Integration of prevention

What is the integration of prevention

Law 54/2003, which amended Law 31/1995, placed the integration of prevention at the heart of the Spanish prevention system to combat mere formal compliance: prevention is not a set of documents prepared by an external service, but a way of working. Article 16.1 of Law 31/1995 requires that prevention be integrated into the company’s general management system, both in all its activities and at all hierarchical levels, through the prevention plan. Royal Decree 39/1997 clarifies that integration into an activity or at a hierarchical level means that its implementation procedure has been established and is applied respecting the applicable preventive requirements, and that the individuals involved in its management or implementation have been assigned the corresponding preventive functions.

Integration has two dimensions. The vertical dimension, along the hierarchical line, involves management approving policy and allocating resources, middle management planning and supervising work with preventative criteria, and employees applying procedures and reporting deficiencies. The horizontal dimension encompasses activities and processes: equipment and product acquisition, contracting and subcontracting, facility design and modification, personnel recruitment, maintenance, organizational changes, and emergency management all incorporate prevention as a quality requirement.

The occupational health and safety service, whether in-house or external, does not replace the organization in this task: it advises, supports, and evaluates, but the responsibility for and implementation of prevention lies with the company and its chain of command. The INSST technical guide for integrating prevention into the company’s general management system elaborates on this approach with practical criteria based on the type of activity and hierarchical level.

Instruments of integration

• Prevention plan. Document that describes the organizational structure, responsibilities, functions, practices, procedures, processes and resources necessary to carry out preventive action, approved by management, assumed by the entire structure and known by all staff (Article 2 of Royal Decree 39/1997).
• Risk assessment and planning. Essential tools for managing and implementing the plan; planning assigns responsibilities, deadlines, and resources in the different areas.
• Procedures with preventive content. Procedures for purchasing, contracting, maintenance, work permits, change management, staff onboarding, and coordination with contractors that include health and safety requirements.
• Assignment of functions. Written definition of the preventive functions of each management position and of the staff, with the necessary training to perform them.
• Consultation and participation. Worker safety representatives and the health and safety committee as a channel for integrating the vision of the workers.
• Indicators and review. Monitoring the degree of integration through internal and regulatory audits, activity and outcome indicators, and management review.

How is integration assessed?

• Regulatory audit. Article 30 of Royal Decree 39/1997 requires the audit to assess the integration of prevention into the company’s general management system, through the implementation and application of the prevention plan.
• Inspection Criteria. The Labor Inspectorate checks whether the company’s activities are carried out in accordance with preventive requirements and whether managers assume their functions, beyond the existence of documents.
• Signs of true integration: Purchasing and design decisions that consider safety, managers who oversee compliance with procedures, incident reporting without retaliation, performance-based training, and resources allocated in the budget.
• Signs of formal integration: Generic prevention plan, external prevention service operating without internal liaisons, managers unaware of their roles, and unimplemented planning measures.

Organizational application: how to integrate prevention

1. Approve a prevention policy signed by management that declares integration as a principle and allocates resources.
2. Define in writing the preventive functions of each level (management, supervisors, staff) and of the prevention service, and incorporate them into job descriptions and performance evaluations.
3. Review the procedures for critical activities (purchasing, contracting, maintenance, design, onboarding, change management, emergencies) to include preventive requirements and responsible parties.
4. Train managers in their preventative functions and in monitoring compliance, and train staff in the procedures of their position.
5. Establish channels for communicating risks and incidents and for consultation with representatives, with documented responses.
6. Measure integration with indicators (measures executed on time, inspections carried out by managers, incidents reported, training completed) and audit internally.
7. Review the prevention plan by management and update it in response to organizational changes.

Preventive management software facilitates integration by distributing preventive tasks among managers with deadlines and evidence, connecting planning with daily operations, and providing management with indicators of the degree of compliance.

Limits and common mistakes

1. Confusing integration with documentation: having a plan, evaluation and planning without changing practices.
2. Outsourcing prevention to an external prevention service without internal interlocutors or functions assigned to managers.
3. Defining preventive functions without training, time, or authority to perform them.
4. Leaving out key activities such as purchasing, contracting for works and services, or process changes.
5. Measure only the accident rate and not the degree of application of the procedures and measures.
6. Approving generic prevention plans that are not adapted to the actual organization of the company.

The required level of integration is adapted to the size and activity of the company; in SMEs it can be achieved with simple procedures and clear functions.

Regulatory framework in Spain

• Law 31/1995, articles 14, 16 and 31. Duty of protection, integration of prevention through the plan and functions of the prevention services.
• Royal Decree 39/1997, articles 1, 2 and 30. Integration of preventive activity, prevention plan and audit.
• Law 54/2003, of December 12. Reform of the regulatory framework for the prevention of occupational risks to strengthen integration and combat formal compliance.
• INSST technical guide for the integration of prevention . Practical criteria for integration by activities and hierarchical levels.
• ISO 45001. Occupational health and safety management systems: leadership, participation and integration into business processes.

In Colombia, Decree 1072 of 2015 requires that the SG-SST be integrated into the company’s management with responsibilities assigned to all levels; the ISO 45001 standard requires that senior management integrate the system requirements into business processes.