safety coordinator

What is the health and safety coordinator?

Construction projects involve significant risks and a wide variety of companies and self-employed workers who work simultaneously. Directive 92/57/EEC addressed this reality by creating a coordination role with clearly defined responsibilities at each stage. In Spain, Royal Decree 1627/1997 incorporated this role and integrated it into the existing structure of construction stakeholders: developer, designer, project management team, contractor, subcontractors, and self-employed workers. The construction-phase coordinator is part of the technical project supervision team and is appointed by the developer, although their function is in the public interest and not merely to represent the developer.

There are two coordinators, who may be the same person. The health and safety coordinator during the project design phase is appointed when several designers are involved and is responsible for ensuring that the project incorporates preventative principles and for preparing, or having prepared, the health and safety study or the basic study. The coordinator during the construction phase is appointed before work begins or as soon as the involvement of several companies or self-employed workers is established, and performs the functions outlined in Article 9 of the Royal Decree throughout the entire construction period.

For building works, the fourth additional provision of Law 38/1999 identifies architects, technical architects, engineers and technical engineers according to their competence and specialisation. Competence must be assessed for the particular project; specific preventive training does not by itself replace the required professional qualification.

Functions of the coordinator during construction (article 9)

• Coordinate the application of prevention principles. This includes making technical and organizational decisions to plan the work and estimating the duration of each phase.
• Coordinate the activities of the work. Ensure that contractors, subcontractors and self-employed workers consistently apply the principles of article 15 of Law 31/1995 and the provisions of the health and safety plan.
• Approve the health and safety plan. Approve the contractor’s plan before work starts and expressly authorise relevant amendments during construction; in public works projects, the approval corresponds to the Administration with a report from the coordinator.
• Organize the coordination of business activities. In accordance with Article 24 of Law 31/1995 and Royal Decree 171/2004, through meetings, information exchange, and coordination mechanisms.
• Coordinate work methods. Ensure the correct application of the planned procedures and work methods.
• Control access. Take the necessary measures to ensure that only authorized persons have access to the construction site; the project management team assumes this function when the appointment of a coordinator is not required.
• Incident logbook. The book remains on site under Article 13. Entries are notified to the affected contractor and its workers’ representatives. A copy is sent to the ITSS within twenty-four hours where previously recorded warnings have not been complied with and in the Article 14 situation, specifying whether the observation is new or repeated.
• Stoppage. Order the stoppage of the work sites or the entire project in the face of serious and imminent risk , notifying the Labour Inspectorate, affected contractors and, where applicable, subcontractors, and their workers’ representatives.

Relationship with other agents

• Developer. Appoints coordinators where required and commissions the necessary preventive instruments, without exemption through appointment. The former Article 18 prior-notice requirement is repealed; the Article 19 opening notification is made only by employers who are contractors.
• Project designer. Integrates prevention into the design. The study or basic study is prepared by the competent professional appointed by the developer; where a design-phase coordinator is appointed, that coordinator prepares it or arranges its preparation under their responsibility, under Articles 5 and 6.
• Contractor. Develops the health and safety plan, applies preventive principles, complies with and enforces the plan, informs subcontractors, and designates preventive resources.
• Technical project supervision team. The construction-phase coordinator forms part of this team. Where no coordinator is required, the team assumes the plan approval or reporting role under Article 7 and the access-control function.
• Preventive resource. A contractor figure who monitors compliance with preventive activities on the construction site, distinct from the coordinator.
• Labour Inspectorate. Receives logbook copies in the circumstances and period specified by Article 13.4, and stoppage notifications under Article 14.

Organizational application: how to integrate the coordinator into the project

1. Appoint the project coordinator when several designers are involved, and the construction-phase coordinator before work starts or as soon as the involvement of several companies or self-employed workers is established, keeping a documentary record of the appointment.
2. Commission the health and safety study or basic study, as applicable, and provide the coordinator with project and planning information.
3. Require the contractor to provide the health and safety plan well in advance for analysis and approval, and update it in case of changes.
4. Establish the system for coordinating activities: regular meetings, information exchange, means of coordinating and controlling subcontracting.
5. Implement access control to the construction site with identification of authorized persons and companies.
6. Keep the incident logbook available and use it rigorously, following up on the entries until it is closed.
7. Document the coordinator’s visits, checks, and communications as evidence of their actions.

