1. The Decree 69/2013: an overall assessment
The Decree-Law of 21 June 2013, n. 69 urgent measures to revive the economy, introduced important provisions of simplification of administrative procedures (Title II) that respond to the recommendation to “simplify the administrative and regulatory framework for citizens and businesses.” They include, among other things, compensation for the delay in concluding the proceedings by public authorities (Article 28), simplifications in the building sector (Article 30). Safety at work (Article 32), the landscape (Article 39) environment (Article 41) and in the management of labor relations (Article 32). Further simplifications are provide d in tax matters, such as the advantages relating to the installment receipts (Article 52).
The measure continues the work undertaken by the Decree-Law 9 February 2012, n. 5 (so-called “Simplify Italy”) and helps to complete the innovative framework outlined in the second decree-development, since these measures concern predominantly businesses, despite being established specific simplifications in particular areas also for citizens.
The new measures are intended to create the framework conditions for economic recovery and the maintenance of Italian companies on the market in the current global economic crisis.
According to estimates by the Department of Public Service – Office for simplification only the reduction of administrative formalities imposed on business in the field of safety at work will significantly reduce a burden estimated at 4.6 billion euros.
2. The measures in the field of health and safety at work
With specific regard to the issue of safety at work, Article 32 of the Decree provides numerous measures of simplification of formalities. Among these we note the rule designed to streamline the documentation relating to compliance with health and safety at work with regard to the single document risk assessment interference (IRAD). In this regard, you are representing that cooperation and coordination between client, contractors and subcontractors, in order to prevent interference risk processing (Article 26 of Legislative Decree no. 81 of 2008), may be implemented, limited to the sectors of activity low risk of accidents, with the identification of a designated person, in possession of the appropriate requirements, to oversee the activities of cooperation and coordination. The identification of sectors with low accident risk is assigned to a decree of the Mi nister of Labour and Social Policy (in consultation with the Minister of Health, after consulting the Standing Consultative Commission for the health and safety at work and after reaching agreement in the Conference State-Regions), based on objective criteria and parameters, derived from the injury rates in the sector INAIL. The type of works or services for which it is required the preparation of DUVRI extends to works or services whose duration is not more than ten men day, meaning men of the work day, the volume of work, services and supplies represented by the sum of working days required to complete the activities considered with reference to the timeframe of one year from the beginning of the work.
There are also rules aimed at avoiding duplication of training and updating, respectively for managers and workers in the service and protection and safety for managers, supervisors, workers and workers’ representatives for safety, providing that in cases where there is no overlap, in whole or in part, between the contents of different courses, which are recognized a training credit for the content and duration of training and the corresponding already paid.
There is, also, that the communication to the supervisory bodies of the information elements relating to new production facilities – now regulated by Article 67 of Legislative Decree no. 81 of 2008 – can be made within the scope of Instances, reports or certificates presented at the one-stop shop for productive activities. The messages are identified by a decree of the Ministers of Labour and Social Policy and the public administration and simplification, after consultation with the State-Regions Conference.
We introduce also provisions for periodic checks of equipment work (Article 71 of Legislative Decree no. 81 of 2008) in order to facilitate the conduct of the same by businesses. In this regard has been reduced from sixty to forty-five days the per iod within which the INAIL is required to carry out the first inspection. It is also no requirement for public entities required inspections – INAIL, ASL, ARPA – to inform the employer, within fifteen days of the request, the possible inability to carry out its checks, in which case the employer may use public or private entity authorized to audit. For the conduct of audits INAIL, the ASL or ARPA can rely on the support of public or private entities authorized. The costs for carrying out the said checks are to be borne by the employer.
then provide a number of simplifications of the obligations on construction sites. In particular, it provides for the exclusion of small works, with a life expectancy is no more than ten men day, aimed at the implementation or maintenance of infrastructure services, the application of the provisions of Legislative Decree no. 81 of 2008 provided for the temporary and mobile sites (Article 88 of the aforementioned decree). It transfers to a decree of the Minister of Labour and Social Policy (in consultation with the Minister for Infrastructure and Transport, after consulting the Advisory Committee and the State-Regions Conference) identification of simplified models for the preparation of certain documents relating to the yards (operational safety plan, safety plan and coordination, edition of the work).
It provides that certain communications relating to health and safety at work can be carried out electronically, including through joint bodies or trade unions of em ployers.
