This article explains the main technical health and safety requirements that companies must manage under Italian Legislative Decree No. 81/2008, with a practical focus on the Risk Assessment Document (DVR), the Prevention and Protection Service (SPP), the RSPP and the documentation that is usually reviewed during audits, inspections and commercial compliance checks.

Why technical compliance matters for foreign companies in Italy

Foreign companies operating in Italy often start from the assumption that occupational health and safety compliance is mainly a matter of training and medical examinations. These are essential components, but they are not sufficient on their own. The Italian occupational health and safety system is built around a technical and organisational framework that must be designed, documented, implemented and kept up to date.

For this reason, after the general overview of Legislative Decree No. 81/2008, mandatory training and occupational health surveillance, the next step is understanding the technical requirements that support the entire prevention system. These include the risk assessment process, the DVR, the appointment of the RSPP, the organisation of the Prevention and Protection Service and the maintenance of coherent safety documentation.

For international groups, this is particularly important because a global HSE policy, a corporate risk matrix or a foreign safety management procedure does not automatically replace the Italian documents and appointments required by law. Local compliance must be aligned with Italian legislation and with the actual activities carried out in Italy.

The central role of risk assessment under Legislative Decree 81/2008

The cornerstone of Italian workplace safety compliance is the assessment of all risks to workers’ health and safety. Under Article 17 of Legislative Decree No. 81/2008, the employer cannot delegate the assessment of risks and the consequent preparation of the Risk Assessment Document, commonly known in Italian as DVR, Documento di Valutazione dei Rischi.

This is a key point for foreign companies: even when external consultants, group HSE departments or local managers support the process, the legal responsibility for ensuring that the risk assessment is carried out remains with the employer as defined by Italian law.

The assessment must consider all risks connected with the specific workplace, tasks, equipment, substances, organisational arrangements and categories of workers. It is not a generic document. It must reflect the company’s real operating conditions in Italy.

What the DVR is and what it must contain

The DVR is the formal document prepared following the risk assessment. It describes the risks present in the workplace and the prevention and protection measures adopted or planned by the company.

According to Article 28 of Legislative Decree No. 81/2008, the DVR must include a report on the assessment of all risks, the criteria used for the assessment, the prevention and protection measures adopted, the programme of measures considered necessary to improve safety over time, the procedures for implementing those measures and the roles responsible for doing so.

The DVR must also identify the job roles that expose workers to specific risks requiring recognised professional skills, experience or training. This means that the document is not only an assessment tool, but also a management tool that connects risk evaluation, training, health surveillance, work procedures and organisational responsibilities.

In practice, the DVR should allow a company to answer a simple question: what risks exist in the Italian workplace, how are they controlled, who is responsible for each measure and what still needs to be improved?

When the DVR must be prepared and updated

The DVR must be prepared at the start of the company’s activities involving workers in Italy and must be kept up to date over time. It is not a one-off document to be filed and forgotten.

Article 29 of Legislative Decree No. 81/2008 requires the risk assessment to be reviewed when there are significant changes in the production process or work organisation, when they may affect workers’ health and safety, following work-related accidents or significant results from health surveillance, and whenever prevention measures need to be updated due to technical or organisational developments.

Typical situations requiring a review include the opening of a new office, warehouse or production site, the introduction of new machinery, changes in tasks or working methods, the use of new chemical substances, relevant changes in headcount, new shifts, new contractors or the introduction of remote or hybrid work arrangements where applicable.

The RSPP and the Prevention and Protection Service

Another non-delegable duty of the employer under Article 17 of Legislative Decree No. 81/2008 is the appointment of the RSPP, Responsabile del Servizio di Prevenzione e Protezione. In English, this role is usually translated as Prevention and Protection Service Manager or Health and Safety Prevention and Protection Manager.

The RSPP is the person designated to coordinate the technical prevention and protection activities within the company. The RSPP supports the employer in identifying risk factors, assessing risks, proposing prevention and protection measures, developing safety procedures and identifying training needs.

Depending on the company’s size, sector and risk profile, the RSPP may be internal or external. In certain cases provided by law, the employer may directly perform the role of RSPP, provided that the required conditions and training requirements are met. The detailed training framework for RSPP and ASPP is regulated by the State-Regions Agreement of 17 April 2025, Rep. Acts No. 59/CSR, which defines the duration and minimum content of health and safety training courses under Article 37 of Legislative Decree No. 81/2008.

DVR, RSPP and Occupational Physician: how they connect

Foreign companies sometimes treat the DVR, the RSPP and the Occupational Physician as separate compliance items. In reality, they are closely connected.

