“The main focus of compliance to the Construction Regulations of 2003, has become the Safety File, which by law has to include reams of contracts and agreements, keeping Sheq officials and inspectors in the office, while failing to reduce construction injuries and diseases,” said GMBA executive director Colin de Kock and HS&E specialist Doug Michell.
“We call for a debate on how to maintain compliance, reduce the paper chase, make the Safety File more accessible, shift the focus back to conditions and behaviour on site, and extend compliance to small contractors,” they pleaded at Shercon, hosted by Dekra at Sun City in March 2010.
Construction contractors and miners nodded in agreement, while Department of Health inspectors responded during question time by pointing out that many site problems are detectable in the Safety File.
Inspectors want status quo
De Kock showed slide after slide of evidence for a paper chase, including rooms full of files, some compliant systems being impractical and inconsistently used, and non-compliance on site while the Construction Regulations Safety File appeared to prove compliance.
Records of Department of Labour inspection blitzes on construction contractors prove that inspections and enforcement by way of notices and site closures, focused on Construction Regulations provisions for keeping the elaborate Safety File, while no closures related to site conditions, hazards, or risks.
“The Safety File, intended as a record or verification of controls, had become the main focus. Construction companies should focus on what is happening on site,” said De Kock.
Asked whether the Construction Regulations Safety File provisions should be simplified or streamlined to allow small and medium enterprises to develop compliance, in the way that some ISO standards have been simplified for SMME certification development, De Kock said he doubted that streamlining of the regulations would be possible.
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