V&G plan: what must it contain?
A V&G plan (safety and health plan) is the legally required plan for a construction project. It sets out which hazards are present on the construction site and how you control them. The client must make sure it exists, under article 2.28 of the Arbobesluit (Dutch Working Conditions Decree) . In the design phase, it describes the risks of the design. In the execution phase, the contractor develops it into a plan for the construction site.
The V&G plan is therefore a legal duty under the construction rules of the Arbowet (Dutch Working Conditions Act) . It is not a VCA requirement. It does connect to the VGM plan for contractors that VCA** asks for. Below you can read when a V&G plan is mandatory, what the law says it must contain, and what a completed plan looks like.
When is a V&G plan mandatory?
A V&G plan is mandatory for two types of construction work. This is set out in article 2.28, first paragraph, of the Arbobesluit.
| Situation | Legal basis | Example |
|---|---|---|
| The construction work is notifiable: more than 30 working days and more than 20 workers at the same time, or more than 500 person-days | Art. 2.27 and 2.28 Arbobesluit | New build of a school |
| The work involves special hazards listed in Annex II of the European construction site directive 92/57/EEC | Art. 2.28 Arbobesluit | A small sewer job in a deep trench |
Note the second row. Even a job that lasts one week can need a V&G plan if the work involves a special hazard.
Which activities involve special hazards?
Annex II of directive 92/57/EEC lists ten types of work. In short:
| No. | Special hazard |
|---|---|
| 1 | Risk of being buried, sinking into the ground or falling from height |
| 2 | Exposure to dangerous chemical or biological substances |
| 3 | Ionising radiation |
| 4 | Work near high-voltage cables |
| 5 | Risk of drowning |
| 6 | Shafts, underground excavation work and tunnels |
| 7 | Diving with air supply |
| 8 | Work in caissons with compressed air |
| 9 | Work with explosives |
| 10 | Assembling or dismantling heavy prefabricated elements |
What must a V&G plan contain? The legal content
Article 2.28, second paragraph, lists what the V&G plan must contain at least, “depending on the progress of the construction process”. There are seven parts.
| Part (art. 2.28 para. 2) | What do you write down? |
|---|---|
| a. Project details | A description of the structure, the companies on the construction site, and the names of the design phase and execution phase coordinators |
| b. Risk inventory | The specific hazards of this structure, such as asbestos, contaminated soil or water, and hazards from working at the same time or one after another |
| c. Measures | What you do against each hazard in part b |
| d. Agreements | Who carries out each measure and when |
| e. Supervision | How you check that the measures work |
| f. Design choices | Structural, technical and organisational choices for safety, with supporting reports |
| g. Information and instruction | How workers on the construction site are informed |
The law does not prescribe a fixed format. A five-page plan is fine if all parts are included. A thick standard document without project-specific hazards is not.
V&G plan design phase and execution phase: the difference
The Arbobesluit divides the construction process into two phases. The V&G plan grows with the project, from design to execution.
| Design phase | Execution phase | |
|---|---|---|
| Who is responsible? | Client | Executing party (contractor) |
| Who drafts it? | Design phase coordinator (art. 2.30) | Execution phase coordinator updates it (art. 2.31) |
| What does it cover? | Risks that follow from the design and the design choices | Working methods, planning, site layout |
| When is it finished? | Part of the specifications, before work starts on site (art. 2.32) | Ongoing, updated as the work progresses |
An example. In the design phase, the architect chooses prefabricated façade elements instead of brickwork at height. That reduces the risk of falling and is recorded as a design choice in the V&G plan. In the execution phase, the contractor describes how the crane places the elements, where the barrier goes and who prepares the lifting plan.
Are two or more employers, or an employer and self-employed workers, on the construction site? Then the client appoints a design phase coordinator, and the executing party appoints an execution phase coordinator (article 2.29 Arbobesluit).
Example V&G plan execution phase: risk table
The core of every V&G plan is the table of hazards, measures and responsible parties (parts b to e). Below is a fictional example for the renovation of a three-storey office building, with eight weeks of construction time and four companies on site.
| Hazard | Phase | Measure | Who | Supervision |
|---|---|---|---|---|
| Falling from the roof edge when replacing the roof covering | Week 2-4 | Temporary edge protection all around, no work without edge protection | Roofer | Site manager checks daily |
| Asbestos-containing sealant in window frames (from the survey report) | Week 1 | Removal by a certified asbestos removal company before demolition | Asbestos remover | Clearance measurement before demolition starts |
| Falling objects during façade work above the entrance | Week 3-6 | Canopy above the entrance, walking route diverted | Main contractor | Weekly workplace inspection |
| Work at the same time: electrician under scaffolding work | Week 5 | Work separated in time, coordination in the site meeting | Execution coordinator | Planning in the site meeting |
| Lifting installations onto the roof | Week 6 | Lifting plan, fenced lifting area, certified crane operator | Crane hire company | Check of lifting plan before start |
| Dust from grinding concrete | Week 2-7 | Extraction at the source, wet working, FFP3 dust mask as a last measure | All companies | Spot check during inspection |
Note the order in the last row. You tackle a hazard at the source first and use personal protective equipment only as the last measure. This is the occupational hygiene strategy from the Arbowet.
V&G plan and VCA: how do they relate?
VCA does not require a V&G plan, but it does require its own VGM project plan for projects. This is set out in question 5.1 of the VCA checklist 2026/6.1 and applies to VCA** and VCA Petrochemie. In practice, they complement each other.
| V&G plan | VGM project plan (VCA) | |
|---|---|---|
| Legal basis | Law: art. 2.28 Arbobesluit | Certification scheme: VCA question 5.1 |
| Who is responsible? | Client, then the executing party | The VCA-certified contractor itself |
| Scope | The whole structure and all companies on the construction site | The contractor’s own work and that of its subcontractors |
| Environment | Not mandatory | Part of VGM (safety, health and environment) |
As a VCA contractor, you use the client’s V&G plan as input. You take over the hazards that affect your work into your own VGM project plan and into your task risk analyses. In addition, question 3.6 of the VCA checklist requires that your workers are instructed on the client’s rules and the project plan before they start.
What does the VCA auditor check on projects with a V&G plan?
The VCA auditor does not test the V&G plan itself. They check how well your company works with it. Expect these questions during the VCA audit:
- Is there a current VGM project plan, and does it match the client’s V&G plan?
- Were workers and subcontractors instructed before they started, with an attendance list as proof?
- Do workers on the construction site know the main hazards and measures?
- Are workplace inspections carried out on the points in the plan?
Frequently asked questions about the V&G plan
Is a V&G plan mandatory for a renovation?
Yes, if the renovation is notifiable or involves a special hazard from Annex II. A small renovation without those characteristics does not need a V&G plan. The employer must still have a RI&E (risk inventory and evaluation) and work safely.
Who pays for the V&G plan?
The client is responsible for the plan in the design phase. It must form part of the specifications (article 2.32). The costs of updating it in the execution phase usually lie with the executing party, depending on the contract.
What is the difference between a V&G plan and a V&G file?
The V&G plan covers the construction phase. The V&G file (article 2.30, under c) gathers information for later work on the building, such as maintenance or demolition. Think of the location of anchor points on the roof.
More information
- VGM plan for contractors: The VCA project plan with an example
- Task risk analysis (TRA): Working out risks per task
- VCA requirements: The checklist explained
- ISO 45001 for construction: Occupational health and safety management in the construction sector
- Arbobesluit, section 5 Construction process : The legal text