A periodic medical examination expires on a different day from an SEP certificate, and UDT qualifications for trucks on yet another. Each of these documents is issued by someone different, each goes into a different folder, and the manager's question is always the same: can this person do this job today? A register of examinations and qualifications should answer that in one place.
Legal basis
- Polish Labour Code (Kodeks pracy), Art. 229 — pre-employment, periodic and follow-up examinations; the employer may not allow anyone to work without a current medical certificate; the referral is issued by the employer.
- Regulation of the Minister of Health and Social Welfare of 30 May 1996 on medical examinations of employees — the scope and frequency of examinations according to the factors present at the workstation, the template referral and certificate.
- Labour Code, Art. 237³ § 1 — prohibition on allowing anyone to work without sufficient knowledge of OHS regulations and rules and without the required qualifications.
- Energy Law Act of 10 April 1997 (Prawo energetyczne) — qualifications for work on energy equipment (qualification certificates, commonly known as SEP).
- Act of 21 December 2000 on technical inspection (ustawa o dozorze technicznym) — authorisation to operate equipment subject to inspection (including industrial lift trucks).
We do not give the validity periods of individual qualifications as a single number, because they depend on the type of document and the date of issue. The register should hold the date from the document, not from memory.
What the register must contain
For each person and each document:
- type (pre-employment/periodic/follow-up examination, qualification certificate, UDT certificate, work-at-height authorisation),
- date of issue and expiry date from the document,
- who issued it (occupational medicine provider, qualification board, UDT),
- scope (e.g. work at height up to 3 m, operating trucks excluding specialised ones),
- link to the workstation — which requirement this document meets,
- a scan of the document or the number and storage location of the original,
- history: who entered it, when, what they changed.
Without the last point, the register is not evidence. It is a note.
Who is responsible
The employer, always. In practice you need one owner of the register (most often the OHS team or HR) and a clear division of tasks: HR enters examinations and contracts, the OHS team enters training and qualifications, and the shift manager only reads and receives notifications. Two owners of the same field is a guaranteed data conflict.
How to keep track of deadlines
- Notification horizon. A periodic examination requires a referral, an appointment with the occupational medicine provider and the employee's time. A reminder 30 days ahead is the minimum; 60 is more convenient.
- Escalation. A reminder to the employee, after a week to the manager, after another week to the OHS team. A deadline that has passed blocks authorisation to work and shows up on the dashboard, not in the archive.
- One review a week. Even with an app: the “expires within 30 days” list reviewed on Monday, with a decision on each item.
What to show during an inspection
The inspector asks about specific people and specific days. Prepare:
- a list of employees with the expiry dates of their examinations and training (filter: department, workstation),
- medical certificates and referrals (scans or originals in personnel files),
- qualification certificates and UDT certificates with their scope,
- evidence of reminders and decisions on deadlines that have passed (why, what was done).
A register from which you can print this in a few minutes shortens the inspection and takes the stress off the department.
Typical mistakes
- expiry date copied from memory, not from the document,
- a qualification without a scope (“has SEP”, but nobody knows up to what voltage),
- an examination assigned to a person but not to a workstation, so a change of workstation shows nothing,
- scans in e-mails instead of in the register,
- no change history, so nobody knows who entered the wrong date.
This is how the ErgoFlow OHS app keeps the register: an employee record with examinations, qualifications and training, workstation requirements, notifications with escalation and a report for inspections. Description of the whole module: OHS at ErgoFlow.
Legal status as of October 2026. This article is for information only and does not replace legal advice or the opinion of an OHS team.
