PAPRIPACT: Understanding France's Annual Occupational Risk Prevention Programme and Its Lessons for UK Businesses

What UK organisations can learn from France's structured approach to turning risk assessment into action

For UK organisations operating in France, or those looking to adopt international best practice in safety management, understanding the PAPRIPACT is essential. The Programme Annuel de Prévention des Risques Professionnels et d'Amélioration des Conditions de Travail (Annual Programme for the Prevention of Occupational Risks and Improvement of Working Conditions) represents one of the most structured approaches to safety improvement planning in Europe.

Since the French law of 2 August 2021 (Loi n°2021-1018) came into force in March 2022, organisations with 50 or more employees operating in France are legally required to produce a PAPRIPACT. This document goes beyond simply identifying risks; it requires employers to commit to specific prevention measures, allocate resources, set timescales, and demonstrate measurable progress. It transforms risk assessment from a static document into a dynamic driver of continuous improvement.

This guide explains what the PAPRIPACT is, how it works, its relationship with the DUERP (Document Unique d'Évaluation des Risques Professionnels), and what lessons UK businesses can draw from this approach. For international health and safety consultants supporting organisations across multiple jurisdictions, understanding PAPRIPACT requirements is increasingly important.

What Is the PAPRIPACT?

The PAPRIPACT is a formal annual programme that sets out the specific measures an organisation will take to prevent occupational risks and improve working conditions over the coming year. It is a legal requirement in France for all organisations with 50 or more employees.

The PAPRIPACT is built around five key principles:

• A legal obligation for organisations with more than 50 employees
• A direct link to the DUERP (the document that evaluates occupational risks)
• An action plan for improving working conditions and preventing occupational risks over one or more years
• Flexibility in format (there is no prescribed template)
• A strengthened role for the CSE (Comité Social et Économique, the employee representative body)

Required Contents of the PAPRIPACT

French law specifies that the PAPRIPACT must include:

• The health and safety improvement measures to be implemented during the coming year, including the conditions for implementation and the financial cost of each measure
• The resources mobilised by the organisation
• Relevant and verifiable performance indicators to demonstrate achievement of objectives and measure the effectiveness of actions
• The implementation calendar showing when each measure will be completed

The Legal Framework: French Law and the Code du Travail

The PAPRIPACT requirements stem from Loi n°2021-1018 of 2 August 2021, which came into force on 31 March 2022. This law transposed the Accord National Interprofessionnel (ANI) concluded on 10 December 2020 by social partners, with the aim of reforming occupational health in France.

Key provisions of this law include:

• Transformation of SST (Services de Santé au Travail) into SPST (Services de Prévention et Santé au Travail), with enhanced health promotion responsibilities
• Creation of the "passeport de prévention" recording health and safety training completed by employees
• Mandatory PAPRIPACT for organisations with more than 50 employees, with defined required content
• Requirement to retain the DUERP and its updates for 40 years
• Mandatory digital filing of the DUERP on a national portal (from July 2023 for organisations with 150+ employees; from July 2024 for smaller organisations)

The law also strengthens the multi-disciplinary approach to risk assessment. Employers must conduct risk evaluation in collaboration with employees responsible for prevention, members of the CSE, and the occupational health service (SPST) to which they belong.

The Role of the CSE

The CSE (Comité Social et Économique) plays a central role in the PAPRIPACT process. As part of the annual consultation on the organisation's social policy, the PAPRIPACT must be presented to the CSE along with an annual report on health, safety, and working conditions. The CSE can give its opinion on the report and the PAPRIPACT, suggest priority ordering of the proposed actions, and propose additional actions. If certain measures are not implemented, the employer must explain the reasons in an annex to the annual report.

The Relationship Between PAPRIPACT and DUERP

The DUERP and PAPRIPACT are complementary documents that together form the foundation of occupational risk prevention in France. They represent two sides of the same coin.

The DUERP (Document Unique d'Évaluation des Risques Professionnels):

• Records the results of the occupational risk assessment (physical and psychosocial risks)
• Is based on analysis of workplace accident risks, occupational diseases, employee interviews, and working group discussions
• Highlights hazards in workstations or work situations that could affect employee safety
• Is required for all employers from the first employee

The PAPRIPACT:

• Identifies prevention measures to address the risks identified in the DUERP
• Ensures the physical and mental health of employees at work
• Comes downstream of the DUERP, turning assessment into action
• Is required only for organisations with 50 or more employees

For organisations with fewer than 50 employees, the DUERP must include both the risk evaluation and a list of prevention actions; a separate PAPRIPACT is not required.

