01
Spain
- Legal framework
- Ley 31/1995 on the prevention of occupational risks · RD 39/1997 on prevention services
- Authority
- INSST — Instituto Nacional de Seguridad y Salud en el Trabajo
The deepest of the four, because it is where the product was born. Beyond risk assessment and preventive planning it covers two things with no equivalent in Ireland or the UK: inter-company coordination on a shared site, and the Spanish construction paperwork.
- Risk assessment and prevention plan (Ley 31/1995, RD 39/1997)
- Coordination of business activities on a shared site (RD 171/2004)
- Construction: subcontracting book, stop orders and incident logbook (RD 1627/1997)
- Accident notification to the labour authority via Delt@: the work-accident report is generated in the official «Estándar Delta» format, ready to import
- Automated regulatory watch: the BOE daily plus EU DOUE/EUR-Lex, classified and scored for how they apply to your company's activity; each company chooses the categories it cares about
- 25 INSST exposure limit values, by CAS number
- Six documents: prevention plan, risk assessment, preventive planning, training record, health surveillance and coordination
- Four sector templates: construction, hospitality, offices and industry
- Interface in Spanish, Catalan, Basque and Galician
Coordination of business activities (Article 24 of Ley 31/1995 and RD 171/2004) is a specifically Spanish legal construct: neither Ireland nor the UK has an equivalent. That is why it only appears in the Spanish jurisdiction. France has its own construct, the plan de prévention with outside contractors, and it appears in its section.
02
Ireland
- Legal framework
- Safety, Health and Welfare at Work Act 2005 · S.I. 299/2007, General Application Regulations
- Authority
- HSA — Health and Safety Authority
Ireland is not the Spanish module translated. It is its own regulations, its own deadlines and its own documents, and the product treats them as such: an injury with more than three days lost triggers HSA notification with the deadline computed on the incident record itself, not a generic reminder.
- Five legal requirements modelled: safety statement (s. 20), risk assessment (s. 19), general duty, General Application Regulations 2007 and chemical agents
- HSA notification: immediate in the case of a fatality
- More than three days lost: the deadline is computed and shown on the incident record (S.I. No. 370/2016)
- Automated EU DOUE/EUR-Lex watch: occupational-safety acts are ingested in English, classified and scored for applicability
- 25 HSA occupational exposure limit values (OELVs), by CAS number
- Five documents: safety statement, risk assessment, training record, health surveillance and accident record
- One sector template: automotive — vehicle repair, servicing and tyre fitting
- Interface in English, with the company in euro and Irish date formats
Section 20 of the SHWWA 2005 requires a written safety statement. It is the document an HSA inspector asks for on arrival.
What it does not cover yet. The construction module is built on Spanish regulations, so it does not fit an Irish contractor today. And there is one sector template so far, the automotive one.
03
United Kingdom
- Legal framework
- Health and Safety at Work etc. Act 1974 · MHSWR 1999 · COSHH 2002 · RIDDOR 2013
- Authority
- HSE — Health and Safety Executive
The thinnest of the four in its own content, and we say so here rather than let it be discovered in a demo. The engine is whole — RIDDOR fires with its deadline, EH40 values resolve by CAS number — but what arrives on day one is considerably shorter than in Spain.
- Five legal requirements modelled: risk assessment, competent person (MHSWR 1999), general duty (HSWA 1974), exposure control (COSHH 2002) and RIDDOR reporting
- HSE notification: immediate for a fatality, ten days for a reportable accident (RIDDOR 2013)
- 25 EH40 exposure limit values, by CAS number
- One document: the RIDDOR record, with its F2508 template
- Interface in English, with the company in pounds and British date formats
RIDDOR 2013: the ten-day deadline runs from the accident, and the product computes it on the record exactly as it does in Ireland.
What it does not cover yet. There are no UK sector templates. A UK customer starts from the English risk baseline and builds their own on top of it.
04
France
- Legal framework
- Code du travail, quatrième partie (santé et sécurité au travail) · Code de la sécurité sociale, art. L441-2 et R441-3 (accidents du travail)
- Authority
- DREETS — Inspection du travail
France is the newest jurisdiction and already has its own apparatus: the single risk document (DUERP) with its annual programme, health follow-up by the occupational health service (SPST), coordination with outside contractors and the declaration to the CPAM, each tied to its article of the Code du travail or the Code de la sécurité sociale.
- Eight legal requirements modelled: duty of safety (L4121-1), DUERP, PAPRIPACT, CSE consultation, SPST follow-up, safety training, registers and inspections, and the CPAM declaration
- Work accident declaration to the CPAM: the 48-hour deadline is shown on the incident record (Code de la sécurité sociale, art. L441-2 and R441-3)
- DUERP export to PDF and Excel, with the PAPRIPACT from 50 employees or the action list below that, and an annual review reminder from 11 employees or after a new site or an accident
- Plan de prévention with outside contractors (art. R4512-6 to R4512-12), in writing from 400 hours over 12 months or for dangerous work, and the protocole de sécurité for loading and unloading (art. R4515-4)
- Health follow-up: information and prevention visit, reinforced individual follow-up, pre-return and return-to-work visits, with the next visit calculated (art. R4624-10 to R4624-31)
- 25 INRS exposure limits (VLEP), by CAS number, and an exposure register for the six C2P factors with the thresholds of art. D4163-2
- Automated monitoring of the EU Official Journal/EUR-Lex in French; Nora and the generated documents cite the Code du travail
- Six documents: DUERP, plan de prévention, protocole de sécurité, training record, health follow-up summary and internal accident record
- Interface in French, with the company in euro and on Paris time
In France every work accident is declared to the CPAM within 48 hours, whatever its severity: there is no days-off threshold as in Ireland.
What it does not cover yet. There are no French sector templates and the construction module is still Spanish. The CPAM deadline is calculated, but the Cerfa declaration form is not generated. The DUERP is exported; filing it on the digital portal is up to the company. And regulatory monitoring covers EUR-Lex, not the Journal officiel.