The PGCSPS: the mandatory document for the construction industry

The PGCSPS (General Coordination Plan for Safety and Health Protection) is a prevention document drawn up by an SPS coordinator, mandated by a project owner.

In France, the development of a PGCSPS is mandatory for all construction and renovation sites which present particular risks, in particular:

• Large-scale construction sites.

• Complex construction sites.

• Construction sites involving simultaneous interventions by several companies.

  
  

This obligation is defined by the Labor Code in articles R4532-1 to R4532-57.

This plan is mandatory for construction operations:

• exceeding 20 workers over more than 30 working days ,

• or representing more than 500 man/days ,

• or involving work with particular risks , even for a lower volume.

The project owner must provide the PGCSPS in the business consultation file (DCE) . If it is not, neither he nor the coordinator can require a PPSPS (Special Safety and Health Protection Plan) from you . The PGCSPS is updated and adapted throughout the operation, as companies arrive on site and according to the different phases of work. This update is communicated to all companies by the SPS coordinator.

Although you do not have to write the PGCSPS, you must know it to establish your own PPSPS. The two documents are complementary .

The content of the PGCSPS

The PGCSPS includes several essential elements, including:

• A detailed description of the construction project, including administrative information such as the project name, site address, start and completion dates, budget, type of construction and site area.

• Identification of the various stakeholders on the site, including companies and subcontractors, with their names, numbers and the contracts binding them to the project.

• Analysis of risks related to the work and the preventive measures to be implemented to avoid them.

• The provisional schedule of the work and the different phases of the project.

• The coordination arrangements between the different companies and stakeholders.

• Specific provisions regarding safety and health at work, as well as the required personal protective equipment.

• Emergency access and evacuation plans.

• Procedures to follow in the event of an incident or accident on the construction site.

The main pitfalls to avoid

Here are the main pitfalls to avoid when setting up and operating a PGCSPS:

1. Copy and paste without customization

• Risk : A generic document does not take into account the specificities of the construction site (site, co-activity, hazards, etc.).

• Good practice : Analyze each site individually and adapt the content (technical constraints, environment, access, etc.).

  
  

2. Forgetting to link the PGCSPS to other security documents

• Risk : Inconsistencies between the PGCSPS, the PPSPS of companies, and the design PGC.

• Good practice : Coordinate documents from the design phase, ensure consistency with the project owner's DUER.

  
  

3. Underestimating coactivity

• Risk : Unassessed risks linked to the simultaneous presence of several companies (fall, collision, electricity, etc.).

• Good practice : Plan for phasing of interventions, separate work areas, staggered hours if necessary.

  
  

4. Neglecting business consultation

• Risk : Preventive measures will not be operational if they do not take into account the companies' methods.

• Best practice : Involve companies from the drafting phase and adjust the plan after receiving their PPSPS.

  
  

5. Writing a document that is too complex or too vague

• Risk : Lack of understanding by field teams, low ownership, ineffective application.

• Best practice : Use clear, structured language, with tables, plans, and diagrams if necessary. Avoid unnecessary jargon.

  
  

6. Forgetting to update the PGCSPS

• Risk : The document becomes obsolete if the conditions of the construction site change (change of schedule, new companies, etc.).

• Good practice : Set up active monitoring of the construction site with regular and recorded updates.

  
  

7. Do not include specific risks (lead, asbestos, ATEX, etc.)

• Risk : Regulatory non-compliance, serious unanticipated risks.

• Good practice : Use technical diagnostics (DTA, asbestos/lead identification, ATEX study, etc.) and integrate them into the PGCSPS.

  
  

8. Underestimating the role of the SPS coordinator

• Risk : The coordinator becomes a simple editor, without an operational role.

• Good practice : Ensure an effective presence on the ground, organize security coordination meetings, and implement the PGCSPS.

Place

The absence or inadequacy of a PGCSPS, in the event of a fatal accident on a construction site , may incur the criminal and civil liability of the project owner, the SPS coordinator, and sometimes other stakeholders. Here is a summary of the possible legal sanctions :

Criminal liability

For the project owner

• Legal obligation : It must appoint an SPS coordinator from the design phase for any construction site with at least two companies.

• In the event of a breach :

  • Fine of up to €9,000 (Article R. 4532-88 of the Labor Code) for failure to designate.

  • Criminal liability in the event of an accident if the lack of coordination contributed to the death (e.g.: involuntary homicide – article 221-6 of the Criminal Code).

  • Maximum penalty : 3 years imprisonment and a €45,000 fine , increased to 5 years and €75,000 in the event of a manifestly deliberate violation of a security obligation.

For the SPS coordinator

• May be prosecuted if he has not drawn up the PGCSPS or if it is clearly insufficient.

• Possible criminal sanctions : same basis as for the project owner in the event of negligence contributing to the accident.

For other stakeholders (project managers, companies, etc.)

• Prosecuted for co-action or complicity if they participated in poor organisation or did not comply with the PGCSPS.

• Example : a company that ignores the requirements of the PGCSPS or does not implement the measures provided for in its PPSPS may be sanctioned.

Civil liability

• Compensation for the victim's beneficiaries .

• The project owner and/or companies may be ordered to pay very substantial damages , sometimes several hundred thousand euros.

• Professional liability insurance can be used, but serious criminal offenses can sometimes exclude coverage .

Case law examples

• Lyon Court of Appeal, 2008 : conviction of a project owner for lack of safety coordination, leading to a death by fall.

  
  

• Court of Cassation, 2017 : an SPS coordinator was found liable for not having updated a PGCSPS despite major changes on the site.

  
  

• Court of Cassation, Criminal Division, September 14, 2010 (no. 09-87.886)

  
  

  Context

  On June 8, 2006, an electrician died after falling while replacing antennas on a water tower. Norisko Coordination, the company responsible for coordination and safety at the construction site, had established a PGCSPS.

  
  

  Shortcomings noted

  • The PGCSPS had not correctly assessed the risks associated with working at height, in particular the transport of bulky materials.

  • During a joint inspection visit with another company, these risks were not identified or addressed.

  
  

  Court decision

  The Court of Cassation upheld the criminal liability of Norisko Coordination. It ruled that the poor assessment of occupational risks in the PGCSPS constituted a fault directly linked to the fatal accident. The company's manager, responsible for validating the plan, should have identified and corrected this shortcoming.

  
  

  Source

  • Court of Cassation, Criminal, Criminal Division, September 14, 2010, 09-87.886