Health and Safety Responsibilities of a Manager in Poland

Health and safety responsibilities of a manager in Poland are a separate set of requirements under the Polish Labour Code — imposed not on the company as a whole, but directly on a specific shift leader, foreman, site manager, or department head. You don’t need the word “manager” in your job title for these duties to apply — what matters is that you actually direct other people’s work, not what it says on your business card.

Who does Article 212 of the Labour Code apply to?

Article 212 of the Polish Labour Code applies to anyone who manages employees or other individuals on a day-to-day basis — regardless of seniority or formal job title. In practice, this covers shift supervisors, foremen, site managers, heads of production departments, and even someone temporarily standing in for a manager. This is a separate category of duties from those placed on the employer as such under Article 207 of the Labour Code, which we cover separately. A manager is responsible for safety at the operational level — where the work actually happens — not for the organisation’s overall OSH policy.

Under Article 212 of the Labour Code, a person managing employees is required to:

1. organise workstations in line with occupational health and safety regulations and principles;
2. ensure personal protective equipment is kept in good working order and used as intended;
3. organise, prepare and carry out work in a way that protects employees against workplace accidents, occupational diseases and other illnesses related to working conditions;
4. ensure the safe and hygienic condition of work premises and technical equipment, as well as the proper functioning and correct use of collective protective measures;
5. enforce employees’ compliance with occupational health and safety regulations and principles;
6. ensure that the recommendations of the physician providing healthcare to employees are carried out.

What this means in practice

Organising workstations isn’t a one-off layout job — it’s an ongoing responsibility to make sure every workstation under a manager’s care meets current regulations, from proper lighting and clear walkways to guarding on moving machine parts.

Personal protective equipment isn’t just issued once at onboarding. A manager has to make sure it’s kept in working order, isn’t out of date, and is actually worn — not sitting in a locker because it “gets in the way.”

Planning work with safety in mind means factoring in risk when scheduling tasks — for example, not running work at height at the same time as work directly underneath the same spot, or separating noisy tasks from ones that require verbal communication.

The condition of premises and collective protective measures covers things like ventilation, machine guarding, railings, and extraction systems — measures that protect everyone at once, and that are easy to overlook if no one is formally accountable for them.

Enforcing the rules is often the hardest part in practice — it means reacting in the moment, not just during an inspection, to a missing hard hat, a bypassed guard, or a shortcut through a hazard zone, even when that means a conflict with a subordinate.

Medical recommendations — if an occupational physician restricts an employee’s ability to perform certain tasks (for example, a lifting-weight limit), it’s the manager assigning the work, not just HR, who has to respect that restriction.

Consequences of failing to meet these duties

What sets Article 212 apart from the employer’s general obligations is direct, personal liability. Under Article 283 of the Labour Code, a person responsible for OSH standards or managing employees who fails to comply with health and safety regulations or principles is liable to a fine — and since 8 July 2026, that fine is significantly higher than before. During an inspection, it’s the Labour Inspectorate (PIP) that determines who actually managed the work at a given location, and it’s that individual — not just the company as a legal entity — who can be issued a penalty notice or referred to court.

In more serious cases, where a breach of OSH regulations puts an employee at direct risk of losing their life or suffering serious harm to health, criminal liability under Article 220 of the Polish Criminal Code can also come into play — independently of the administrative penalties imposed by the Labour Inspectorate.

Preparing your management staff for these duties

Because this liability is personal, not just corporate, it’s worth making sure that anyone who actually manages employees — whether or not it’s written into their contract — completes dedicated OSH training for supervisory staff, rather than just the standard periodic training. A useful complement is an independent OSH audit, which shows where these duties are genuinely being met in practice, and where they exist only on paper.