The DUERP is not limited to a fixed form that is filled out once a year to satisfy a check. It is a living document whose value directly depends on the granularity of the risk assessment and the rigor with which each version is maintained. Any company employing at least one employee must keep it up to date, but regulatory compliance is only the baseline of the approach.
Retention of the DUERP for forty years: traceability of successive versions
The retention rule applies to all successive versions of the document, not just the current version. Deleting or overwriting an old version means losing the history of the professional risk assessment. In the event of a dispute related to an occupational disease declared years after exposure, it is precisely this history that allows for the reconstruction of working conditions.
In practical terms, each update must be archived with its date and scope. A DUERP updated in 2024 after the addition of a new workshop does not replace that of 2023: it is added to it. We recommend timestamping each version and storing it in a non-modifiable format (signed PDF, for example) to ensure the integrity of the document over time.
The national digital portal provided by law to centralize submissions is not, at this stage, a reliable operational solution. Companies are better off organizing their own internal archiving rather than waiting for a functional institutional tool. To discover the definition of the DUERP and its regulatory foundations, the framework set by Articles L.4121-1 and following of the Labor Code remains the reference.
DUERP and heat episodes: anticipating decisions before the crisis
Preventing extreme heat is not just about distributing water bottles in July. The DUERP allows for formalizing in advance who decides on adaptations (adjustment of schedules, rotation of exposed positions, temporary cessation of activity) and at what threshold these measures are triggered.
The positions concerned are not only outdoor ones. A poorly ventilated warehouse, a collective kitchen, a technical room without air conditioning generate prolonged exposures that many companies underestimate. The assessment of heat-related risks must be included in the DUERP just like chemical risks or fall risks.
Incorporating these scenarios into the single document transforms reaction into anticipation. On the day the temperature exceeds the defined threshold, the safety manager or the nearby manager does not have to improvise: the decision chain is already documented. This protocol, validated in advance with the CSE, protects both employees and the employer in case of inspection or accident.
- Identify in the DUERP each work unit exposed to heat (indoor and outdoor) with the temperature and duration of exposure criteria retained.
- Designate by name the person authorized to trigger adaptation measures, without waiting for a lengthy hierarchical validation.
- Plan graduated actions: enhanced breaks, schedule adjustments, then cessation of activity if the critical threshold is reached.
- Record actual triggers to inform the annual update of the document.
Absence of DUERP and non-updated DUERP: two distinct legal situations
The complete absence of a DUERP and a simply outdated document do not lead to the same consequences. Since June 2026, an administrative fine specifically penalizes the lack of documentation. An existing DUERP that is not updated does not fall under the same regime, even if the employer remains exposed to other legal risks (serious fault, formal notice from the labor inspection).
This distinction has practical implications: a company with a DUERP that is three years old is not in the same position as a company that has never drafted one. The former must plan its update, while the latter is exposed to immediate sanction.
For structures with fewer than fifty employees, the risk assessment process leads to the definition of preventive actions. Beyond this threshold, the PAPRIPACT (annual program for the prevention of professional risks) formalizes actions, their schedule, and their budget. In both cases, the CSE must be consulted during each update.
Structuring the assessment by work units rather than by profession
Breaking down the assessment by job description is the most common reflex, but it masks transversal risks. The work unit groups together homogeneous exposure situations, regardless of the job title. A warehouse worker and an order picker often share the same work unit if their exposures (noise, handling, movement of machinery) are identical.
This breakdown conditions the relevance of the entire document. A unit that is too broad drowns out specific risks, while a unit that is too narrow complicates management without gaining in prevention. The employer has some leeway to define the scope of each unit based on actual exposures.
- Group employees by actual exposure (physical agents, rhythms, environment) rather than by organizational chart.
- Reassess the breakdown with each organizational change: relocation, new process, use of subcontracting.
- Involve the employees themselves in defining work units, as they know the actual exposures better than management.
The DUERP becomes more useful when it stops being seen as a documentary obligation and becomes a management tool. Rigorous archiving, integration of climate risks, and proper breakdown of work units are the three levers that separate a formal document from a true system for preventing professional risks.
