Overdue or forgotten VGP inspection: what do you risk, and what should you do right now?

What you risk with an overdue VGP

VGP (vérification générale périodique), the periodic thorough inspection French law requires for lifting equipment, is an employer's obligation, set out in article R4323-23 of the French Labour Code (Code du travail) and the orders that implement it. Even if the inspection is outsourced to a body or the machine is hired, responsibility remains with the company whose employees operate the equipment.

• Criminal penalty: article L4741-1 of the French Labour Code fines an employer or their delegate ten thousand euros for personally and culpably breaching health and safety rules, including those on work equipment. The fine applies for each worker concerned. On repeat offence: one year's imprisonment and a fine of thirty thousand euros.
• Labour inspectorate: during an inspection, the inspector can review the safety register and reports. They can also require the employer to have the equipment's compliance checked by an accredited body (article L4722-1).
• In the event of an accident: a missed VGP shows the hazard was not checked. It can weigh in establishing the employer's “faute inexcusable” (inexcusable fault) — a breach of their duty of care despite being in a position to be aware of the danger — and in assessing their criminal liability.
• Clients and insurers: a client or insurer can request up-to-date reports. A machine without a valid VGP can be turned away from a site. Check the clauses in your contract.

What to do right away

1. Check the real date: look for the last VGP report and the safety register. The sticker is not enough — it can be false or out of date. According to INRS, it only shows the date of the last inspection.
2. Stop the machine: equipment whose VGP is overdue is no longer up to date with its inspections. The safest course is to stop using it until it is inspected, and to tell the team. For equipment that lifts people, such as an aerial work platform, take no chances.
3. Call your inspection body or inspector: ask for a prompt visit. If the inspection cannot happen immediately, ask them what they recommend for your machine.
4. Hired machine: contact the rental company. They must be able to provide the report of the last VGP, which must accompany the equipment (order of 1 March 2004, article 15). Without a report, the machine does not work.
5. Prepare for the inspection: instructions, previous reports, maintenance logbook, an available operator, test loads if needed (article 3 of the 2004 order).
6. Record it: note the date the delay was discovered, when the machine was stopped, and the date of the inspection. After the VGP, record the result in the safety register (article R4323-25) and deal with any reservations raised.

What if the machine was used during the delay?

You cannot undo the past. The most useful thing is to get the inspection done as soon as possible, fix any defects found, and keep a clear record of the steps taken. If the report flags a serious defect, INRS points out that the employer must act on every observation: depending on its nature, the machine either stays in service or must be stopped.

Use the opportunity to check the rest of the fleet: a lapse rarely comes alone. It often reveals tracking that relies on one person's memory.

How to never miss a VGP again

• A single schedule: one row per machine, with the equipment type, the interval (3, 6 or 12 months), the date of the last VGP and the next date. Our free VGP tracking Excel spreadsheet is a good starting point.
• Early alerts: a reminder at least a month before the deadline gives time to book the inspection body and free up the machine.
• A named owner: one person tracks VGP inspections, with a stand-in during their leave.
• Grouping inspections: scheduling machines on the same site for the same visit reduces the number of dates to track.
• A check on every machine's arrival: purchase, hire or return from repair — check the report before first use.
• Reports kept in one place: the safety register and reports can be kept on any medium, including digitally (article R4323-27).

Overdue VGP and return-to-service inspection: don't confuse them

An overdue VGP is caught up with a VGP. A return-to-service inspection is something else: it is required after dismantling and reassembly, a major repair to an essential component, an accident, or a change of configuration (order of 1 March 2004, article 20). If the machine was repaired while out of service, tell your inspector — a return-to-service inspection may be needed.