The RSPP contributes to the technical assessment of risks and supports the employer in preparing and updating the DVR. The Occupational Physician, where health surveillance is required, contributes to the assessment of risks relevant to workers’ health and defines the health surveillance protocol. The Workers’ Safety Representative, RLS, must be consulted as part of the prevention system.

This integrated approach is essential because the DVR should be consistent with the training plan, health surveillance, personal protective equipment, emergency arrangements and operating procedures. If these elements do not match, the company may appear formally organised but technically inconsistent during an audit or inspection.

Main technical documents companies should keep under control

The exact documentation depends on the company’s activities, risks and organisational structure. However, foreign companies operating in Italy should normally verify the following documentation areas:

1. Risk Assessment Document (DVR), prepared and updated according to Articles 28 and 29 of Legislative Decree No. 81/2008. 2. Appointment of the RSPP and, where applicable, ASPP. 3. Appointment of the Occupational Physician where health surveillance is required. 4. Training records for workers, supervisors, managers, RSPP, emergency teams and other relevant roles. 5. Health surveillance records and medical fitness judgements where applicable. 6. Emergency plan and appointments of first aid and fire safety personnel. 7. Records relating to work equipment, maintenance and checks. 8. PPE assignment and information records where relevant. 9. Contractor management documents, including DUVRI where required under Article 26. 10. Minutes of the periodic safety meeting where required under Article 35.

For commercial and audit purposes, this documentation should be traceable, coherent and easily retrievable. Many companies only discover gaps when a client requests evidence, during an internal audit or after an inspection by the competent authorities.

DUVRI and contractor management

When a company entrusts works, services or supplies to contractors within its workplace or production cycle, Article 26 of Legislative Decree No. 81/2008 may require specific cooperation and coordination measures. In many cases, this includes the preparation of the DUVRI, Documento Unico di Valutazione dei Rischi da Interferenze, which addresses interference risks between the client company and contractors.

This is particularly relevant for foreign companies that use external providers for maintenance, cleaning, logistics, installation, technical services or facility management in Italy. The presence of a supplier does not automatically transfer safety obligations away from the client company. The employer must verify technical and professional suitability where required, provide relevant information and coordinate prevention measures.

Common mistakes made by foreign companies

One common mistake is assuming that a global HSE document is sufficient for the Italian legal system. Corporate policies are useful, but they do not replace the DVR required by Italian law.

A second mistake is appointing a generic safety contact without verifying whether that person meets the requirements to act as RSPP under Italian rules.

A third mistake is preparing the DVR only after employees have already started working in Italy or after a client requests compliance evidence. The risk assessment should be in place before work activities are started.

A fourth mistake is failing to update the DVR after operational changes, such as new premises, new tasks, new equipment or new contractors.

Finally, many companies manage training, medical surveillance and technical documentation separately. Under the Italian system these elements must be coordinated, because they all originate from the risk assessment.

How Frareg can support companies

Frareg supports companies in understanding, implementing and maintaining the technical requirements of the Italian occupational health and safety system. This includes risk assessment, DVR preparation or review, RSPP support, safety documentation checks, coordination with the Occupational Physician, training planning and assistance during audits or client compliance requests.

For foreign companies, the objective is not only to create documents, but to build a clear and usable compliance framework that can be understood by local teams, headquarters and external stakeholders.

Quick overview: key technical obligations

FAQ

Is the DVR mandatory for every company with employees in Italy?

Yes. The employer must assess all risks and prepare the DVR when workers are employed in Italy, except for very limited cases governed by specific rules. The obligation is one of the central duties of the Italian safety system.

Can a foreign group risk assessment replace the Italian DVR?

No. A group-level assessment can support the process, but the Italian DVR must reflect the actual workplaces, tasks, risks and legal requirements applicable in Italy.

Can the employer delegate the DVR to a consultant?

The employer can receive technical support, but the risk assessment and preparation of the DVR are non-delegable duties under Article 17 of Legislative Decree No. 81/2008.

Is the RSPP always required?

Yes. The employer must designate the RSPP. The role may be internal or external, depending on the organisation and legal conditions.

Can the employer act as RSPP?

In specific cases allowed by law, the employer may directly perform the RSPP role if the required conditions and training requirements are met.

When should the DVR be updated?

The DVR should be reviewed whenever significant organisational, technical or production changes occur, after relevant accidents, when health surveillance results indicate the need for review, or when prevention measures need to be updated.

What is the difference between DVR and DUVRI?

The DVR assesses the company’s own risks. The DUVRI focuses on interference risks arising from the presence of contractors or external service providers in the workplace, where required by Article 26.

Are technical documents useful during commercial negotiations?

Yes. International clients often request evidence of Italian safety compliance before signing contracts, authorising access to sites or approving supplier qualification.