For companies operating in Italy, the Workers’ Safety Representative, known in Italian as Rappresentante dei Lavoratori per la Sicurezza or RLS, is one of the key figures in the Italian occupational health and safety system. The RLS represents workers in relation to health and safety matters and acts as a formal point of consultation between employees and the employer.

This role is particularly important for foreign companies because it has no exact equivalent in many other jurisdictions. In Italy, employee participation in health and safety is not merely an internal good practice. It is part of the legal architecture established by Legislative Decree No. 81/2008, the main Italian law on occupational health and safety.

In commercial practice, the RLS is often discussed when a company opens a branch, hires employees in Italy, updates its Risk Assessment Document (DVR), starts mandatory safety training, or prepares for inspections. Understanding how the RLS is elected, trained, consulted and communicated to INAIL helps companies avoid common compliance errors.

RLS at a glance

What is the RLS in the Italian safety system?

The RLS is the workers’ representative for health and safety. Under Article 47 of Legislative Decree No. 81/2008, the RLS is established at company, territorial or production-site level. The purpose of the role is to ensure worker participation in prevention and protection activities.

The RLS is not a company consultant and is not the same as the RSPP, the Prevention and Protection Service Manager. The RLS represents workers, while the RSPP supports the employer from a technical and organisational point of view. These two roles should not be confused when designing the company’s safety organisation.

For a foreign company, the RLS should be seen as a mandatory part of the Italian consultation system. The company must involve the RLS in specific matters, provide information and documentation where required, and ensure that the role can be exercised effectively.

When is an RLS required?

Article 47 states that in all companies or production units the Workers’ Safety Representative is elected or designated. The mechanism varies according to the size of the company and the applicable collective bargaining rules.

In companies or production units with up to 15 workers, the RLS is normally elected directly by the workers from among themselves, or may be identified at territorial or sector level. In companies or production units with more than 15 workers, the RLS is elected or designated within workplace union representatives where present, or elected directly by workers if such representatives are not present.

If no company RLS is elected or designated, the functions are normally carried out by the Territorial Workers’ Safety Representative (RLST) or, in specific cases, by the Site Workers’ Safety Representative. This is relevant for companies with small teams in Italy, where employees may not immediately start an internal election process.

How many RLS are required?

Legislative Decree No. 81/2008 also provides minimum numbers. As a general rule, there must be at least one RLS in companies or production units with up to 200 workers, three RLS in companies or production units from 201 to 1,000 workers, and six RLS in companies or production units with more than 1,000 workers. Collective agreements may increase these numbers in larger organisations.

For multinational groups, the key point is that the calculation is not only a global headcount issue. The company must look at the Italian company or production unit and apply the Italian rules to that local organisation. This is why foreign HR or EHS teams should verify the Italian legal structure, number of employees and actual operating sites before defining the RLS process.

Election or designation process

The employer should not simply appoint a person as RLS as if it were an internal management role. The RLS is a workers’ representative and must be elected or designated according to Article 47 and applicable collective agreements.

In practice, the company should make sure that workers are informed of their right to elect or designate an RLS, that the process is documented, and that the final result is recorded. The documentation should normally include evidence of the election or designation, the date, the person selected and the relevant production unit or company scope.

For foreign companies, this is often one of the most underestimated points. A global HR department may assume that an existing employee representative, works council representative or HR contact automatically covers the Italian RLS role. This is not necessarily correct. The Italian RLS has a specific legal function under occupational health and safety law.

Communication of the RLS name to INAIL

Under Article 18, paragraph 1, letter aa) of Legislative Decree No. 81/2008, the employer or the relevant manager must communicate the names of the Workers’ Safety Representatives to INAIL through the telematic procedure. INAIL issued administrative instructions on this obligation, including Circular No. 11 of 12 March 2009 and subsequent clarifications.

In practical terms, the communication is generally required in case of new election or designation, or when the previously communicated name changes. If the RLS already communicated to INAIL has not changed, companies normally do not have to repeat the communication every year.

The deadline traditionally used for this communication is 31 March, referring to the situation as of 31 December of the previous year. The communication is made through the INAIL online service dedicated to the RLS declaration. Companies with multiple production units should verify whether separate communications are needed for each unit.

RLS training requirements

Training is a fundamental element of the RLS role. Article 37 of Legislative Decree No. 81/2008 provides that the RLS must receive specific training adequate to the role. The statutory minimum initial training is 32 hours, including 12 hours on the specific risks present in the company and on prevention and protection measures adopted.

The RLS must also receive periodic updates. Article 37 provides minimum annual update durations of 4 hours for companies with 15 to 50 workers and 8 hours for companies with more than 50 workers, while collective bargaining may regulate further details. For smaller companies, the applicable collective agreement and sector rules should be checked carefully.

The State-Regions Agreement of 17 April 2025 is mainly relevant to the broader system of safety training and to several other figures, such as workers, supervisors, managers and RSPP/ASPP. When planning the training matrix for an Italian company, the RLS training path should therefore be coordinated with the overall mandatory training plan.

Main rights and duties of the RLS

The RLS has consultation, information and participation rights. Article 50 of Legislative Decree No. 81/2008 lists the main powers and responsibilities of the role. These include access to workplaces where work activities are carried out, consultation on the risk assessment, consultation on the appointment of the RSPP, emergency team members and the occupational physician where required, and consultation on the organisation of safety training.

