You've just learned something concerning about a product, piece of equipment, or way of working in your company. You have no certainty, no benchmark, and no unlimited budget. Here's a five-step method to address the situation immediately and without putting yourself in a difficult position.
First step: detect
A signal arrives. Where does it come from? The sources are few and it is useful to know them.
First, from the field: an employee, a team leader, a staff representative. From the occupational health and safety service. From public monitoring: INRS news, opinions from health agencies. From literature. Or from a formal alert under Article L. 4133-1 of the French Labor Code, which allows any worker to alert their employer if they believe in good faith that the products or processes used pose a serious risk.
At this stage, there's only one thing to do: note it down, date it, and keep track. There's no such thing as an unwritten signal. And the date will be important later to assess whether you reacted within a reasonable timeframe.
Second step: qualifying
Ask the two questions from the European grid. Is it new, and based on what criteria? Is it increasing, and based on what criteria?
Quick reminder. Novelty can stem from the danger itself, society's perception of it, or an advancement in scientific knowledge. Growth can result from the number of dangers, the number of people exposed, or the worsening of health effects.
If you check both boxes, you have an emerging risk and you should proceed with the current method. If you only check growth, you have a prevention issue that needs to be addressed immediately, with resources, not with a study. If you only check novelty, you have a standard risk that should be assessed normally.
This step takes ten minutes and prevents you from starting the wrong project.
Third step: characterizing
Who is exposed, to what, how many people, how, and for how long?
Ask yourself this question for all the people present on your site, not just your permanent employees. Consider temporary workers, employees of your subcontractors, service providers, apprentices, and seasonal workers. And don't forget maintenance and cleaning operations, which are systematically overlooked even though they often concentrate the highest levels of exposure.
Here's the most surprising instruction: take responsibility for the blank spaces. Writing "number of people exposed: not yet established" is information, not an admission of weakness. It's actually crucial information because it justifies concrete action, which is to fill in the gap. What you must never do is leave a blank space without stating it. A blank space is interpreted as a zero.
Fourth step: deciding
Provisional and proportionate measures. Both adjectives matter.
Provisional, because the state of knowledge will evolve and you will revisit it. Proportionate, because a disproportionate measure will be circumvented by the teams, or abandoned at the first peak of activity.
Follow the order prescribed by the Labor Code. First, eliminate or replace anything dangerous. Then, implement collective protection measures. Next, address work organization. And personal protective equipment comes last.
This order is not an expert preference, it's a legal obligation. And it's also the first point you'll be criticized for if you reverse it, because starting with personal protective equipment is tantamount to placing the burden of prevention on the employee.
When no reference limit value exists, the logic changes. The goal is no longer to be below a threshold, but to reduce exposure to the lowest technically possible level. This is what specialists call the minimization logic, or ALARA logic.
Fifth step: dating
This is the time everyone jumps, and it's the one that protects you.
Record the risk in the single document, including the date, the current state of knowledge, and the assumed uncertainty. Include a review clause specifying both a deadline and the events triggering an early review. And when the regulations concerning carcinogenic, mutagenic, or reprotoxic agents apply, maintain a list of exposed workers, including the nature, duration, and intensity of their exposure.
Why insist so much? Because the day a pathology appears, the question won't be whether you knew. It will be what you did with what you knew, and when.
This is not a closed loop.
Each re-examination restarts the cycle. New information arrives, you qualify it, you update your characterization, you adjust your measures, you redate.
It's an ongoing process, not a project with an end date. This may seem daunting. In reality, once the first round is done, subsequent rounds take much less time, because the structure is already in place and all that remains is to feed it.
And above all, this method requires no special budget for the first three stages. Detecting, qualifying, and characterizing take time and rigor. Expenses, if any, only arise in the fourth stage, once you know what you're talking about.
KEY POINTS TO REMEMBER
- Detect: note, date and trace the signal, whatever its source.
- To qualify: new based on which criterion, growing based on which criterion. The diagnosis changes the action plan.
- Characterize: who is exposed, how much, to what, and above all, acknowledge in writing what one does not know.
- Decide: provisional and proportionate measures, in the order imposed by the Labour Code.
- Dating: the date, the assumed uncertainty and the review clause are what protect the company.
TO GO FURTHER
Do you want to apply this method to a specific situation in your company? That's the training format I offer: your real-life cases, not theoretical examples. Write to us to discuss it.