Preventive management software can organise plans, versions, communications and coordination tasks. Traceability depends on complete, verifiable records; it does not replace professional action on site or guarantee compliance by itself.

Limits and common mistakes

1. Delay appointment even though the circumstances requiring a coordinator already exist, or wait for an Inspectorate visit.
2. Approving the health and safety plan without analyzing it or approving generic plans that do not correspond to the work.
3. Confusing the role of the coordinator with that of the contractor’s preventive resource or with that of a company prevention technician.
4. Limiting coordination to the collection of documentation without on-site presence or real coordination of activities.
5. Not using the incident logbook or not following up on the entries.
6. Consider that the designation of the coordinator exempts the promoter and the contractor from their responsibilities.

The functions and responsibilities are detailed 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: designation and functions of coordinators.
• Law 31/1995, article 24. Coordination of business activities.
• Royal Decree 171/2004, of January 30. Development of article 24 of Law 31/1995 on the coordination of business activities.
• Law 38/1999, of November 5, on Building Regulations, fourth additional provision . Qualifications required for the health and safety coordinator.
• Technical guide for the assessment and prevention of risks related to construction works (INSST) . Criteria for the application of Royal Decree 1627/1997.

Council Directive 92/57/EEC establishes the minimum health and safety requirements for temporary or mobile construction sites and is the origin of the figure of the coordinator; Law 32/2006 regulates subcontracting in the construction sector.

Appointment by the developer and continuity of coordination

Article 3 of Royal Decree 1627/1997 distinguishes coordination during design from coordination during construction. The former is required where several designers participate; the latter where more than one company, a company and self-employed workers, or several self-employed workers participate. The developer must appoint the construction-phase coordinator before work begins or as soon as that circumstance is established. Waiting for an accident is inappropriate, and the check cannot be reduced to counting employees of a single company. These are Spanish statutory requirements.

The appointment should identify the phase, site, competent person and means available to perform the function. For building works, the fourth additional provision of the Building Act identifies qualifying professions according to their competence and specialisation; it does not make every listed qualification universally sufficient for every project. Specific training and knowledge of construction processes support effective performance. Formal appointment alone does not establish that real coordination is taking place, or that the professional has received the information needed for the work.

Changes in contractors, phases and scheduling require review of coordination arrangements. As a management measure, a replacement professional should receive information on outstanding risks, approved plans, logbook entries and unresolved decisions. Continuity is not achieved merely by changing a name in a platform. The developer should enable the function to be performed and retains its own responsibilities under Article 3.4, even when appointing an independent professional. Handover arrangements should reflect the actual stage of work rather than an abstract administrative checklist.

Project supervision, coordinator and contractors: separate functions

The construction-phase coordinator is a competent professional within the technical project supervision team, known in Spain as the dirección facultativa. Preventive functions should not be confused with every power to direct and supervise construction. Article 9 specifies coordination of preventive principles, activities, methods and access, alongside the health and safety plan. Clear allocation helps distinguish who decides a technical solution, who arranges a work sequence and who physically installs a protective measure. English terminology must preserve these differences between statutory roles.

Each contractor retains its duties to prepare the plan appropriate to its construction method, comply with it and ensure compliance by its personnel. Contractors and subcontractors must correctly implement their respective measures and follow applicable directions and instructions. Article 11.3 prevents the responsibilities of the coordinator, technical supervision team or developer from exempting executing companies. The contractor’s designated preventive resource is also a separate role with specific duties; appointing that person does not replace construction-phase coordination or transfer every employer duty to them.

Plan approval follows Article 7: it belongs to the construction-phase coordinator or, where no coordinator is required, the technical supervision team. For works commissioned by public administrations, the plan and relevant report are submitted to the awarding administration for approval. Amendments require express approval on the same terms. Coordination must reflect the real progress of work. Retaining an approved plan without reviewing significant changes does not guarantee that current risks are properly addressed, either in the documents or in the work actually performed.