Why the PAPRIPACT Approach Matters

The PAPRIPACT represents a significant evolution in occupational health and safety management. It moves beyond the traditional approach of risk assessment as a compliance document and instead positions it as the foundation for active, measurable improvement.

The PAPRIPACT drives effective prevention through several mechanisms:

It measures commitment: By requiring specific actions with allocated budgets and timescales, it demonstrates the organisation's genuine commitment to improving working conditions.

It formalises actions: It records the various actions adapted to identified risks: training, physical improvements, collective and individual protective equipment.

It creates accountability: By requiring resources, budgets, and a roadmap, and by obliging the employer to justify any non-implementation of planned actions.

It enables a multi-dimensional approach: Actions can be classified across human, technical, and organisational categories, ensuring comprehensive coverage.

It creates momentum: The continuous cycle of risk evaluation, action development and implementation, effectiveness evaluation, and risk re-evaluation creates ongoing improvement rather than static compliance.

How to Create a PAPRIPACT

While there is no prescribed template for the PAPRIPACT, it typically follows a four-part structure:

Part 1: General provisions and priority prevention areas. This section sets out the overall context, the organisation's safety policy, and identifies the priority areas based on the DUERP findings.

Part 2: Measures and actions for Year N+1. The core of the document, listing specific actions to be implemented in the coming year, with responsibilities, resources, costs, and timescales for each.

Part 3: Longer-term measures and actions. Actions that require more than one year to implement, or that are planned for future years, with indicative timescales.

Part 4: Rejected measures and reasons. Transparency about measures that were considered but not included, with explanations of why they were rejected.

Comparing PAPRIPACT to UK Requirements

The UK does not have a direct equivalent to the PAPRIPACT. While UK law requires risk assessment and action to control risks, it does not mandate a formal annual prevention programme with the structured content requirements of the PAPRIPACT.

Under the Management of Health and Safety at Work Regulations 1999, UK employers must assess risks, implement preventive and protective measures, and review assessments when they are no longer valid. The Health and Safety at Work etc. Act 1974 requires employers to ensure, so far as is reasonably practicable, the health, safety, and welfare of employees. However, neither specifies a formal annual programme with defined content requirements.

Nevertheless, the principles underlying the PAPRIPACT align well with UK good practice. HSG65: Managing for Health and Safety recommends a Plan-Do-Check-Act approach that inherently involves planning improvements, implementing them, checking effectiveness, and acting on the findings. ISO 45001 requires organisations to establish objectives for continual improvement and plan actions to achieve them. Many UK organisations would benefit from adopting a PAPRIPACT-style approach, even where not legally required.

Health and Safety Consultants and Software: Managing PAPRIPACT Digitally

Managing PAPRIPACT compliance, particularly for organisations operating across multiple French sites or combining French and UK operations, benefits significantly from digital tools. Health and safety consultants and software platforms work together to provide integrated approaches to risk assessment, action planning, and progress tracking.

Digital PAPRIPACT management enables:

• Direct linking between DUERP risk assessments and PAPRIPACT actions
• Centralised tracking of action progress across multiple sites
• Automated reporting for CSE consultation and health and safety audits
• Dashboard views of performance indicators and progress against targets
• Document management for storing DUERP and PAPRIPACT as required by law
• Integration with incident reporting and investigation systems

For global health and safety consultants supporting organisations with operations in both France and the UK, software platforms that can accommodate both the formal PAPRIPACT requirements and UK risk assessment approaches provide significant efficiency benefits.

How Arinite Can Help

At Arinite, we are experienced international health and safety consultants who help UK organisations operating in France comply with PAPRIPACT requirements, and help organisations everywhere adopt structured improvement planning approaches. Our team of Chartered (CMIOSH) consultants provides practical, proportionate advice across multiple regulatory frameworks.

Our services include:

• PAPRIPACT development for French operations, meeting all legal requirements
• DUERP risk assessment support aligned with PAPRIPACT action planning
• Health and safety audits covering both UK and French compliance requirements
• Annual improvement programme development for UK operations adopting PAPRIPACT principles
• ISO 45001 implementation including continual improvement requirements
• Support with CSE consultation processes where required
• Guidance for multi-country operations as global health and safety consultants

With experience supporting over 1,500 UK businesses and operations in more than 50 countries, we understand the challenges of managing safety across different regulatory frameworks. Whether you need specific PAPRIPACT compliance support for French operations or want to adopt structured improvement planning across your entire organisation, our approach is practical, proportionate, and focused on driving genuine improvement. We call it "Keeping It Simple."