34 presence of a work organisation that requires operational control over several people, not individual operations per se. The fact that a worker performs a task independently, even in complex contexts or at the customer’s premises, does not automatically make him or her a supervisor, nor does it entail the obligation to formally assign him or her that status. The legislation does not provide for the concept of “supervisor of oneself” and does not link the role of supervisor to the condition of working alone, but rather to the organisational structure of the company and the distribution of responsibilities. MANAGERS For managers, initial training of 12 hours remains unchanged, with a five-yearly refresher course of 6 hours. If the company operates as a contractor, an additional Construction Site Module lasting at least 6 hours is required. EMPLOYERS As mentioned, the most significant change introduced by the State-Regions Agreement of 17 April 2025 concerns employer training, which becomes mandatory for all and has a minimum duration of 16 hours. In addition to this, there is the Construction Sites Module (6 hours) exclusively in cases where the activity falls within the scope of Title IV of Legislative Decree 81/2008, as in the case of contractors. Title IV of Legislative Decree 81/2008 regulates health and safety protection on temporary or mobile construction sites, defining the roles, responsibilities and obligations of all parties involved — from the client to the contractors — in order to prevent risks associated with construction and civil engineering works. If the employer directly performs the duties of RSPP – the Head of the Prevention and Protection Service employer, the mandatory 16-hour training course is supplemented by a common 8-hour RSPP module and a 16-hour Construction Module for companies operating on temporary and mobile construction sites. The employer’s training refresher course is 6 hours every 5 years; if they perform RSPP duties, an 8-hour refresher course is required every five years. There is no provision for independent refresher training for the Construction Site Module (DL) and the Construction Module (Ita: RSPP, ASPP - Prevention and Protection Service Officer); however, if these modules have been attended because they are necessary in relation to the activity carried out, the contents must be included in the five-yearly refresher training for the role, as long as the operating conditions that required attendance remain in place. RSPP AND ASPP For Prevention and Protection Service Managers and Officers (Ita: RSPP and ASPP), the modular structure of the training remains unchanged, divided into modules A, B and C. The new Agreement clarifies the overall frameFORMAZIONE DI GIUSEPPE IOTTI* work and delivery methods. The modules are as follows: • Module A: 28 hours (compulsory); • Module B (common): 48 hours (compulsory); • Module B (specialist): duration varies depending on the production sector; • Module C (RSPP only): 24 hours. Module C for RSPPs does not replace Modules A and B, but is added to them. The specialist Construction Module B (16 hours), which may be of interest to the lift sector, is required only in cases where the activity falls within the scope of Title IV. RLS - WORKERS’ SAFETY REPRESENTATIVE For the Workers’ Safety Representative (Ita: RLS), the State-Regions Agreement of 17 April 2025 does not introduce any changes, confirming the provisions of Legislative Decree 81/2008: initial training of 32 hours and annual refresher training of 4 hours in companies with up to 50 employees and 8 hours in companies with more than 50 employees. On the other hand, Decree Law 159/2025 introduces an important change, explicitly extending the obligation of periodic refresher training to RLS in companies with fewer than 15 employees, in accordance with the principle of proportionality and depending on the level of risk. FIREFIGHTING AND FIRST AID PERSONNEL For firefighting personnel, the level of risk is determined by the fire risk assessment for the company premises. Fire risks on construction sites and at customer premises are managed within the scope of the respective PSC - Safety and Coordination Plan and DUVRI- Single Interference Risk Assessment Document. The training of first aid personnel remains governed by Ministerial Decree 388/2003. The duration of the courses depends on the classification of the company (Group A, B or C), according to current legislation. The lift sector falls within Group A for the purposes of first aid classification, as it is an industrial and plant engineering activity characterised by a significant risk of accidents. This results in the obligation to provide 16-hours of training for first aiders, with a 6-hour refresher course every three years. TRAINING DELIVERY METHODS The Agreement provides for four possible methods: • physical attendance; • synchronous videoconferencing (VCS); • e-learning; • blended learning. For training courses: • VCS is permitted for most courses, but not for those that the Agreement reserves exclusively for attendance (e.g. certain training courses with a strong operational component, such as operators of
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