The RLS must also receive information and company documentation relating to risk assessment and prevention measures. This includes access to the Risk Assessment Document according to the conditions set by the law. The RLS may make proposals, promote suitable prevention measures and submit observations during inspections by competent authorities.

At the same time, the RLS is not responsible for replacing the employer, RSPP or supervisor. The RLS does not manage the company’s safety system and does not assume the employer’s legal obligations. The role is one of representation, consultation and active participation.

How the RLS interacts with other safety roles

The Italian safety system is based on interaction between several roles. The employer retains primary responsibility for occupational health and safety. The RSPP supports the employer with technical risk prevention and protection activities. The occupational physician, where required, manages health surveillance. Supervisors oversee day-to-day work activities. The RLS represents workers’ interests in health and safety matters.

The RLS should therefore be involved at key moments: risk assessment, updates to the DVR, introduction of new equipment or processes, organisation of training, emergency planning and consultation on prevention measures. This interaction should be documented where appropriate, especially in companies subject to audits, inspections or client qualification checks.

For foreign companies, a clear internal map of roles is useful. It helps local management, HR, EHS and headquarters understand who does what in Italy and prevents the common mistake of assuming that one global function can automatically replace several legally defined Italian roles.

Common mistakes made by foreign companies

The first common mistake is treating the RLS as an optional role. In Italy, the workers’ representative system is part of the legal safety framework, even where the company is small or the local team is recently established.

A second mistake is appointing the RLS directly from management without respecting the election or designation process. The RLS represents workers and should not be confused with an employer-appointed safety manager.

A third mistake is assuming that an international HSE manager, HR manager or works council member automatically fulfils the RLS function. The Italian RLS has specific legal rights, training requirements and consultation functions.

A fourth mistake is failing to communicate a new or changed RLS to INAIL. This may appear to be a minor administrative issue, but it is a specific obligation under Article 18 and can emerge during inspections or document reviews.

Finally, some companies consult the RLS only formally, without integrating the role into the practical safety management process. This weakens the evidence of compliance and may create difficulties when the company must demonstrate that the prevention system is actually functioning.

Practical checklist for companies

Foreign companies with employees in Italy should verify whether an RLS has been elected or designated, whether the process has been documented, whether the RLS has received the required training, and whether the name has been communicated to INAIL when required.

They should also check whether the RLS is involved in the main safety processes: DVR preparation and updates, training planning, emergency procedures, introduction of new risks, and consultation on prevention measures. These checks are particularly important after corporate changes, new hires, site openings, reorganisations or changes in the applicable collective agreement.

From a business perspective, the RLS process should be integrated into the wider compliance package that is often requested by clients, auditors and public or private procurement procedures.

FAQ

Is the RLS mandatory for every company in Italy?

Yes. Article 47 of Legislative Decree No. 81/2008 provides that a Workers’ Safety Representative is elected or designated in all companies or production units. If no company RLS is elected, the territorial or site representative system may apply.

Can the employer appoint the RLS directly?

No, the RLS is a workers’ representative. The process must follow the election or designation rules set by Italian law and applicable collective agreements.

Can the RLS be the same person as the RSPP?

The roles should not be confused. The RSPP supports the employer from a technical prevention and protection perspective, while the RLS represents workers. In practice, combining these roles is generally not appropriate because they have different functions and interests.

Does the RLS need specific training?

Yes. The RLS must receive specific training. The minimum initial duration is 32 hours, including 12 hours on company-specific risks and prevention measures.

Does the RLS need refresher training?

Yes. Article 37 provides for periodic updates. Minimum annual update durations are 4 hours for companies with 15 to 50 workers and 8 hours for companies with more than 50 workers, with further details potentially regulated by collective agreements.

Do we need to communicate the RLS to INAIL every year?

The communication is required in case of new election or designation, or when the name changes. If the RLS already communicated remains unchanged, the company normally does not repeat the communication annually.

What happens if workers do not elect an RLS?

If no company RLS is elected or designated, the functions are normally carried out by the territorial or site Workers’ Safety Representative according to the applicable system.

Should the RLS receive the Risk Assessment Document?

The RLS has specific rights to information and documentation relating to risk assessment and prevention measures under Article 50. Access to the DVR must be managed according to the conditions set by the law.

Does a foreign parent company’s safety representative cover the Italian RLS role?

Not automatically. A representative appointed under another country’s system does not replace the Italian RLS unless the Italian legal requirements for election, designation, training and consultation are met.

Why is the RLS important for business compliance?

The RLS process is often reviewed during inspections, audits, tenders and client qualification activities. A properly managed RLS helps demonstrate that the company’s Italian safety system is not only documented, but also participatory and operational.

How Frareg can support foreign companies

Frareg supports companies with employees or operating units in Italy in understanding and managing the requirements of Legislative Decree No. 81/2008. This includes the organisation of safety roles, RLS-related procedures, training planning, DVR management and ongoing compliance support.

For international companies, the objective is to make the Italian safety system clear, documented and manageable, while aligning local compliance with group-level HR, EHS and legal processes.