Assess liability through specific actions and evidence

A liability investigation must identify the applicable duty, particular conduct, actual powers and available evidence. The title of coordinator and the occurrence of an accident do not alone establish civil or criminal liability. The same assessment applies to residential construction: the building’s use does not automatically make the professional responsible for every company failure. Established facts, technical hypotheses and legal conclusions should remain distinct, with safeguards for affected people. The assessment concerns the individual circumstances rather than a predetermined conclusion based on the job title.

Articles 316 and 317 of the Criminal Code have specific conditions involving a preventive breach, failure by a legally obliged person to provide necessary means, and serious danger, with the negligent form governed by the statutory requirements. Not every documentary defect constitutes these offences, and a position should not mechanically be equated with criminal authorship. Where injury or death occurs, potential result-based offences require their own assessment, including causation and individual attribution. The absence of injury also does not automatically exclude every danger-based offence.

Relevant evidence can include instructions, visits, alerts received, responses, available resources and follow-up of deficiencies. Examine what each person knew, when they knew it and what they were required to do, without manufacturing a retrospective appearance of supervision. Distinguish recommending a measure, directing action within one’s powers and checking implementation. Recording a warning alone does not establish that the problem was resolved. The case file should show what happened afterwards and which conditions remained at the site when subsequent activities took place.

Respond to breaches and serious and imminent danger

Article 14 addresses the construction-phase coordinator and any other member of the technical supervision team who observes health and safety breaches. The contractor must be warned and the breach recorded in the incident logbook where it exists under the regulation. In circumstances of serious and imminent danger, the provision authorises stopping the affected work areas or the whole project. Action must address the observed risk rather than wait for the next meeting or for the same breach to be repeated.

Article 13.4 distinguishes notification of a logbook entry to the affected contractor and its workers’ representatives from sending a copy to the Labour Inspectorate. A copy must be sent within twenty-four hours where previously recorded warnings or observations have not been complied with, and in the situation covered by Article 14. The entry must specify whether it repeats an earlier warning or is a new observation. This rule should not be replaced with an inaccurate statement that every entry is sent, or only a risk already observed twice.

The person ordering a stoppage must notify the Inspectorate, affected contractors and, where appropriate, subcontractors, and their workers’ representatives. In a hypothetical example, an unprotected opening presenting a serious fall exposure calls for action and the required communications without waiting for a second observation. Subsequent planning should establish corrections and checks before work resumes in safe conditions. Administrative recording must be distinguished from actual removal of the danger that prompted the intervention; sending a message does not itself protect the exposed people.

Professional engagement, civil liability and useful records

An independent coordinator’s engagement should define the project, phase, scope, available information and communication channels. Visits and follow-up should be organised according to the work and risks, without presenting a weekly or fortnightly frequency as a universal statutory rule. Private terms cannot empty legal duties of substance or automatically transfer all developer or contractor responsibilities. An ambiguous engagement makes both performance and later reconstruction of required services harder. Changes to the assignment should be documented and communicated to the people who rely on the arrangements.

Contractual and non-contractual civil liability are assessed under their respective conditions, including Articles 1101 and 1902 of the Civil Code where applicable. Breach, harm and causal connection require substantiation; a professional invoice, insurance policy or appointment alone does not replace that assessment. Insurance terms require examination of coverage and exclusions, without promising protection against every claim. Available proceedings and the parties entitled to bring them depend on the relationship and circumstances. The general description of the role cannot decide an individual claim.

A useful file brings together the engagement, plan and report versions, meeting records, logbook entries and verifiable communications, with access controls and original preservation. A platform helps locate evidence and follow tasks, but storing documents does not create physical coordination. Final handover should identify completed actions and outstanding matters without providing a general guarantee that no risks remain. The preventive purpose is to ensure decisions reach the companies and people who must implement them throughout construction, including changing crews and subcontractors.