What Article 15 of the LPRL requires
Article 15 develops the duty of protection in Article 14. Employers must apply it before starting an activity and when reviewing conditions. Issuing protective equipment or writing an assessment is insufficient: how prevention decisions are made matters.
These criteria originate in Article 6.2 of Framework Directive 89/391/EEC. This article explains their Spanish application; it does not automatically transfer those obligations to other countries.
The nine principles, with examples
- Avoid risks: eliminate an unnecessary operation, such as access at height that can be achieved from ground level.
- Assess unavoidable risks: analyse remaining exposure and decide which measures it needs.
- Combat risks at source: capture an emission where it is generated.
- Adapt work to the person: adjust heights, reaches, equipment and pace, also addressing monotony and repetition.
- Consider technical progress: review whether safer solutions exist for a known process.
- Replace what is dangerous: consider another product or method that reduces danger without introducing greater risks.
- Plan coherently: integrate technology, organisation, conditions, social relationships and the working environment.
- Prioritise collective protection: favour a barrier protecting everyone rather than relying solely on individual equipment.
- Provide appropriate instructions: explain how to perform the task, its limits and when to stop.
Difference from the hierarchy of controls
The hierarchy of controls ranks intervention types such as elimination, substitution and engineering controls. Article 15 principles have a broader scope, including adaptation of work, planning and professional capabilities.
The approaches complement each other. The familiar control pyramid should not be presented as a literal reproduction of the nine legal principles, nor should instructions be interpreted as permission to omit a feasible collective solution.
Capabilities, access and foreseeable errors
Paragraphs 2 and 3 require consideration of professional capability when assigning tasks and restrict access to areas of serious and specific risk to people with sufficient, appropriate information.
Paragraph 4 requires provision for distractions and non-reckless carelessness. Protection cannot always depend on perfect attention. Risks introduced by the measure itself must also be assessed: a solution obstructing evacuation or creating entrapment requires review before implementation.
How to incorporate them into planning
For each risk, record what can be avoided, alternatives considered, the selected measure and how effectiveness will be checked. Assessment and planning must preserve that connection.
Articles 8 and 9 of the Prevention Services Regulations connect planning with the principles, risk magnitude, people exposed and necessary resources. Owners, deadlines and follow-up must be specified, alongside appropriate interim measures.
Errors to avoid
Buying PPE first, copying measures without observing the task or closing an action because training took place leaves the central decision unresolved: could the risk have been eliminated or better controlled?
Verification must take place in actual work. An installed but disabled measure, an incomprehensible instruction or a pace incompatible with the planned method does not resolve the problem. Process changes, incidents and workforce observations must inform review.
Hypothetical example: cleaning parts
A workshop cleans parts with a product generating vapours. Before simply requiring respiratory protection, it considers eliminating some cleaning through process changes and substituting the product. For residual exposure, it considers a closed system or capture at source, adapts the workstation and instructs staff.
Planning records the chosen solution, its deadline and how exposure control will be verified. The example illustrates the reasoning; it does not specify a product, ventilation system or PPE suitable for every workshop.
