HSE Professional Guide · Construction H&S Coordination · Issue 8
The Health & Safety Plan in International Perspective: Where Does Hungary Stand, and What's Missing for the Next Step?
Introduction
The previous issue, Issue 7, looked at the client's statutory role and the coordinator's independent, legally grounded authority. This issue continues that same thread through a single, concrete document: what does the Health & Safety Plan (H&S Plan) — required under EU Directive 92/57/EEC and known in Hungary as the Biztonsági és Egészségvédelmi Terv (BET) — actually reveal about how seriously a construction project takes safety coordination?
The H&S Plan is not a paperwork formality. Compared against the practice of five other countries, it becomes clear that where this document is treated as a genuine management tool, it also serves as real legal protection for the client. Where it is treated as paperwork for its own sake — and Hungarian practice, unfortunately, often falls into this category — it protects neither the workers on site nor the client's liability position.
⛔ A note on tone
This article is deliberately critical in tone. Not because Hungarian regulation is bad, but because the gap between the legal text and everyday practice has persisted for two decades now — and this is a conversation the profession itself should be having, not only the regulator or the legislator.
1 · The International Framework – A Brief Overview
Table 1: Comparison of regulatory models across six countries
| Country | Document | Legal basis | Defining feature |
|---|---|---|---|
| United Kingdom | Construction Phase Plan (CPP) | CDM 2015, Regulation 12 | Mandatory for every project regardless of size; the regulator treats it as a "live management tool." |
| Germany | SiGe-Plan | Baustellenverordnung §3; RAB 31 | Five core content pillars: work processes, shared equipment, scheduling, measures, allocation of responsibility. |
| Austria | SiGe-Plan | BauKG §7 | Content broadly similar to the German model, in a more compact regulatory structure. |
Sources: CDM 2015 (UK) · Baustellenverordnung / RAB 31 (DE) · BauKG (AT) — HSE Professional Guide, Issue 8, 2026
| Country | Document | Legal basis | Defining feature |
|---|---|---|---|
| Sweden | Arbetsmiljöplan (AMP) | AFS 2023:3 (since 1 Jan 2025) | Written plan required before work begins; client responsible for continuous updates and access. |
| France | PGCSPS | Code du travail R4532-42–55 | Detail scales with the project's risk category (1–3); mandatory adaptation as construction progresses. |
| Hungary | Health & Safety Plan (BET) | Decree 4/2002 SzCsM-EüM §6(2)(b) | A single-sentence, sparse definition; no mandatory template, no explicit "living document" requirement. |
Sources: AFS 2023:3 (SE) · Code du travail (FR) · Decree 4/2002 SzCsM-EüM (HU) — HSE Professional Guide, Issue 8, 2026
One feature is common to all five models: in none of them does the client's liability disappear because a coordinator has been appointed. Swedish law states this explicitly — the byggherre is not released from the responsibilities attached to the Bas-P/Bas-U roles simply by appointing someone to fill them. Under the French system, too, the maître d'ouvrage remains the formal "owner" of the PGCSPS, even though in practice it is almost always drafted by the coordonnateur SPS. This is, word for word, the same logic found in Section 9 of the Hungarian decree: appointing a coordinator does not relieve the client of its own H&S liability.
The French example is instructive for two further reasons. First, the PGCSPS is scaled to the project's risk category (Category 1, 2, or 3, with a simplified version within the latter) — meaning it is not a single, uniformly detailed document, but a scalable system calibrated to risk. Second, French law explicitly requires the plan to be adapted as construction progresses, reinforcing the same "living document" principle found in the UK's CDM 2015.
In other words, the underlying legal principle is identical across all five systems. What differs is the depth of elaboration, and how seriously the market and the regulator take that principle in day-to-day practice.
2 · Where Does Hungarian Practice Fall Short?
2.1 Depth of content
The Hungarian legal basis, Joint Decree 4/2002 (II. 20.) SzCsM-EüM, Section 6(2)(b), defines what the plan must contain in essentially a single sentence: health and safety requirements appropriate to the specific construction site, with particular regard to the high-risk work activities listed in Annex 2.
By comparison:
- Germany's RAB 31 sets out five concrete content pillars,
- the UK's CDM 2015 provides an itemised checklist built on the Schedule 3 risk categories,
- Chapter 11 of Sweden's AFS 2023:3 specifies precisely what the plan must contain, both at the design stage and during construction,
- Article R4532-43 of the French Code du travail lists the mandatory content elements item by item — from risk analysis through site-logistics detail to accident-response procedures — and scales this to the project's size and risk through its category system.
ℹ️ Not flawed, only sparse
Hungarian regulation is therefore not flawed, only sparse. That brevity was understandable in 2002, drafted under time pressure ahead of EU accession. More than twenty years later, however, this is precisely the gap that the market — through professional self-regulation — should have filled. For the most part, it has not.
2.2 The missing "living document" mindset
UK practice explicitly emphasises that the CPP is not a one-off document filed away after signing, but a continuously updated tool used on a daily basis. Swedish law imposes the same requirement on the arbetsmiljöplan.
Hungarian practice, by contrast, typically follows this pattern:
- the H&S Plan is prepared as part of the execution design documentation,
- it is signed once,
- it is filed in a folder or uploaded to the electronic site diary,
- and from that point on — honourable exceptions aside — it is rarely touched again, even when the sequence of work phases changes, a new subcontractor arrives, or the risk profile shifts.
⚠️ The obligation exists, but isn't enforced
This is precisely the gap that Section 7 of the Hungarian decree is meant to close: it is the coordinator's duty to keep the plan aligned with the progress of the works. The legal obligation exists — it simply is not enforced in practice.
