A reader asks: We are currently working on updating our company’s risk analysis; the updated risk analysis will be completed in January next year. As the risk analysis was due to be submitted in September, we would like confirmation from the Labour Inspectorate that we may submit the risk analysis once it has been completed.
Piret Kaljula, working environment consultant at the Labour Inspectorate, responds: Unfortunately, the Labour Inspectorate cannot enter into agreements to change the term, since this would conflict with the laws in force. We draw your attention to the fact that employers have been able to upload their working environment risk analysis to the Labour Inspectorate’s self-service environment since 1 March 2021. The risk analysis had to be uploaded to or prepared in the self-service environment at the latest on 1 September 2021, i.e. employers were given six months to submit their risk analysis. A risk analysis must be submitted by all employers with at least one employee working under an employment contract. Only security authorities are not required to submit a risk analysis.
When risk analysis uploads to the Labour Inspectorate’s self-service environment were first opened, a tool for assessing risks in the working environment was also made available in the self-service environment. The risk assessment tool was created to increase companies’ awareness of the working environment and the related risks and to facilitate the performance of the working environment risk analysis. The system displays to the employer the hazards related to their field of activity and lists typical measures to mitigate these hazards. The main target group is small and medium-sized enterprises. The risk analysis tool can be used by a member of the management board, a working environment specialist appointed by the employer, or another authorised person to map the hazards present in the working environment and, based on the results, to prepare an action plan for addressing the hazards present – for preventing, avoiding, or mitigating them.
Employers can fulfil the obligation to submit a risk analysis in one of two ways: by uploading an existing risk analysis (together with the action plan) or to prepare a risk analysis in the self-service environment. Employers who are, for whatever reason, late in fulfilling the obligation are advised to fulfil it as soon as possible. In your case, you should upload your current risk analysis and then the new version once you have finished making the updates. We have seen many cases where the risk analysis has not been submitted because it is currently being updated. However, since the risk analysis is a document that needs to change whenever the work being performed and the working environment change, it will need to be updated and re-uploaded eventually anyway.
The purpose of the working environment risk analysis is to identify the possible risk factors in the company’s working environment and to assess the risks posed to the health and safety of employees. The obligation to perform a working environment risk analysis has been in force since 1999.
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