Planning of preventive activity

What is preventive activity planning?

Article 16.2.b of Law 31/1995 establishes that, if the results of the risk assessment reveal risk situations, the employer shall carry out the necessary preventive activities to eliminate, reduce, and control such risks, and that these activities shall be subject to planning, including for each one the timeframe, the designation of responsible parties, and the resources necessary for its implementation. Article 8 of Royal Decree 39/1997 adds that planning is mandatory when the risk assessment reveals risks and that it must be carried out in accordance with the principles of preventive action.

The minimum content is set out in Article 9 of the Regulation: the necessary human and material resources and the allocation of financial resources; emergency measures and health surveillance; information and training for workers; and the timeline, with phases and priorities based on the magnitude of the risks and the number of people exposed. Planning is done for a specific period and, if it exceeds one year, an annual program of activities must be established.

In the prevention documentation system, planning is the third instrument, along with the prevention plan and risk assessment. It is the most dynamic of the three: each planned measure has a life cycle (pending, in progress, implemented, verified), and the document must reflect that status at all times.

Differences between preventive planning, prevention plan and risk assessment

The three documents form a chain and are often mixed together in documentary practice.

• Prevention plan. It describes how prevention is organized within the company: policy, structure, functions, and general resources. It is the framework.
• Risk assessment. It identifies and evaluates the risks of each position and determines what measures are necessary. It is the diagnosis.
• Planning preventive activities. This transforms the assessment findings into a program with concrete measures, priorities, deadlines, responsible parties, and resources, and allows for its monitoring. It is action.

Practical rule: if the document states who does what in general, it’s the plan; if it describes the risks, it’s the assessment; if it specifies the measures to be taken, when, who will implement them, and with what budget, it’s the planning. A measure not included in the planning is not being managed, even if it appears in the assessment.

How planning is developed and maintained

The planning process begins with the measures proposed in the risk assessment and prioritizes them according to the hierarchy of controls and the magnitude of the risk. Its development is the responsibility of the company, with support from the occupational health and safety service, and workers’ representatives must be consulted.

The usual stages are:

1. Compile all measures derived from risk assessment, accident investigations, safety inspections, and labor authority requirements.
2. Prioritize according to the level of risk, the number of people exposed and the hierarchy of controls, recording the criteria.
3. Assign to each measure a responsible person with the real capacity to execute it, a deadline, and the necessary human, material, and economic resources.
4. Integrate cross-cutting activities: emergency measures, health surveillance, information and training, and periodic checks of working conditions.
5. Approve the plan, communicate it to the managers and the workers’ representatives, and register it as a controlled document.
6. Perform regular monitoring, verify the effectiveness of each measure implemented, and update the plan with any new measures that arise.

Monitoring is the part that most frequently fails. Article 16.2.b of the Law requires ensuring the effective implementation of preventive activities and carrying out continuous monitoring; planning without a record of implementation does not comply with this mandate.

Content and usual fields of a plan

Although the regulations do not impose a format, a useful plan usually includes the following for each measure:

• Origin. Risk or deficiency that motivates the measure and reference to the evaluation, inspection or investigation from which it originates.
• Measure. Specific description of the action, with the level of the hierarchy of controls to which it corresponds.
• Priority and deadline. Risk level, assigned priority and execution deadline, with phases if the measure is complex.
• Responsible party and resources. Person or unit responsible, budget, and allocated human and material resources.
• Status and verification. Status of the measure, actual date of implementation, verification of effectiveness and, where applicable, risk reassessment.
• Cross-cutting activities. Emergency and drill program, health surveillance, information and training, and periodic checks.

Digital management systems allow this record to be kept up-to-date, with expiration alerts and traceability of who did what and when, making it easier to prove the follow-up in the event of audits and inspections.

Common errors and quality criteria

The most common deficiencies detected by regulatory audits and Labor Inspections in planning are:

1. Generic measures copied from the evaluation without specifying what will be done or where.
2. Non-existent or non-decision-making managers, such as assigning all measures to an external prevention service.
3. Deadlines expired without justification or documented rescheduling.
4. Lack of budget or allocated resources, which turns planning into a list of intentions.
5. Lack of follow-up: measures marked as executed without evidence or verification of effectiveness.
6. Disconnection from the rest of the system: measures that do not reach training, coordination of activities or health monitoring.

A quality plan is concrete, prioritized, resourced, with real people in charge, with recorded monitoring and reviewed at least annually or when the evaluation changes.

Regulatory framework in Spain

• Law 31/1995, article 16.2 . It requires planning the preventive activities derived from the evaluation, with deadlines, responsible parties and resources, and ensuring their effective execution through continuous monitoring.
• Royal Decree 39/1997, articles 8 and 9. They determine when planning is necessary and its minimum content: means, economic resources, emergencies, health surveillance, information and training, and timing by phases and priorities.
• Law 31/1995, articles 23 and 33. They include planning among the mandatory documentation and require consultation with workers on the planning and organization of work.
• Basic guidelines for the assessment of occupational risks (INSST, 2021) . They place planning as a result of the assessment and provide guidance on the prioritization and monitoring of measures.

In Colombia, Peru or Chile the equivalent figure is the annual work plan or the annual OSH program required by their management systems; the logic (measures, responsible parties, deadlines and resources) is the same, but the formats and registration obligations are specific to each country.