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Regulations

Working on French scaffolds: SIPSI, the carte BTP and the R408 standard

A scaffold crew sent to France has to clear two hurdles: the posting formalities, which are checked by the client as well as the inspectorate, and a scaffold regime written into the Labour Code itself. This guide covers both, with the article number for each point.

By Ole Emil Frikstad Urstad · How the numbers are computed ·

Tubesca-Comabi M368 scaffolding around a house of 11.4 × 5.3 m with a gabled roof (eaves 4.5 m, ridge 6 m), drawn by the ScaFix 3D model
ScaFix model of the 11.4 × 5.3 m example house with a Tubesca-Comabi M368 scaffold

What does a foreign scaffolding firm need to work in France?

Before posting, file a SIPSI declaration with the labour inspectorate and name a representative in France (L1262-2-1), and request a carte BTP for each worker (R8293-2). On site, keep the payroll documents of R1263-1, the manufacturer's notice and any calculation (R4323-70), and run the inspections of the order of 21 December 2004.

What has to be done before the crew leaves?

Two filings, and they are separate.

  1. The posting declaration. Under L1262-2-1, an employer posting workers to France sends a declaration, before the posting, to the labour inspectorate where the job starts, and appoints a representative in France to liaise with inspectors for the length of the job. The declaration is made on the SIPSI online service. Filing it does not by itself make the posting lawful.
  2. The carte BTP. L8291-1 gives every worker doing building or public-works jobs for a firm based abroad a professional identity card. Under R8293-2, for each posted worker without a valid card, the employer declares the worker to the association CIBTP France before the posting, after telling the worker that his data will be sent. R8291-1 covers construction, renovation, maintenance and similar work on a building or public-works site and all directly linked ancillary operations, so a scaffold crew on such a site should plan for it.

Since 1 April 2024 the card of a posted worker is valid for five years and active during each posting in France (R8292-3).

Why will the French client ask for your paperwork?

Because the law makes it check. Under L1262-4-1, the client or main contractor must verify before the posting starts that you have filed the declaration and named a representative. If it has not received a copy, it must send its own declaration to the inspectorate within 48 hours of the start. R1263-12 says what it will ask you for: the SIPSI acknowledgement of receipt and a signed statement that you have paid any fines due under the articles it lists. Once it holds both, the client is deemed to have made its checks.

Fortal FORTEC scaffolding around a house of 11.4 × 5.3 m with a gabled roof (eaves 4.5 m, ridge 6 m), drawn by the ScaFix 3D model
The same example house with Fortal FORTEC, another system in the app

Which documents must be kept on site?

R1263-1 requires the employer to keep these at the workplace, or where the representative can reach them, and to show them to the inspectorate without delay:

  • the employment contract, where there is one, showing where the worker was hired;
  • any work permit for a non-EU national;
  • where relevant, proof of a medical examination in the home country;
  • for postings of a month or more, payslips showing gross pay, hours at normal and overtime rates, leave and the applicable sector agreement;
  • for shorter postings, proof that the minimum wage was paid;
  • proof that wages were actually paid;
  • a record of the start, end and length of each worker's daily hours.

For the scaffold itself, R4323-70 adds the manufacturer's notice or the erection plan, and any calculation, kept at the workplace.

Which French words will you meet on the site?

FrenchEnglishWhere it matters
échafaudage de piedbase-supported scaffoldscope of recommendation R 408
montantstandardpart of every bay
lisseledger / railmid rail at half height (R4323-59)
plancherdeckgap to the wall at most 20 cm (R4323-78)
garde-corpsguardrailbetween 1 m and 1.10 m (R4323-59)
plinthetoe board10 to 15 cm (R4323-59)
amarrage / ancragetie / anchorrequired for fixed scaffolds (R4323-74)
notice du fabricantmanufacturer's instructionsmust be with the crew (R4323-70)
note de calculstructural calculationoutside the notice's configurations
personne compétentecompetent persondirects erection (R4323-69)
vérification journalièredaily checkorder of 21 December 2004, article 5
PV de réceptionhandover recordmodel in annex 6 of R 408

Note that French uses lisse for the mid rail and plinthe for the toe board; see guardrail, toe board and wall tie in our glossary.