Into It transfers to a decree of the Minister of Labour and Social Policy (in consultation with the Minister for Infrastructure and Transport, after consulting the Advisory Committee and the State-Regions Conference) identification of simplified models for the preparation of the plan safety replacement of the safety plan and coordination of public contracts called Article 131 (paragraph 4).
provide, finally, simplification measures in the field of communications and notifications, concerning, among other things, the reporting of accidents at work by the employer. In particular, is repealed Article 54 of the consolidated text of the decree of the President of the Republic n. 1124 of 1965 which provides for the obligation of the employer to report to the local public security every accident at work which would result in either death or incapacity for work for more than three days, and it modified the ‘Article 56 of the decree, stating that the public security authorities, port authorities and consular direction and territorial labor INAIL acquire, through electronic access, data relating to complaints of workplace injuries and fatal prognosis than those with greater than thirty days. Similarly, the inspection services of the competent labor territorial direction they view the results relating to the complaints of injuries by means of access to the databa se INAIL (paragraph 6).
Before examining the provisions analytical, it should be noted that all measures introduced on the issue of health and safety at work apply only formal requirements (the so-called “bureaucracy of work”), and additional information, but do not touch the fundamental aspects of security, whose effectiveness is indeed strengthened, since the reduction of charges related to administrative formalities will free up resources to ensure the highest good consists of the protection of the health and safety of workers. In summary, “less paper and more security.” In addition, the simplification measures will facilitate businesses in the identification of the essential elements to be indicated in the preparation of documents, making it easier for the proper fulfillment of the obligations of substance (eg. Risk assessment, health surveillance) and facilitating at the same time, the control part of the supervisory bodies and the partici pation of workers and their representatives.
3. Analysis of the simplification measures
In the table below shows, in detail, the rules laid down in Article 32 of Decree Law 69/2013 on simplification of the formalities of security
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A) Risks arising from interference in the workings
Article 32, paragraph 1, lett. a) provides that the obligation to prepare the “single document for the evaluation of interference” (IRAD) can be replaced by the identification, paid by the principal employer, a manager who will oversee and vigilant on the activities subcontracted or outsourced to self-employed and that this assignment is given out in the contract or works. Is set at “10 man-days” (instead of the previous “two days”) the extent to which waived the obligation of preparing the DUVRI, provided that it is not exposed to risks arising from the presence of carcinogens, biological or explosive atmospheres.
Article 26 of Legislative Decree 81/08, paragraphs 3:03-bis shall be replaced by the following:
“3. The employer must promote cooperation and coordination referred to in paragraph 2 by preparing a single document for the risk assessment to indicate the steps taken to eliminate or, where that is not possible, to minimize the risk of interference or identifying, limited to the sectors of activity at low risk of accidents referred to in Article 29, paragraph 6-ter, with reference to the principal employer, its own responsibility in possession of training, experience and professional competence, typical of a charge as well as periodic updating and direct knowledge of the work environment, to oversee such cooperation and coordination. In the case of preparation of the document shall be attached to the contract or work and must be adjusted according to the progress of works, services and supplies. Identifying persons in charge of in th e first sentence or of its replacement must be given immediate evidence in the contract or work. The provisions of this subparagraph shall not apply to the specific risks to the activity of the contractors or self-employed individuals. Within the scope of the code referred to in Legislative Decree 12 April 2006, no. 163, this document has been prepared, for award of the contract, by the person who holds the power of decision-making and spending on the management of specific contract.
3-bis. Notwithstanding the provisions of paragraphs 1 and 2, the obligation referred to in paragraph 3 shall not apply to the services of an intellectual nature, the mere supply of materials or equipment, works or services, the duration of which does not exceed ten men -day, as long as they do not involve risks arising from the presence of carcinogens, biological, explosive atmospheres or by the presence of the special risks referred to in Annex XI. For the purposes of this subparagraph, for man-days means the volume of work of the works, services and supplies represented by the sum of working days needed for execution of the works, services or supplies considered with reference to the timeframe of one year from ‘start of work. ».
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B) Risk assessment for activities with a low index of accidents
Article 32, paragraph 1, lett. b) refer the matter to a special decree of the Ministry of Labour (to be adopted within 60 days of the entry into force of the law of conversion) the identification of sectors with low injury rate – to be identified on the basis of objective criteria and parameters, obtained by injury rates in the sector INAIL – for which employers can attest to have carried out risk assessment on the basis of a simplified model attached to the future decree.
