The Chief Inspector of Labour will publish a Construction Regulations Guide or guidance notes in the second half of 2014.
Meanwhile DOL Construction Health and Safety Manager Pumi Maphaha advised contractors to comply with Regulation 4 regarding Notification of construction work, as follows;
* Complete Annexure 2 in full
* If a similar form is used, include all the information required in Annexure 2
* Contractor and Client must sign Annexure 2
* Email Annexure 2 to the DOL provincial office of the province where the work is carried out.
Construction Heath and Safety Agents have to register with SACPCMP by August 2015. Managers and Officers should be registered by August 2014, despite several grey areas in professionalisation.
SACPCMP responded to a range of queries from contractors at a Sasol conference in June, noting that;
. Applicants upgrading from Candidate, to Officer, to Manager, to Agent levels, have to re-apply, re-submit various documents and essays on work reports, re-write exams or undergo interviews, and pay the relevant fees and annual fees.
. Registration cost for Agents is about R8000, plus ‘exam preparation’ workshops, annual fees and CPD fees, in addition to training costs.
. SACPCMP offers CPD exercises via a contractor.
. Exams include 20 ‘true or false’ questions, and some scenarios requiring narrative responses, for which marking memos are not workable, requiring experienced markers.
. The application process takes about four months.
. Training qualifications are set low, and experience levels are set high. There is likely to be a shortage of mentors.
. Most applicants lack the experience required to register for the work they do.
. SACPCMP verifies the experience of applicants only by random checks.
. Many applicants submit incomplete documentation, or delay payment of the fees.
. Salaries are unlikely to be standardised to registration levels. Salaries range widely, between R2000 and R35 000 for Officers, and between R5000 and R48 000 for Managers.
. Some practitioners falsely claim to be registered.
SACPCMP conducts examination “preparatory workshops that focus on the structure and requirements of the examination system” at a fee of R1050.
The council acknowledge that the ideal health and safety training is tertiary study, but they note that there are “few construction health and safety academic programmes”.
Consultants criticise registration process
Consulting body NIOCCSA said registration should apply only to Agents. “The competency of construction health and safety Managers and Officers has no direct effect on the outcome of projects.
“These practitioners are employed and carry no personal legal liability or civil liability. The supposed incompetence that the enforced registration process pretends to prevent, has little effect on design, engineering, management or incidents.
“They are ineffective since the way in which client-appointed Agents manages health and safety on site, is ineffective. Clients do not engage HS Agents in planning.
“From a list of 25 complaints against Client Agents raised via the NIOCCSA dispute resolution process, none of the complainants opted to proceed, since they believe that such a process would jeopardize their business relationships with their clients,” said NIOCCSA.
DOL to check on Agents
DOL said it would rate Construction Health and Safety Agents on their work and site records, and the number of sites where they operate simultaneously, and focus inspections on their weak points.
Consulting body NIOCCSA is also skeptical of this goal. “Policing HS Agents is pie in the sky except on a few large sites. Most high risk work lasts only a week or two, on relatively smaller budgets, and some Client Agents serve up to 20 sites per month.
“Where DOL inspectors would find the time and people to check these site records is a mystery. If the DOL wanted Agents to prepare site reports to verify their competence, it only reduces the Agent’s time on site, adds fruitless admin work, and would raise paper costs.”
DOL said it would inspect Agents as they inspect electrical certificates of compliance (COCs). One DOL inspector had recently confiscated 40 COCs that were ‘meaningless pieces of paper containing only a signature’.
Construction project managers’ fees
Among construction project managers, who already register with SACPCMP, many candidates fail to submit their logbook, are not properly mentored, lack support from their employers, and lack exposure in all of the competencies required, said SACPCMP official Jimmy Otsile Modise.
Project professionals pay an Annual fee of R2440, Application fee R1450, Registration fee R740, Appeal fee R2390, Examination fee R1250 per module, Interview fee R2390, Exam workshop fee R1050, or RPL fee R15 040.
Project professional Candidates pay an Annual fee of R1890, Appeal fee R2390, Registration fee R740, and Application Fee R1450. All project management categories pay for a Letter of good standing at R290, and replacement of a registration certificate at R290.
Project management registration candidates have to maintain a logbook throughout the entire candidature period, submit the logbook yearly, work under the supervision of a mentor who is a registered professional with SACPCMP in the category the candidate is registered in.
Construction health and safety practitioners may face similar fees and difficulties, in addition to the lack of choice in tertiary health and safety training, and consequent lack of recognition of their skills.
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