SERVICES
Worker Monitoring
GPS on Waste Vehicles: When a Union Agreement Is Required and When It Is Not
INL
The National Labour Inspectorate (INL) has intervened following several queries regarding the installation of geolocation systems on vehicles used for the transport of hazardous waste, in the context of the new traceability system and the National Electronic Register for Waste Traceability (RENTRI). In particular, it was asked whether such devices, mandated by special environmental regulations, could be considered work tools and therefore exempt from the safeguards provided for remote worker monitoring. The Inspectorate clarified that the obligation to track vehicle routes, in cases established by special regulations, constitutes a condition for carrying out business activity. In this context, the installation of the GPS system falls outside the rules on remote monitoring, as the organisational or productive reasons typical of the general provision are not required. However, the geolocation system cannot be classified as a tool strictly necessary for the performance of work, which could in principle be carried out even without it. Furthermore, the data collected must be used exclusively for the purposes set out in environmental regulations. Should the company wish to use GPS for additional purposes — organisational, productive, asset protection, or occupational safety — it will be necessary to activate the procedural safeguards provided for remote monitoring.