Company safety register in France: what to record for your machines?

What the French Labour Code says

There is no official form. INRS (the French national research and safety institute) sums it up: the employer must make sure that inspections of work equipment are recorded in an up-to-date document, whatever its form. The Labour Code (Code du travail) sets the rules:

• Documents relating to health and safety inspections and checks must contain mandatory information (article L4711-1): they are dated and state the body responsible for the inspection and the person who carried it out (article D4711-2).
• The result of the periodic general inspections (vérifications générales périodiques, VGP) of work equipment is recorded in the safety register or registers (article R4323-25). The same applies to personal protective equipment (article R4323-101).
• If the inspector does not belong to the establishment, their report is attached to the register. Failing that, the register states the date of the inspection, the date the report was handed over and where it is filed (article R4323-26).
• Where this information appears in separate registers, the employer may combine it into a single register, provided this makes it easier to keep and consult (article L4711-5). This is an option, not an obligation.

What to record for machines and lifting equipment

For lifting appliances and accessories (aerial work platforms, forklifts, cranes, machines fitted for lifting, slings), the ministerial order of 1 March 2004 (arrêté du 1er mars 2004) sets out the process: a provisional report at the end of the inspection, the final report within four weeks, then the results entered without delay in the safety register by the head of the establishment (article 3). To read that report properly, see how to read a VGP report.

An entry is made for each of the following events:

A register template you can reuse

No text imposes columns. These follow the requirements of D4711-2 and R4323-26, plus two follow-up columns. One line per inspection and per item of equipment. OPPBTP (the French construction industry prevention body) also offers a free downloadable template (16-page PDF, in French).

How long to keep it, who can see it, paper or digital

Retention: unless a specific text says otherwise, the employer keeps the documents of inspections and checks from the last five years and, in any event, those of the last two inspections (article D4711-3). For an appliance inspected every six months, that is about ten reports.

Access: labour inspectors and the prevention services of the social security bodies (Carsat) have access to them during their visits (article L4711-3). The documents are communicated to the members of the social and economic committee (CSE), the occupational physician and, where relevant, the industry prevention bodies: in construction, OPPBTP (article L4711-4; Prévention BTP).

Medium: the register and reports may be kept and stored on any medium (article R4323-27), under the conditions of article L8113-6, which requires equivalent control guarantees to be maintained. These guarantees are not listed: in practice, a digital register should stay dated, quick to consult and keep the original reports, for example as PDFs. No location is imposed: you must be able to produce it on request.

What this register is not

The fire-safety register of buildings open to the public (ERP). In these buildings, the French Construction and Housing Code (Code de la construction et de l’habitation) requires a register that records in particular the fire-safety staff, the fire instructions, the dates of checks and inspections with their findings, and fit-out works (article R143-44). Different law, different purpose: if your rental branch receives the public, both registers coexist.

The single staff register (registre unique du personnel). Despite the word “unique”, it lists employees in order of hiring (article L1221-13) and has nothing to do with equipment.

The maintenance logbook (carnet de maintenance). For each lifting appliance, it records servicing, repairs and modifications until the appliance is scrapped (order of 2 March 2004). See the maintenance logbook for lifting appliances and the list of mandatory documents for a construction machine.

What is the penalty without a register?

Breaching articles L4711-1 to L4711-5 and D4711-1 to D4711-3 is punishable by the fine for fourth-class petty offences (contraventions de quatrième classe), applied as many times as there are employees concerned (article R4741-3). For an individual, this fine is up to 750 euros (French Criminal Code, article 131-13).

The real risk lies elsewhere: without a register or reports, the employer cannot prove that the machines were inspected, while remaining responsible for the inspections even when they are outsourced (INRS).

What Trackary does, and what it does not

Trackary stores inspection reports as PDFs on each machine’s record, along with the next VGP due date and alerts. A finding can become an issue to deal with, closed with a work report. Trackary costs €14 excl. VAT per active machine per month (€11 above 50 machines), unlimited users, with a 30-day free trial, no credit card required.

Trackary does not carry out inspections, certifies nothing and does not replace the inspection body. Keeping the register remains the employer’s obligation.