On this point it should be noted the rationale underlying the important legislation simplification introduced by the decree.
In fact, despite the recent processes of review of the rules of health and safety at the workplace have made both public and private, in recent years, important advances and elements of significant improvement, the current legisla tion preventional is still characterized by deep dysfunction and the absence of aspects of rationality and equilibrium in the overall system of prevention of occupational risks. And ‘in fact still widespread orientation to adopt, as a benchmark, a reality essentially focused on the model of “industrial enterprise”, not always taking into account the specificity and diversity of companies in different sectors, regardless of size, as well as the SMEs are characterized by a lower incidence of the risk of accidents who encounter difficulties in fulfilling their obligations under legislation objectively designed for large enterprises and high specific risks.
It is a clear demonstration of the current configuration ‘ articulation adempimentale, still paced in relation to the number of workers in the company and not, instead, to the specific risk of economic activity.
Just think, just to give you three examples, a professional firm with two par tners, to commercial operation of a simple retail with only one employee, an office with 100 employees working at the desk.
Well in all three of these cases, the general safety requirements will be the same manufacturing industry!
The current legislation on safety at work is in fact applicable whenever there is an employer, public or private, and at least one worker as defined by art. 2 of Legislative Decree 81/08.
To this end will recognize the type of contractual relationship between employer and employee, nor the presence or absence of a payment or the type of the same. In fact, workers are considered and the subjects that are in the company only to learn a trade, an art or a profession. The worker is then equated: the working member of a cooperative society or a society, even de facto, who lends his activities on behalf of the company and the entity itself, the associate member, the beneficiary of the initiatives of job training and orientation promo ted in order to achieve moments of alternation between study and work or to facilitate career choices through direct knowledge of the world of work, the student of educational institutions and universities, and the participant to professional training courses in which work is done laboratories, work equipment in general, chemical, physical and biological agents, including equipment provided with display screens limited to periods in which the student is actually applied to the equipment or laboratories concerned, the volunteer, etc. ..
The result is that the employer makes use of only one of these subjects, while not having to employ more staff and whilst not dangerous activities must fulfill all the requirements of general security faced by a large industry and, in particular, should evaluate the business risks and draw up the document, appoint the workers in charge of emergency management firefighting and first aid, appoint the RSPP, the physician in charge, where t he specific activity so requires, and the names to workers; provide personal protective equipment to workers; train firefighters, the first responders, form itself (if you carry out directly the duties of RSPP).
Such legislation preventional pose – as well as being deeply unfair – distorts competition between firms without adding anything in terms of raising the protections.
The solution chosen by the legislature moves in order to reorganize and reorient the overall levels of protection, associating each economic activity specific safety standards sized in relation to the risk of accidents peculiar to that activity. In this direction, the decree provided for companies operating in the sectors of activity at low risk of accidents, precisely because of the danger of the activities observed Limited, certify that you have carried out the risk assessment on the basis of a simplified model.
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Article 29 of Legislative Decree 81/08:
1) in paragraphs 5 and 6 are preceded by the following words: ” Notwithstanding the provisions of paragraph 6-ter, ‘;
2) after paragraph 6-bis of Legislative Decree 81/08, the following is inserted:
“6-ter. By decree of the Minister of Labour and Social Policy, to be taken after consulting the Standing Consultative Commission for the health and safety at work and after reaching agreement in the Permanent Conference for relations between the State, the regions and the autonomous provinces of Trento and Bolzano, are identified sectors with low accident risk, based on objective criteria and parameters, derived from the injury rates in the sector INAIL. The decree referred to in the first period, shall be attached with the model which, without prejudice to its obligations, employers of companies operating in the sectors of activity at low risk of accid ents can attest to having carried out the risk assessment referred to in Articles 17, 28 and 29. Retains the right of companies to use standardized procedures required by paragraphs 5 and 6 dell’articolo26.
6-quater. Until the date of entry into force of the decree referred to in paragraph 6-ter for the companies referred to in that paragraph is the provisions of paragraphs 5, 6 and 6A. ‘
C) Training and refresher courses for RSPP and ASPP
Article 32, paragraph 1, lett. c) is expected, in the case of training and refresher courses for managers and employees in the service of prevention and protection, recognition of educational credit in cases of overlap, in whole or in part of the contents of the training courses corresponding to those already paid.
