Safety and health coordination is one of the most important obligations within the preventive management of a construction project in Spain. However, there are still doubts about when it is mandatory to appoint a safety and health coordinator, who must do so, and what responsibilities each of the parties involved in the project has.
For developers, construction companies, subcontractors and, especially, foreign companies starting to carry out projects in Spain, understanding these requirements is essential to avoid non-compliance and to properly organise prevention before work begins.
The main legal framework is Royal Decree 1627/1997, which regulates the minimum safety and health requirements on construction sites.
When is it mandatory to appoint a safety and health coordinator?
The obligation to appoint a safety and health coordinator depends mainly on the number and type of parties involved in the project.
According to Article 3 of Royal Decree 1627/1997, the developer must appoint a safety and health coordinator in certain cases. The regulations distinguish between the project design phase and the construction execution phase.
Project design phase
Appointment is mandatory when several designers are involved in preparing the project.
In this case, the developer must appoint a competent technician to coordinate the application of preventive principles during the design and planning phase. The aim is to integrate prevention from the outset and to assess technical and organisational decisions before risks reach the execution phase.
This coordination can be especially relevant in complex projects in which, for example, architects, engineers and different specialists responsible for different parts of the design take part.
Construction execution phase
The obligation is more common during execution. The developer must appoint a safety and health coordinator when the following are involved on site:
- More than one company.
- One company and one or more self-employed workers.
- Several self-employed workers.
The appointment must be made before work begins or as soon as it is confirmed that these circumstances apply. In addition, appointing a coordinator does not release the developer from its own legal responsibilities.
Therefore, it is not only the size of the project that determines the need for a coordinator. A relatively small project may require coordination if different companies or self-employed workers are involved.
What happens if only one company is involved?
When only one company is involved, it will not always be mandatory to appoint a safety and health coordinator during execution.
However, this does not mean that preventive obligations disappear. The project will still be subject to the applicable prevention and safety regulations, and the corresponding documentary and organisational obligations must be met.
In cases where appointing a coordinator is not necessary, certain functions assigned by the regulations may be assumed by the site management team, as happens, for example, with the approval of the Safety and Health Plan when applicable.
For this reason, before starting a project it is advisable to analyse its actual contracting structure and not limit the assessment solely to its budget or duration.
The functions of the safety and health coordinator on a construction site
The coordinator’s role is not simply to review documentation. During execution, they have essential functions to ensure that the different companies and professionals apply preventive principles consistently.
Their main responsibilities include:
- Coordinating the application of the general principles of prevention and safety.
- Coordinating the activities of contractors, subcontractors and self-employed workers.
- Approving the Safety and Health Plan and, where applicable, monitoring its amendments.
- Organising Business Activity Coordination.
- Coordinating control actions to ensure the correct application of working methods.
- Adopting the necessary measures to control access to the site by authorised persons.
These functions are set out in Article 9 of Royal Decree 1627/1997. Contractors and subcontractors, for their part, must follow the coordinator’s instructions and continue to comply with the preventive obligations that apply to them.
When should a construction safety and health consultancy be involved?
Having a construction safety and health consultancy can be especially advisable from the earliest phases of the project, even before execution begins.
A specialised consultancy can help to:
- Determine whether it is mandatory to appoint a coordinator.
- Analyse the obligations of the developer, contractor and subcontractors.
- Integrate prevention during the project phase.
- Prepare or review the necessary preventive documentation.
- Coordinate the involvement of companies and self-employed workers.
- Manage documentary requirements linked to subcontracting.
- Monitor safety during execution.
- Prepare the company for possible inspections or requests.
In more complex projects, it may also be necessary to have prevention technicians on site with a presence adapted to the project’s needs. GespreObra provides coordination services, Business Activity Coordination (CAE), prevention technicians and safety and health advisory services for construction projects.
Foreign companies: the importance of preparing the project before starting
When a foreign company comes to Spain to carry out a project, questions may arise about who must assume each obligation, what documentation must be prepared, and what requirements the companies that will form part of the contracting chain must meet.
Key aspects to review before starting include:
- The project’s contracting structure.
- Whether it is necessary to appoint a safety and health coordinator.
- The obligations of the developer and the executing companies.
- The necessary preventive documentation.
- Coordination between companies and self-employed workers.
- Requirements related to subcontracting.
- The company’s status with the Accredited Companies Register (REA), where required.
Anticipating these requirements helps avoid administrative delays and problems arising from starting a project without a properly organised preventive structure.
Proper coordination protects the project and makes it easier to deliver
Determining whether safety and health coordination is mandatory is one of the first steps in properly organising any construction project. The key is to analyse who is actually involved on site and how execution is structured.
When several companies are involved, or one company and self-employed workers, or several self-employed workers, the developer must appoint a safety and health coordinator during execution under the terms established by Royal Decree 1627/1997. From there, active coordination makes it possible to integrate prevention into day-to-day planning and improve control of activities carried out simultaneously or successively.
Is your foreign company going to carry out a project in Spain?
If your company is going to act as a contractor or subcontractor in Spain, having a specialised consultant from before work begins can help you identify the applicable obligations and properly prepare the project’s preventive and documentary structure. At GespreObra, we offer safety and health coordinator services, consultancy, preventive coordination and document management for companies carrying out projects in Spain.
In addition, we can be a key support in reviewing requirements related to the Accredited Companies Register (REA), especially when a foreign company needs to assess its situation and comply with the applicable obligations in order to participate in the contracting or subcontracting chain. Before starting your project, discuss your case with one of our advisors and prepare your entry into the Spanish market with a properly organised prevention, documentation and subcontracting strategy.