2.3 Why isn't high-quality professional work being produced?
Several mutually reinforcing causes are at play:
a) Price competition undermining quality. There is no mandatory fee schedule or industry minimum price for producing an H&S Plan, and clients — particularly on smaller projects — think primarily in terms of price. A carefully developed, project-specific plan takes time to prepare; a generic document filled in from a template can be "produced" in minutes. As long as the market cannot distinguish between the two, quality work does not pay off.
b) A low entry threshold for the coordinator role. Under the decree, a coordinator must hold "occupational safety qualifications and at least an upper-secondary technical or construction-related qualification, plus three years of verified experience." This is a considerably lower bar than, for example, the UK system requires of a Principal Designer, and there is no accompanying, industry-recognised continuing-education or accreditation system to sustain professional standards over time.
c) No professional feedback mechanism. While Germany's RAB 31 provides a concrete template and professional bodies (BG BAU) actively publish guidance, Hungary has no centrally recognised industry template or methodological handbook against which the quality of a completed H&S Plan could be measured. As a result, every coordinator works from their own template — and the quality varies enormously. France filled precisely this gap through professional self-organisation: the coordonnateur SPS community, through the "Livre blanc de la coordination SPS" initiative, jointly developed a standardised PGCSPS template and methodological guide, specifically to harmonise practice and make the documents easier for every stakeholder to interpret. It is a good example of how a gap left by legislation can be closed by the profession itself — provided it is organised enough to do so.
d) A gap in the "simplified notification" regime. For residential construction subject to simplified notification under Government Decree 155/2016, the mandatory components of the execution documentation do not explicitly include the H&S Plan — even though Decree 4/2002 would still require one wherever more than one employer is working on site. In practice, this inconsistency means the H&S Plan is simply omitted on many smaller projects, and neither the designer nor the client perceives this as a gap at all.
2.4 Why isn't it taken seriously?
Behind these causes lies a deeper cultural pattern: in Hungarian construction practice, a large share of H&S documentation is still produced "for the authority," not "for the work." This is fundamentally different from the mindset conveyed by the UK or Swedish systems, where the document's primary audience is the person working on site, and only secondarily the regulator.
Compounding this:
- responsibility-sharing between the parties (client, designer, contractor, coordinator) is often left unclear,
- tight deadlines and price pressure leave little time for proper drafting,
- and an incomplete or purely formal H&S Plan rarely produces any immediate, visible consequence in day-to-day practice — until an accident occurs.
2.5 Why doesn't the authority enforce this more strictly?
Construction consistently appears as a priority sector in the annual inspection plans of Hungary's occupational safety and employment-supervision authority, primarily because of its high accident rates. Inspections, however, typically assess overall H&S compliance (existence of a risk assessment, training records, PPE use, notification obligations), within which the depth and currency of the H&S Plan is just one item among many — not a standalone, itemised audit process comparable to the one the UK's HSE applies to CDM documentation.
ℹ️ An approach issue, not just a resourcing one
This is not necessarily a question of resources, but of approach: Hungarian inspection practice tends to check for existence, not substantive quality and currency. A plan that formally exists but is substantively empty can therefore easily "pass" an inspection.
3 · Good Practice and Bad Practice – Two Composite, Characteristic Scenarios
(The examples below do not refer to any specific project; they represent typical patterns drawn from professional experience.)
⛔ Bad practice
The contractor receives, as part of the execution documentation, a generic three-to-four-page H&S Plan identical across projects, where the "site-specific" section contains boilerplate language ("general occupational safety requirements must be observed during the works"). No one updates the plan during construction, even as a roofing subcontractor joins the project and a previously unplanned work-at-height phase emerges. The coordinator visits the site exactly once during the entire project — at the signing stage.
💡 Good practice
The coordinator is involved as early as the execution-design phase, coordinating with the designer on the sequencing of work phases and potential overlaps. The H&S Plan is project-specific, reflects the site's actual conditions (e.g. an adjacent operating facility, a restricted staging area), and devotes a separate section to every high-risk activity listed in Annex 2. During construction, the coordinator visits the site regularly and documents each visit, updating the plan with every material change — a new subcontractor, a revised schedule — each signed and dated.
The difference is not one of formal legal compliance — on paper, both cases could "pass" a superficial inspection. The difference lies in which document actually protects someone if an accident occurs, and which one later becomes evidence that coordination was merely a formality.
4 · What's Missing From the Market?
Drawing together what the international examples show and what Hungarian practice lacks:
- An industry-standard template or methodological guide that goes beyond the statutory minimum — comparable to Germany's RAB 31 or the PGCSPS template developed by the French professional community. The latter is a particularly good example of how such an initiative need not come from the legislature; it can arise from the profession's own self-organisation.
- A structured, continuously updatable format (potentially digital) — not a static PDF, but a version-controlled document that reflects the project's actual current state.
- A continuing-education and quality-assurance system for coordinators that goes beyond a one-time qualification.
- Market differentiation based on quality — which requires clients (and their legal advisors) to understand that a carefully maintained H&S Plan reduces their own legal exposure; it is not a formal line item.
- A more itemised set of inspection criteria specifically addressing the substantive quality and currency of the H&S Plan, not merely its existence.
5 · Conclusion – Back to the Series' Central Thread
The H&S Plan repeats exactly the pattern the earlier issues of this series described in relation to the coordinator's role and the client's liability: it is the quality of the documentation that actually protects the client — not restricting the coordinator's independence, nor formally ticking a box.
International practice is not relevant because "things are simply better abroad" — it matters because it shows that the same legal principle (the client's liability does not disappear when a coordinator is appointed) can be operated within a far more elaborated, daily-use procedural framework. From here, the question is professional, not legislative: the Hungarian market needs to recognise that a carefully maintained, living H&S Plan is not a cost. It is protection.