Article 32 of Legislative Decree 81/08, after paragraph 5, the following is inserted:
“5-bis . In all cases, training and updating, under this decree, in which the contents of the training courses overlap, in whole or in part, as those set for the manager and workers in the prevention and protection service is recognized for training credit the duration and content of training and corresponding disbursed. ».
D) Training and refresher courses for workers, managers , supervisors and representatives of workers’ safety
Similarly to the letter above, Article 32, paragraph 1, lett. d) is provided on Recognition of credits on training already delivered, duration and content, in order to avoid duplication of the same in the case of carrying out more training in-chief to the same person worker.
Article 37 of Legislative Decree 81/08, after paragraph 14 is added as follows:
“14-bis. In all cases, training and updating, as provided for in this legislative decree for managers, supervisors, workers and workers’ representatives for safety in which the contents of the training courses overlap, in whole or in part, is the recognized training credit for duration and content of training and corresponding disbursed. ».
E) Notifications to the supervisory body
Article 32, paragraph 1, lett. e) provides that the notice to the supervisory bodies of the information elements relating to new production facilities – now regulated by Article 67 of Legislative Decree no. n. 81/2008 – is carried out within the instances, the reports or certificates presented at the one-stop shop for productive activities in the manner provided for in Presidential Decree no. 160 of 2010. The messages are identified by the Minister of Labour and Social Policy and the Minister for Public Administration and simplification, after consulting the Conference for relations between the State, the Regions and Autonomous Provinces, along with the preparation of standard to be used for its communications. The transfer of information between administrations will be ensured through a computerized system, without any further problems for the enterprise. Paragraphs 3, 4, 5 and 6 of article in question stipulate that certain communications relating to health and safety at work can be carried out electronically, including through joint bodies or trade unions of employers, the obvious order to reduce paper-based communications and enable employers to avail themselves of representative bodies that assist in complying with legal obligations.
Article 67 of Decree 81/08 is replaced by the following:
‘Art 67. – (Notifications to the supervisory body responsible for the area). – 1. In the case of construction and construction of buildings or premises to be used in industrial processes, as well as in cases of expansions and renovations of existing ones, this work must be performed in compliance with industry regulations and must be notified to the supervisory responsible for the area the following information:
a) description of the main ways of working and execution of the same;
b) a description of the characteristics of the premises and facilities.
2. The employer shall provide the notice referred to in paragraph 1 within the instances, the reports or certificates presented at the one-stop shop for productive activities with the rules laid down in the rules of the Decree of the President of the Republic 7 September 2010, n . 160. W ithin ninety days from the date of entry into force of this provision, by decree of the Minister of Labour and Social Policy and the Minister for Public Administration and simplification, after consultation with the Permanent Conference for relations between the State, the regions and the provinces provinces of Trento and Bolzano are identified according to criteria of simplicity and comprehensibility of the information to be transmitted and are approved standard forms to be used for the purposes referred to in this Article.
3. Authorities who receive the submissions referred to in paragraph 1 shall transmit electronically to the supervisory body responsible for the area the information received in the manner indicated in paragraph 2.
4. The reporting obligation referred to in paragraph 1 shall apply to workplaces where it is expected the presence of more than three workers.
5. Until the date of entry into force of the decree referred to in paragraph 2 a pply the provisions referred to in paragraph 1. “.
F) Periodic inspections of work equipment
The procedure of periodic inspections of work equipment referred to in Article 71, paragraphs 11-13 of the Legislative Decree n. 81 of 2008 is extremely complex and does not facilitate businesses in the fulfillment of an obligation that is in their interest to comply, and anticipate as much as possible, with a view to the correct and timely use of the equipment to be tested. The main problems lie in the times and high costs under the current rules.
Article 32, paragraph 1, lett. f) equates public and private entities enabled, eliminating unnecessary steps and expensive today and provided that, in any case, to have recourse to allow private entities enabled but only at the end of the path.
The above equation also responds to ‘ need expressed by the Italian Competition Authority and the European Commission to avoid monopolistic situations, such as that provided for by paragraph 11 of Art. 71 of Legislative Decree 81/2008 in favor of public control.
