Not under that name. The Labor Code requires the employer to inform workers who use or maintain a machine (article R4323-1) and to train them in safety (article L4141-2). The safety card at the workplace is a means of making these instructions readable in front of the machine.
In short
- The obligation applies to information and training operators, not on a specific document. The sheet is a way to keep it at the station.
- A job description is mandatory in at least one case, the most frequent in the workshop: the post exposes workers to dangerous chemical agents. This is the posting notice (article R4412-39).
- A useful sheet summarizes, point by point, what Article R4323-1 requires to be transmitted. Reviewing it each time the machine is modified and after each incident is important. good practice.
What the Labor Code really requires: informing and training
No article of the Labor Code requires a «safety sheet at the workplace.» What it does require is broader: that every person who works on a machine knows how to do it without getting hurt.
Inform. Article R4323-1 requires the employer to «appropriately» inform workers responsible for the use or maintenance of work equipment. It lists four topics:
- the conditions of use or maintenance of equipment; ;
- the instructions or directions which concern them, in particular those concerning manufacturer’s instructions ;
- the being prepared to deal with foreseeable abnormal situations ;
- the Conclusions drawn from the experience gained which make it possible to eliminate certain risks.
The following article, R4323-2, expands the circle: all the workers of the establishment They must be informed of the risks of the equipment located in their immediate environment, even if they do not use it, as well as of the modifications that affect them. The operator who passes behind the press is concerned, not just the operator.
Former. The obligation to provide training stems from Article L4141-2: the employer organizes practical and appropriate training in safety, particularly for workers he employs and for those who change jobs or techniques, and repeats it periodically. For machinery, Article R4323-3 specifies its duration. Renewal It is renewed and supplemented as often as necessary to keep up with the evolution of equipment. Article R4323-4 adds a specific training for those involved in maintenance and modification.
The text therefore says what transmit, not in what form. An oral instruction on the day of an operator’s arrival is not read again six months later. A page displayed at the station, yes.
A case where a job description is mandatory: the job description
There is at least one case, the most common in the workshop, where the Labour Code requires a written document, item by item. Article R4412-39 requires one job description for every job or work situation that exposes workers to hazards dangerous chemical agents, classified or not (article R4412-3).
This manual must:
- Inform about risks to which the work exposes and measures measures to avoid them; ;
- to recall the hygiene rules applicable; ;
- give, if necessary, the Instructions for the use of protective equipment.
It is not the machine that triggers the obligation; it is the position or process: what is used there, and how. A cutting fluid, a degreasing solvent, a glue: check, product by product, whether they fall within the definition of Article R4412-3, including when they are not classified. If so, and if you have the position sheet and the safety data sheet on the same support, check that everything required by Article R4412-39 is included in it.
Safety sheet at the station, instruction manual, DUERP: who writes what, for whom
Three documents talk about the same risks. They are not addressed to the same person.
| Document | Who writes it | For whom | What it covers |
|---|---|---|---|
| Instruction notice | The manufacturer of the machine | All users of the machine | The entire life of the machine: transport, installation, adjustments, use, maintenance |
| DUERP (unique document for the assessment of occupational risks) | The employer | The company, the workers and their representatives | All the risks of the company, per work unit |
| Security file at the station | The employer | The operator in front of the machine | What this operator needs to know and do in this position |
The form is at the end of the chain: it translates what the instructions and risk assessment have established, for someone who has only a few seconds to read it. But writing it requires looking closely at the post. If you discover a discrepancy there, for example a cleaning that is carried out with the door open and that the assessment did not see, it is not included in the form: it is sent back up to the DUERP and its action plan.
The manufacturer writes the instructions; his client, the employer, writes the fiche. The manufacturer can provide a fiche based on his instructions, which his client completes with his workshop, organisation and risk assessment.
