Do we always need a preventive resource on a Spanish site?

No. Only in the cases the law sets out: concurrence that aggravates risks, activities legally classed as dangerous, a requirement from the Labour Inspectorate and, in construction, the special risk works in Annex II of Royal Decree 1627/1997.

Can our site foreman be the preventive resource?

They can, if they have the knowledge, qualification and experience for the activities to be supervised and hold at least the basic level prevention training. The job title alone does not qualify anyone.

How many hours of basic level training are required?

Thirty as a general rule, and fifty when the company carries out one of the activities in Annex I of the Prevention Services Regulation, which includes construction.

Does training from our own country count?

Not automatically. The requirement refers to the Spanish basic level programme, so equivalence has to be assessed and in many cases the fastest route is to complete the Spanish training.

Is one general appointment enough for all our sites?

It depends on the client, but most ask for it referred to the specific site or task. A generic appointment usually ends up rejected.

Preventive resource in Spain: when it is required and who can be one

What it is

The preventive resource is one or more people appointed by the company whose job is to be physically present at the workplace, watching that the preventive measures are being applied and that they actually work. The figure was introduced by Law 54/2003 into article 32 bis of the Spanish occupational risk prevention act.

Presence is the whole point. It is not a title held from an office or a form that gets signed and filed: the appointed person has to be where the work that triggered the appointment is being carried out, for as long as it lasts.

When it is required

It is not needed on every job. Spanish law sets out specific situations, and outside them there is no obligation to appoint one:

When risks may be aggravated or altered by successive or simultaneous operations that make it necessary to check the correct application of working methods.
When the work involves activities or processes legally classed as dangerous or carrying special risks, listed in article 22 bis of the Prevention Services Regulation.
When the Labour Inspectorate requires it because of the working conditions it has found.
On construction sites, additionally, for the works with special risks listed in Annex II of Royal Decree 1627/1997, such as risk of burial, particularly serious risk of falling from height, work near high voltage power lines or in confined spaces, among others.

Who can be appointed

The company can assign that presence to several profiles, and this is where most improvisation happens. Being on site is not in itself enough to qualify.

One or more workers designated by the company for preventive duties.
One or more members of the company's own prevention service.
One or more members of the external prevention service the company has contracted.
Other employees who are not part of the preventive organisation, provided they have the knowledge, qualification and experience needed for the activities to be supervised, and hold at least the basic level prevention training.

The basic level training

When the appointed person is one of your own employees, the minimum is the basic level prevention training, whose content and duration are set by Annex IV of the Prevention Services Regulation: thirty hours as a general rule, and fifty hours when the company carries out one of the activities in Annex I, which includes construction.

This is a different thing from job specific training and from the sector collective agreement training. A client may well ask for both: one shows the person can act as preventive resource, the other that they can do their trade.

Not the same as the safety coordinator

Several preventive figures coexist on a Spanish construction site and foreign contractors mix them up constantly. Each one is appointed by a different party:

Health and safety coordinator: appointed by the developer, not by the contractor, and responsible for coordinating the site as a whole.
Prevention delegate: a workers' representative, elected among staff representatives, not chosen by management.
Designated worker: takes on preventive duties inside the company, which does not mean being present at every risky task.
Preventive resource: appointed by the company doing the work, and their obligation is to be physically present while the activity that triggered it lasts.

What the CAE platform asks for

When the client ticks this requirement they normally expect a small but specific set of documents, and most rejections come from sending only part of it.

The appointment document signed by the company.
A written acceptance signed by the appointed person.
The basic level training certificate, with the relevant number of hours.
Identification of the site or the specific task the appointment covers.
In some cases, evidence of their presence during the works.

How EntraObra can help

The first thing we check is whether you actually need one, because appointments are often made out of habit for work that falls outside every legal case. If it is needed, we review who on your team meets the requirements, prepare the appointment and the acceptance, confirm that the training certificate is the right one and upload it under the correct requirement in your client's platform.

EntraObra provides document management and administrative support. We are not an external prevention service: assessing risks and delivering preventive training are matters for accredited bodies and qualified professionals. The appointment is always made by the company and the acceptance signed by the person named.