In detail, the article reduces from 60 to 45 days the period within which the Inail must undertake the first periodic verification of the equipment at the request of employer working. A requirement is added to the supervisory bodies (Inail, ASL, Harp) notify us within 15 days of the request of the checks after its inability to conduct such inspections, allowing the employer to turn to private entities enabled.
Article 71, paragraphs 11 and 12 are replaced by the following:
“11. In addition to the provisions of paragraph 8, the employer submits the work equipment listed in Annex VII to periodic audits to gauge the actual state of conservation and efficiency for security purposes, the frequency indicated in that Annex. The first such review is carried out by INAIL that will be done within forty-five days of the request, passed fruitlessly which the employer can make use of ASL or, where this is provided by a regional law, the regional agency for the protection environmental (ARPA), or to public or private entities authorized in the manner referred to in paragraph 13. Further tests are carried out by ASL or, where this is provided by a regional law, by ARPA, which will provide within thirty days of the request, passed fruitlessly which the employer may use public or private entities authorized in accordance with the rules referred to in p aragraph 13. The INAIL, the ASL or ARPA have an obligation to inform the employer, within fifteen days of the request, the possible inability to carry out its checks and provide sufficient motivation. In this case, the employer may use public or private entity authorized to audit in the manner referred to in paragraph 13. For the conduct of audits, INAIL, the SLA and the ARPA can rely on the support of public or private entities authorized. The checks referred to in this paragraph are onerous and the costs for their execution are borne by the employer.
12. Private entities authorized pursuant to subsection 11 acquire the qualification of civil servants and public reporting directly to the structure holding the function. ».
G) Simplification of construction sites
Article 32, paragraph 1, lett. g) and h) are excluded the application of the rules laid down in Title II (temporary or mobile) of Legislative Decree 81/08. the small jobs lasting less than 10 days and men are finalized the construction or maintenance of infrastructure services
simplifications are introduced for the preparation and coordination of the security plan for temporary and mobile construction sites.
‘Art 104-bis. – (Simplification measures in temporary and furniture). – 1. By decree of the Minister of Labour and Social Policy, in consultation with the Minister for Infrastructure and Transport, to be taken after consultation with the Standing Consultative Commission for the health and safety at work and the Permanent Conference for relations between the state, regions and the autonomous provinces of Trento and Bolzano, simplified models are identified for the preparation of operational safety plan referred to in Article 89, paragraph 1, letter h) of the safety plan and the coordination referred to in Article 100, paragraph 1, and the work of the dossier referred to in Article 91, paragraph 1, letter b), subject to its obligations. “.
H) Communications to the supervisory body
Article 32, paragraph 1, lett. i), l), m) and n), it is stated that in cases involving exposures to chemical hazards, carcinogens, physical or biological, communications can be carried out electronically, including by joint bodies or trade unions of employers job.
Article 225, paragraph 8, of Legislative Decree 81/08 is added at the end the following sentence: “The communication can be carried out electronically, including through joint bodies or organizations trade union of employers. ‘
Article 240, paragraph 3, of Legislative Decree 81/08 is added at the end, the following sentence: “The communication can be carried out electronically, including through joint bodies or trade unions of employers. ‘
Article 250, paragraph 1, of Legislative Decree 81/08 added at the end the following sentence: “Such notification may be made electronically, including through joint bodies or trade unions of employers. ‘
In Article 277, paragraph 2, of D . Decree 81/08 is added at the end the following sentence: “The communication can be carried out electronically, including through joint bodies or trade unions of employers.».
I) Terms for the adoption of the decrees
Paragraph 2 of Article 32 provides that the decrees for the identification of activities low risk and for the adoption of a simplified model of the operational safety at construction sites are respectively issued within 90 days and within 60 days of the entry into force of the measure.
L) Contracts for public procurement, services and supplies
paragraphs 4 and 5 of Article 32 devolved to a special inter-ministerial decree, to be issued within 60 days of entry into force of the measure, the definition of simplified models for the preparation of security plans replacement of security plans and coordination.