What a useful sheet should contain
The safest way to ensure you don’t forget anything is to start from the four topics of Article R4323-1 and give each of them a place on the form.
| What R4323-1 requests | Where he goes on the sheet |
|---|---|
| Terms of use and maintenance | The tasks What the operator does on the machine, in order (start-up, production, adjustment, cleaning, shutdown) |
| Instructions and guidelines, including those in the manual | The measures to be respected for every task, and the PPEs to wear |
| Managing abnormal, predictable situations | The conduct to be followed : emergency stop, accident, fire, which to prevent |
| Lessons from experience | Instructions added after an incident or a near-accident on this job |
Above this table, the datasheet starts with the dangers This can be harmful in this position (training, cuts, projection, noise, product). This is what gives meaning to the following measures.
Three rules make the sheet readable:
- One sheet per post, Not by machine family. Two identical presses in two different workshops do not have the same environment.
- Action verbs. « Record the machine before opening the casing », not « it is appropriate to ensure that it is recorded ».
- What is actually being done. The datasheet describes the position as it works, not as it should work.
Who writes it, who validates it, when to review it
Who writes it. The obligation to inform rests with the employer. In practice, the safety or QHSE manager prepares the form together with the workshop manager and, ideally, the operator of the position: it is he or she who knows what is actually being done.
Who validates it. Whoever is responsible for this in the company, after having confronted her with the actual position. A written form in the office, without going through the machine, risks missing an important step.
When I see her again. None of the articles cited here requires a safety sheet to be revised at the station. The only written update rule concerns the station notice: it is «updated as necessary» (article R4412-39). For the sheet, revising it is a good practice, based on the times when the information transmitted is no longer valid:
- the machine is modified or the environment changes: the modifications must be brought to the attention of the workers concerned (R4323-2) and the training must be completed (R4323-3); ;
- an incident or accident occurs: this is what Article R4323-1 calls the acquired experience; ;
- a new operator arrives at the station, or an operator change of job This is the time for his security training (L4141-2), and the form serves as a support document.
Keep track of each version. A datasheet without a date does not tell you whether it describes the machine of today.
Starting from the manufacturer's manual rather than a blank page
Article R4323-1 itself states this: the instructions to be transmitted include, among others, those contained in the manufacturer’s instructions manual. The instructions are therefore the first source of the fiche, not a reference to be cited at the bottom of the page.
The difficulty: the instructions cover the entire life of the machine, and the instructions concerning the operator are scattered across several chapters. You have to find them, sort them, rewrite them in a few lines, and then add what your risk assessment says about this position.
It is this selection that pushes the decision back. And it is this that can be entrusted to a tool, provided that the review is kept in mind.
Write the profile with Optima Job
Optima Job part of the documents you already have on the machine: instructions manual, DUERP, risk analysis, photo of the workplace. You specify the workplace and the workshop. The test produces a first draft of the report in four sections: hazards, tasks, measurements, PPE.
The full application adds driving in the event of an accident, emergency services and fire, and indicates for each instruction the document from which it comes. Your workshop’s feedback, however, remains to be written by you: it is not included in the manual.
What Optima Job does not do: validate the profile. It is a first draft, which your security manager checks against the actual position, corrects it and signs it before displaying it. The tool is still under validation: we tested it on our own test sets.
Frequently asked questions
What is a hazardous chemical agent within the meaning of the Labour Code?
Article R4412-3 of the Labour Code includes two categories: agents classified as dangerous, and those who, without fulfilling the classification criteria, may present a risk to health and safety due to their physico-chemical, chemical or toxicological properties and the way they are present or used. Any agent for which a limit value for occupational exposure is set by decree is included in this category.
When should an operator be trained in security?
Article L4141-2 of the Labour Code imposes practical and appropriate safety training on temporary employees upon hiring, when changing job duties or techniques, and upon resumption after at least 21 days of absence, at the request of the occupational health physician. It is repeated periodically, and for machinery, renewed and supplemented as often as necessary as the equipment changes (article R4323-3).
Should the machine manufacturer provide the safety fiche to the station?
No. The obligation to inform workers about the use of a machine falls on the employer (Article R4323-1 of the Labour Code). The manufacturer provides the instruction manual, the instructions of which are part of what the employer must convey.
Safety card at the station and station card: what's the difference?
The job description is a human resources document that describes the duties and competencies of a job. The job safety sheet describes the hazards of a workplace, the tasks involved, the measures to be followed, and the protective equipment to be worn. One does not replace the other.
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