External companies are regularly called upon to work on the premises of another company: deliveries, cleaning services, equipment maintenance or repair, etc. Co-activity or the external company's lack of familiarity with the work environment generates significant risks.
All work or services carried out by one or more companies on the premises of a user company must be coordinated by the head of the user company in order to prevent risks related to interference between the activities, facilities and equipment of the different companies present at the same workplace.
A joint preliminary inspection must be carried out under the responsibility of the head of the user company, who must invite the heads of the external companies involved in the upcoming intervention to the user company's premises. This visit must, in particular, allow for:
- to specify the work to be carried out, the equipment used and the operating procedures
- to define the area of intervention, to identify and prevent hazards
- to communicate the applicable safety instructions within the company
- to indicate traffic routes as well as access to hygiene facilities
A risk assessment, based on the work carried out by each external company and especially on the co-activity between these external companies and the user company's regular operations (which generate new risks), must be conducted rigorously and meticulously. The results of this risk assessment must be included in the document, whatever its form, which will be signed by all company directors or their representatives, and then by all employees of the external companies involved in the project.
When the risks of co-activity between external companies and the user company are: likely to exceed 400 cumulative hours per rolling year (meaning the total hours spent by each of the external company's workers on the premises of the user company) OR likely to be included on the list of hazardous work defined by the French Labor Code (Decree of March 19, 1993) without any mention of cumulative hours, a prevention plan must be drawn up (Decree No. 2008-244 of March 7, 2008) containing, in particular:
- the definition of hazardous activity phases and corresponding specific prevention measures
- adapting equipment, installations and devices to the nature of the operations to be carried out, as well as defining their maintenance conditions
- instructions to be given to workers
- the organization put in place to provide first aid in case of emergency and a description of the system put in place for this purpose by the user company
- the conditions for the participation of workers from one company in work carried out by another in order to ensure the necessary coordination
The following must also be included in the plan or attached to it:
- the distribution of maintenance costs between external companies
- the list of positions held by workers likely to be subject to individual monitoring
- technical files relating to asbestos-containing materials
However, following the joint preliminary inspection, if the nature of the work is that of construction or civil engineering and the site is enclosed and independent, a General Health and Safety Coordination Plan (PGCSPS) will be drawn up under the responsibility of a health and safety coordinator when:
- The anticipated number of workers must exceed 20 at any point during the work, and the duration of the work must exceed 30 working days.
- The planned volume of work must exceed 500 man-days.
- The works present specific risks listed in the regulations.
If the PGCSPS is not attached to the Tender Documents (DCE), the project owner or coordinator cannot require you to draw up your PPSPS.
These numerous and thick documents should in no way obscure, depending on the circumstances, and potentially cumulatively, the drafting of fire permits (hot work permits), work authorizations or even authorizations to enter (into confined spaces), but I will reserve that for another article.