M) Complaints of accidents
Article 32, paragraphs 6 and 7 are introduced changes to the DPR June 30, 1965 n. 1124 (consolidated text of the provisions of compulsory insurance against accidents at work and occupational diseases), by repealing Article 54 and placing in the following paragraphs that the local public security authorities, port or consular posts and provincial directorates of labor acquire electronically from ‘ Workers’ compensation data relating to complaints of injuries. These arrangements will come into force with effect from the one hundred and eightieth day after the date of entry into force of the decree constituting the SINP (National Prevention Information System) referred to in paragraph 4 of art. 8 of Legislative Decree 81/08..
a) Article 54 shall be repealed with effect from the one hundred and eightieth day after the date of entry into force of the decree referred to in Article 8, paragraph 4, of Legislative Decree 9 April 2008 , n. 81;
b) in Article 56:
1) the first subparagraph is replaced by the following:
“The public security authorities, local health authorities, port authorities and consular agencies regional offices of the work and the corresponding offices of the Sicilian Region and the autonomous provinces of Trento and Bolzano competent to acquire territory by INAIL, through electronic access, data relating to complaints of workplace injuries and fatal prognosis than those with more than thirty days . ‘
2) the second paragraph, the introductory phrase is replaced by the following: “In the shortest time possible, and in any case with in four days of taking the vision by INAIL access to the database, the data relating to reports of injuries in the first subparagraph, the direction of the work area – field inspection of the work shall, at the request of the injured worker, or of a survivor allowance, an investigation in order to ascertain: ‘;
3) after the fourth paragraph the following is added:
“To the obligations referred to in this article we will arrange with human resources, equipment and financial resources available under current legislation, no new or increased burdens on the public finances.” .
B) The communication mode of the provisions referred to in paragraph 6 apply as from one hundred and eightieth day after the date of entry into force of the decree referred to in Article 8, paragraph 4, of Legislative Decree 9 April 2008 , n. 81, as amended, which defines the technical requirements for the construction and operation.
N) Simplification measures for performance short employment spells)
Article 35, finally, provides that the decree of the Minister of Labour and Social Policy, in consultation with the Minister of Health, after consulting the Standing Consultative Commission for the health and safety at work and the State-Regions Conference, measures are taken to simplify the formalities for the information, training and medical surveillance required by legislative decree 9 April 2008, n. 81, in cases where the benefit of the worker presupposes a short-term stay in the workplace (up to fifty working days in the calendar year of reference).
This is to avoid repetition, for reasons only the formal, the obligations already entered into by the same or other employers. Consider, for example, the need to subject the employee to medical examination for each work performance, even a few hours, or that, where applicable, to repeat the same training activities related to similar activity because the employer at which the provider is the performance has changed compared to the previous employer, while in the same sector. Measures similar to those in question have been provided by the “text only” health and safety in Article 3, paragraph 13, although only in relation to agricultural workers (the relative decree, developed taking into account the provisions of a special “joint notice “between the social partners, is being finalized).
Article 3 of the legislative decree 9 April 2008, no. 81 is added at the end the following paragraph:
“13-bis. By decree of the Minister of Labour and Social Policy and the Minister of Health, adopted pursuant to Article 17, paragraph 3, of the Law of 23 August 1988, n. 400, after consulting the Standing Consultative Commission for the health and safety at work referred to in Article 6 of this Decree and the Permanent Conference for relations between the State, the regions and the autonomous provinces of Trento and Bolzano, while respecting the general protection under the law on health and safety at work and without prejudice to the obligations referred to in Articles 36, 37 and 41 of this Decree, shall be defined simplification measures of compliance relating to information, training and health surveillance provided by this decree apply to benefits that involve a stay of the worker in the company for a period not exceedi ng fifty working days in the calendar year of reference, in order to take into account, by means of appropriate certificates, the discharge of obligations by the same or another employer, work against an employee during the calendar year. ».
4. Revaluation of fines and administrative penalties
It is useful to point out, finally, that Article 9, paragraph 2, of the Decree-Law of 28 June 2013, n. 76, entitled “Early on urgent measures for the promotion of employment” has introduced a significant change to paragraph 4-bis, article 306 of legislative decree 9 April 2008, no. 81 concerning the revaluation of fines and administrative penalties applicable for breaches of the provisions on hygiene, health and safety at work. The original legislation provided for the disposal, in fact, that they were re-evaluated every five years in an amount equal to the ISTAT consumer price index for the same period, subject to rounding of decimal digits at the top.
The new paragraph 4-bis , as amended by Decree in question, clarifies that the revaluation takes place to the extent of 9.6% and that the above increases are intended to fund initiatives supervision a s well as prevention and promotion of health and safety at work carried out by the Departments territorial labor. Basically you increase the appreciation of the amount of the fines and allocate the additional amounts to promotional campaigns.
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