Is a foreign scaffolding qualification accepted?

R4323-69 names no diploma. It requires erection under the direction of a competent person, by workers with adequate training specific to the job, covering six topics from reading the erection plan to permissible structural loads. The French reference for that training is recommendation R 408, adopted on 10 June 2004, under which the employer issues a certificate of competence (attestation de compétences) that is required to erect, dismantle, alter or operate a base-supported scaffold.

That leaves room for a foreign firm, with one catch. The INRS reference document for the R408 training scheme (version 07, January 2023) requires trainees to know enough French to understand the manufacturer's notice, except for users who only work from the scaffold. The erector course takes at least 3 days (21 hours) and expects six months of scaffold experience, fall-arrest training and a medical fitness opinion. Courses run only at bodies approved by INRS and the Assurance maladie. The scheme sets no validity period; the employer decides when to retrain.

The French vocational route is the CQP Monteur d'échafaudage, a level 3 qualification registered until 29 September 2027.

What does the 2004 inspection order expect on site?

The order of 21 December 2004 puts the duty on the head of each firm whose workers use the scaffold (article 2). A firm that only uses a scaffold erected by others is therefore not off the hook, although several firms using one scaffold in the same configuration need not each repeat the pre-use check. Three moments matter:

  • before first use and before reuse, including after a move, a re-erection, a change of configuration, a weather event that affects safety, or a break in use of at least one month (article 4);
  • every day, a check for visible damage, with corrective measures entered in the safety register (article 5);
  • at least every three months, a thorough examination of the scaffold's condition (article 6).

For the comparison with other countries' intervals, see scaffolding regulations by country.

What happens when edge protection is missing?

French inspectors can act on the spot. L4731-1 lets a labour inspector order the temporary stop of the part of the work concerned when a worker faces serious and imminent danger caused by a lack of protection against falls from height. The Carsat regional insurance funds set each firm's occupational accident and disease contribution rate, which the UCANSS guide calls a power of incentive, and their safety engineers and inspectors advise firms on risk control.

Which French limits differ from home rules?

RuleValueSource
Guardrail height1 m to 1.10 m, with mid railR4323-59
Toe board10 to 15 cmR4323-59
Gap deck to wallat most 20 cm (the Dutch sector checklist allows 15 cm)R4323-78
Safety nets insteadstop a fall of more than 3 mR4323-60
Calculation for every stability measureabove 24 m heightR 408, 5.4.2
Distance between accessesat most 20 m, at least one per facadeR 408, 5.3.2
Re-check after a break in useone month or moreorder of 2004, art. 4
Thorough examinationat least every 3 monthsorder of 2004, art. 6

How ScaFix fits in

ScaFix lays out the lifts, guardrails and access bays of a French facade job on many systems, including Tubesca-Comabi, so you can check the 20 m access spacing and the deck count before the material is ordered; the French calculation and the pre-use inspection stay with a competent person.

Planning information, not structural approval and not legal advice. In France the Labour Code on Légifrance, the order of 21 December 2004 and the manufacturer's notice decide; outside the notice's configurations a competent person prepares a calculation (R4323-70), and the scaffold is inspected before first use (order of 2004, article 4). Check the posting formalities on the French labour ministry's services before each job.

Frequently asked questions

Do I need a carte BTP for posted scaffolders?

Yes, for building and public-works sites: declare each worker without a valid card to CIBTP France before the posting (R8293-2). Since April 2024 the card is valid for five years.

What is SIPSI?

The French online service for the prior posting declaration required by L1262-2-1. Your French client will ask for its acknowledgement of receipt before the job starts.

Is R408 training mandatory for foreign scaffolders?

R4323-69 requires adequate, specific training rather than a named course. R 408 makes an employer-issued certificate of competence the norm, and its training scheme expects enough French to read the manufacturer's notice.

How often must a scaffold be inspected in France?

Before first use and after changes, every day, and thoroughly at least every three months, under the order of 21 December 2004.

What is the guardrail height on French scaffolds?

Between 1 m and 1.10 m, with a mid rail and a toe board of 10 to 15 cm (R4323-59).

Sources

Primary sources used for this article, with the date each was read.