This article follows our previous article on the origin, meaning, and content of the 9 GPP. If you haven’t read it yet, it lays the essential foundations for what follows.
Knowing the 9 General Prevention Principles is a good start. Understanding what they actually do within your organisation — and why neglecting them exposes you to significant human, legal, and financial risks — is what makes the real difference.
The GPP: Known in Form, Misunderstood in Function
The 9 GPP have been enshrined in the French Labour Code since the transposition of the 1989 European Directive. Thirty-five years. And yet, in the majority of companies we support at C2D Prévention, the observation is always the same: the GPP are displayed, cited, and integrated into HSE policies — but rarely applied in their hierarchical order.
It is precisely this order that gives them their full meaning. The GPP are not a checklist. They form a hierarchy of actions, from most to least effective: eliminate the risk at source first, assess what cannot be eliminated, combat the hazard as early as possible, adapt work to the person, account for technical progress — and only as a last resort, train and individually equip workers.
Ignoring this hierarchy means investing in prevention that is costly, fragile, and poorly protective over the long term.
Want to assess where your company stands on this hierarchy?
What They Concretely Produce Within Your Organisation
A Logic of Prevention at Source, Not Repair
The first contribution of the GPP is to shift the dial: from a culture of “fix it after” to a culture of “prevent it before.” As long as a company responds to risks with PPE handed out in a rush, one-off training sessions, or procedures added after each incident, it remains in a reactive mindset — and its accident rate does not structurally decrease.
The GPP invite a more demanding question: does this risk need to exist? And if so, can it be reduced before it reaches the worker? This is a primary prevention posture — the most effective over time, and often the least costly once in place.
A Hierarchy That Protects Better — and Can Be Demonstrated
Collective protection measures (source extraction, guardrails, machine enclosures, redesigned work organisation) protect all workers regardless of their individual behaviour. They remain reliable even under fatigue, inattention, or time pressure.
PPE, on the other hand, depends on actual wearing, correct fit, maintenance, and individual compliance — all human variables that can fail. This is not a criticism of PPE: it is the physiological and psychological reality of human behaviour at work, well documented by neuroscience.
Respecting the GPP hierarchy means building prevention that works even when conditions are degraded — and that is precisely what judges examine in the event of an accident.
A Management Tool, Not an Administrative Formality
The GPP provide a structuring framework to turn the DUER (Single Risk Assessment Document) into a living management tool, integrate prevention into strategic decisions from the design phase, and move beyond reactive incident indicators toward anticipation indicators. Companies that apply the GPP in their hierarchical order are not only more compliant — they steer their prevention with a coherent compass.
Our support modules help embed this logic into your day-to-day management practices.
What Non-Compliance with the GPP Actually Exposes You To
Beyond the obvious human risks, failing to respect the GPP exposes your company legally. Article L. 4121-1 of the French Labour Code requires employers to take the necessary measures to ensure the safety and protect the physical and mental health of workers. In the event of a workplace accident or occupational illness, judges systematically examine whether this hierarchy was respected.
The employer’s inexcusable fault — which significantly increases compensation — can be recognised as soon as it is established that the employer was aware, or should have been aware, of the danger and failed to take the necessary measures. Knowing the GPP without applying them constitutes precisely this level of awareness in the eyes of case law.
Respecting the GPP also means building your legal defence in advance.
Our conferences raise awareness among executives and senior leadership teams about legal obligations and their practical implications.
GPP and Safety Culture: The Missing Link
Formally complying with the GPP is necessary. But it is not enough to create a lasting safety culture — that collective dynamic in which every member of the organisation integrates prevention as a genuine value rather than an external constraint.
Safety culture is built over time, through the continuous infusion of practices consistent with the 9 principles. It requires visible leadership from management and the executive committee, regular prevention rituals embedded in day-to-day field operations, and the ability to learn collectively — not only from accidents that have occurred, but from those that have not yet happened.
Without the GPP Applied | With the GPP Respected |
Repeated accidents despite PPE | Real reduction of exposures at source |
Chronic unexplained absenteeism | Weak signals identified and addressed upstream |
DUER filed away but never consulted | Living assessment, grounded in field reality |
Regulatory compliance endured | Safety culture chosen and sustained |
Exposed criminal liability | Documented evidence of reasonable diligence |
This is precisely where the real difference lies between companies that are overwhelmed by their accident rate and those that master it — and turn it into a lever for collective performance.
Our Safety Day workshops help embed these collective reflexes in a concrete and engaging way.
Key Takeaways
- The GPP form a hierarchy, not a checklist. Their order is their meaning: eliminating the risk always takes precedence over protecting against it.
- Collective protection measures are more reliable than PPE, which depends on human behaviour — inherently variable.
- The DUER is only useful if it is alive, co-constructed with the field, and followed by a real action plan.
- Non-compliance with the GPP exposes the employer to inexcusable fault — knowing the principles without applying them is sufficient to engage liability.
- The GPP are the foundation of a lasting safety culture — but it is their continuous infusion into management practices that keeps them alive.
FAQ
Do the GPP apply to all companies, regardless of size? Yes, without exception. The obligation to respect the 9 General Prevention Principles (Art. L. 4121-2 of the Labour Code) applies to any employer with at least one employee, regardless of company size, sector, or the nature of the risks. A micro-business of 3 people is subject to the same requirements as an industrial group of 10,000 employees.
What is the difference between the GPP and the DUER? The GPP are the legal reference framework that defines how an employer must approach prevention — in what order, with what logic. The DUER (Single Risk Assessment Document) is the operational tool for implementing the 2nd principle (assessing risks that cannot be avoided). The DUER is a distinct regulatory obligation, but it only makes full sense when built in line with the GPP hierarchy.
Can an employer be held liable even if PPE was distributed to all workers? Yes. Case law is consistent on this point: distributing PPE is not sufficient to exempt an employer from liability if a collective protection measure was possible and was not implemented. PPE is the last resort in the GPP hierarchy (principle no. 8), and its exclusive use — without an upstream approach — can constitute inexcusable fault in the event of an accident.
Are psychosocial risks (PSR) covered by the GPP? Absolutely. Article L. 4121-1 of the Labour Code requires employers to protect the physical and mental health of workers. The GPP therefore apply fully to PSR: work overload, role conflict, pathogenic management, isolation… These risks must be assessed in the DUER and be subject to prevention measures following the same hierarchy as physical risks. This is a dimension that is still too often overlooked in the companies we support.
Where should I start to put the GPP into real practice? The first step is an honest assessment: where does your company actually stand in the application of the GPP hierarchy? Which risks are addressed at source, and which are merely “covered” by PPE or training? At C2D Prévention, we offer a structured assessment that identifies gaps and defines a prioritised action plan — concrete, realistic, and tailored to your context.
Ready to Make the GPP a Real Lever for Your Business?
Our consultants support you over time, using the CAP® Method, so that prevention becomes a continuous infusion into your company culture — not an annual compliance exercise.
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Sources
Direction générale du travail. Code du travail, art. L. 4121-1 et L. 4121-2. Legifrance.
European Directive 89/391/EEC of 12 June 1989.
INRS. (2025). Évaluation des risques professionnels. https://www.inrs.fr
Eurogip. (2026). France: point sur la sinistralité en 2024. https://eurogip.fr
ICSI. (2023). Une meilleure prise en compte des facteurs humains et organisationnels. https://www.icsi-eu.org
