OHS document management is an essential part of occupational risk prevention in any company operating in Spain, especially when several contractors and subcontractors are involved in the same construction project.
Not having a mandatory document, having an expired accreditation, or presenting information that does not correspond to the activity actually carried out can lead to incidents during an inspection, prevent workers from accessing a construction site, or hinder coordination between participating companies.
For this reason, conducting an OHS documentary audit before starting a project allows for the detection of non-compliance and incomplete documentation before they become a problem.
What is an OHS documentary audit?
An OHS documentary audit consists of systematically reviewing documentation related to occupational risk prevention to verify that it is complete, current, and adapted to the characteristics of the company and the project.
This review may include both general company documentation and specific documentation for a construction project, workers, machinery, equipment, or specific activities.
It is important to differentiate this review from the audit of the prevention system regulated by the Regulation on Prevention Services.
Royal Decree 39/1997 establishes that the audit of the prevention system is a systematic, documented, and objective evaluation of the effectiveness of the prevention system and regulates when an external audit or evaluation must be carried out.
Therefore, when a company refers to an “OHS documentary audit,” it usually refers to a prior or complementary documentary compliance review, whereas a legal audit of the prevention system has a specific scope and requirements.
What documentation should be reviewed?
The scope depends on the activity, the number of workers, the type of construction project, and the specific obligations of the company. However, an OHS document management review can check, among other aspects:
General company documentation
- Occupational Risk Prevention Plan.
- Risk assessment.
- Planning of preventive activity.
- Adopted prevention organization.
- Agreement with the prevention service, when applicable.
- Preventive training and information.
- Health surveillance.
- Documentation related to emergencies and first aid.
- Records and evidence of preventive activity.
The prevention plan must integrate prevention into the company’s general management system and reflect, among other elements, its organizational structure, production organization, prevention modality, and resources allocated to prevention.
Worker documentation
The review can verify that the documentation corresponding to the individuals who will access the construction site is available and up-to-date.
Depending on the characteristics of the work, it may include:
- OHS training.
- Information on the risks of the position.
- Medical fitness when applicable.
- Delivery and control of personal protective equipment.
- Authorizations for specific tasks.
- Training or accreditation for certain equipment.
- Designation of a preventive resource when required.
- Documentation for seconded workers in the case of foreign companies.
Not all documents are required in all cases. Precisely for this reason, the review must be carried out taking into account the specific activity and not through a simple generic list of documents.
OHS Audit of Contractors and Subcontractors
In construction, document management takes on an additional dimension due to the presence of different companies on the same construction project.
The contractor may need to verify that subcontracted companies have the necessary prevention documentation before allowing them to begin work.
Among other aspects, the following can be reviewed:
- Company identification and documentation.
- Registration in the Register of Accredited Companies (REA), when applicable.
- Preventive organisation.
- Worker training.
- Skills and accreditations.
- Machinery and equipment documentation.
- Work procedures.
- Risk assessments.
- Provision of PPE.
- Specific documentation required by the project.
- Preventive information and coordination.
Coordination of Business Activities (CAE) must be adapted to the characteristics of each situation of business concurrency. The INSST indicates that CAE should be considered a process adapted to the nature and structure of the organization and to each specific scenario.
Therefore, document management should not be limited to storing files. It is necessary to verify that the documentation truly responds to the risks and activities being carried out.
Frequent errors that a documentary audit can detect
A specialized review can identify incidents that are not always evident to a company’s administrative department.
Some examples include:
Expired documentation.
Certificates, training, medical examinations, or accreditations may have exceeded their validity period.
Incomplete documentation.
The company may have some of the necessary documents, but lack an essential one to complete the file.
Information that does not match the reality of the construction project.
The documented procedure may not correspond to the work actually carried out.
Workers not included in the submitted documentation.
A personnel addition that is not updated on the document platform can generate an access incident.
Machinery without updated documentation.
Certain equipment requires documentation, revisions, or accreditations that must be available before use.
Problems in the subcontracting chain.
When multiple levels of companies are involved, it is necessary to keep track of the information corresponding to each participant.
Documentation submitted in another country that does not, by itself, prove compliance with Spanish requirements.
This point is especially relevant for foreign companies that second workers or carry out projects in Spain.
Why hire an expert in OHS document management?
Spanish prevention legislation includes numerous obligations that can vary depending on the activity, prevention modality, characteristics of the workplace, and type of construction project.
For a company unfamiliar with the Spanish regulatory framework, identifying what documentation is needed can be particularly complex.
A specialized consultant can perform a preliminary review, identify deficiencies, and establish what documentation needs to be completed or updated.
Furthermore, in the case of construction projects, it may be necessary to coordinate the documentation of different companies, workers, and equipment, as well as manage document platforms and specific requirements established by the project.
At GespreObra, we can help you review, prepare, and manage your company’s prevention documentation in Spain, in addition to offering CAE services, safety and health coordination, OHS technicians, and a technical office. If you are a foreign company that will carry out work in Spain and want to verify that your OHS documentation is ready before starting on site, contact us and rely on the support of a team specialized in prevention and construction project coordination.
