Czas czytania: 7 minut
What training a contractor must prove before entering your plant in Spain
Spain's rules on coordinating business activities don't require the site owner to train its contractors' staff, but they do require it to inform and instruct them before work starts. If the service is part of its own core activity, it must also demand written proof that the contractor has trained and informed every person who comes in.
Coordination of business activities (known in Spain as CAE, coordinación de actividades empresariales) is the set of obligations triggered when workers from two or more companies share the same workplace. It is regulated by Royal Decree 171/2004, which develops Article 24 of Spain's Occupational Risk Prevention Act.¹ ² In a plant with external maintenance, industrial cleaning and installation work, that happens almost every week.
The most common mistake is to treat it as paperwork: ask for each operator's safety training certificate, file it and open the gate. The regulation asks for something else. It separates three obligations (informing, instructing and training) and assigns each one to a different company.
In this article we explain what falls to each company, what must be accredited before a contractor enters the plant and what it looks like in a concrete case.
Royal Decree 171/2004 distinguishes between the company that owns the workplace, the concurrent companies and, when the service is part of its own core activity, the principal company. The same company can be both owner and principal.
| Who | What they must do | When | In writing? |
|---|---|---|---|
| All concurrent companies | Cooperate and inform each other about risks from their activity that affect the others (art. 4) | Before work starts | If risks are serious or very serious |
| Workplace owner | Inform about the site's risks, preventive measures and emergency measures (art. 7). Give instructions to prevent them (art. 8) | Before work starts and whenever risks change | If risks are serious or very serious |
| Contractor | Take that information into account in its own risk assessment, follow the instructions and pass them on to its workers (art. 9) | Before work starts | As set out in art. 18 of the Prevention Act |
| Principal company (services within its own core activity) | Monitor the contractor's compliance and demand written accreditation of its risk assessment, prevention plan and its workers' information and training (art. 10) | Before activity begins | Yes |
The last point is the one most often overlooked. On top of that, the principal company is jointly liable with its contractors and subcontractors for safety infringements committed at its site during the contract.³ And the accreditation requirement runs down the chain: if the contractor subcontracts part of the service, it must request the same documents from its subcontractor and hand them to the principal.¹
The three words appear together in every coordination procedure, but they are not met by the same company.
The confusion has consequences both ways. If the owner treats a site induction talk as "the contractor's training", nobody has trained those people for their job. If it just asks for the generic safety certificate, nobody has told them about the risks of that particular site.
Before opening the gate, each contractor's file should contain the following:
Points 2 and 5 are the ones that fail most often when the team changes. The logic is the same as in the mixed crews of the energy sector we describe in our article on field crew training: what matters is who is coming in today, not the list that was sent a month ago.
A food plant hires a maintenance company to service a packaging line on Saturday. The service is part of its own core activity, so the plant acts as both owner and principal. On Friday afternoon the list arrives: four technicians, one of them a last-minute replacement. Names are illustrative.
| Technician | Training accreditation (contractor) | Site information received | Lockout instructions for the line | Coming in on Saturday? |
|---|---|---|---|---|
| Rubén | Yes | Yes | Yes | Yes |
| Ainhoa | Yes | Yes | Yes | Yes |
| Jorge | Yes | Yes | No | Not until he receives them |
| Carlos (replacement) | Not included | No | No | No |
Carlos isn't in the accreditation the contractor sent, so the plant has to request it before letting him in. Jorge is trained, but he hasn't received the lockout instructions for that line, which changed last month. If the line requires lockout, that machine's locking sequence should be part of what is passed on to him, as we explain in how to train lockout procedures.
Site information is repeated with every contractor and every change in risks. Preparing it once as a short module that is sent by link and records who has completed it is the kind of task that custom training tools like Vidext prepare with AI from the site's own procedures, with the safety team's approval before it goes out.
Coordination of business activities splits obligations fairly clearly. The owner informs and instructs, the contractor trains and passes information on, and the principal checks and demands written proof. The hard part isn't understanding the split, but keeping it up to date when the list of people changes the day before. An accreditation that doesn't include the person coming in today accredits nothing.
The site owner must give it information about the site's risks, preventive and emergency measures, and instructions to prevent those risks, before work starts and in writing if the risks are serious or very serious. Job-specific training is provided by the contractor to its own workers.
That companies sharing a workplace cooperate and exchange risk information, that the owner informs and instructs the others, that each contractor passes that information on to its workers and that, for services within its own core activity, the principal company monitors compliance and demands written accreditation.
With a named list per contractor and per job: who is coming in, what training accreditation their company has provided, when they received the site information and instructions, and in which version. The record should be updated every time a team member changes, not only when the contract is signed.
No. Job-specific training is the responsibility of each worker's employer. The owner has to inform and instruct about its site's risks and, if the service is part of its own core activity, demand written proof that the contractor has trained and informed its workers.
If the service is part of its own core activity and is carried out at its site, the principal company is jointly liable with the contractor for safety obligations during the contract, under Spain's Law on Social Order Infringements and Penalties. That's why it makes sense to demand accreditation before entry, not afterwards.
¹ Royal Decree 171/2004 on coordination of business activities, consolidated text - BOE ² Ley 31/1995 on Occupational Risk Prevention, article 24 - BOE ³ Royal Legislative Decree 5/2000, Law on Social Order Infringements and Penalties, article 42.3 - BOE
Program wspierania zatrudnienia na czas nieokreślony wykwalifikowanych osób młodych w ramach Krajowego Systemu Gwarancji dla Młodzieży. Vidext otrzymał dotację w wysokości 25.401€ przyznaną przez LABORA (Walencka Służba Zatrudnienia i Szkoleń) na zatrudnienie na czas nieokreślony w 2024 r. wykwalifikowanych osób młodych zarejestrowanych w Krajowym Systemie Gwarancji dla Młodzieży; działanie kwalifikuje się do współfinansowania z Europejskiego Funduszu Społecznego Plus (EFS+) 2021-2027 lub innego funduszu Unii Europejskiej. Expediente ECOGJU/2024/550/46. Niniejsza publikacja jest dokonywana w wypełnieniu obowiązków przejrzystości określonych w ustawie 19/2013 z dnia 9 grudnia.
