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How to cure the construction safety file syndrome

Work is often delayed to get a construction safety file approved, lacking the required safety plan, writes Master Builders North CHS manager Doug Michell.

Hours turn into days and days into weeks as contractors attempt to meet the requirements presented to them by a client representative. There are even disturbing allegations of contractors being warned that their file would achieve only 20% in review, and that they should buy a safety file from a consultant, usually at an exorbitant fee.

The contractor may be a specialist contractor who has taken the effort to develop work-specific risk assessments and other relevant documents using experts in their field.

On the other hand the safety file they are recommended to buy would be compiled by a generalist possibly with limited insight into the associated risks and whose expertise lies in satisfying the client’s agent!

Health and Safety Specifications

Was this the intention of the legislator, that a safety file syndrome should become the focal point of health and safety implementation on a construction site? It is my opinion that this is not the case. The Construction Regulations define a process or path that appears to make good business sense, in three phases.

Phase 1; Client Health and Safety Specifications

The Client prepares project-specific health and safety specifications. For the specifications to be relevant one is led to believe that relevant project specific factors would be considered by the person drafting the specifications.  These may include;
• Scope of work (what is being built?)
• Location of site and elements specific to the location (municipal by-laws, weather factors, geographical factors)
• Geo- technical report (conditions of the soil, raise any concerns that may hinder the project progress)
• Baseline risk assessments based on scope of work (Is this a high rise building in a built up area? Is it a Greenfield site?)
• Controls specific to client requirements (two day induction, pink overalls, entrance to existing premises etc).

Is it reasonable to assume that if the client appoints a principal contractor with the “necessary resources and skill” that this would include the premise that this contractor complies with South African law as a minimum and so the health and safety specifications need not be a repetition of the basic Occupational Health and Safety Act and Construction Regulation (CR) requirements?

Phase 2; Health and Safety Plan

Following on from the preparation and issuing of the client’s health and safety specifications, the Principal Contractor is required to provide and demonstrate to the client asuitable and sufficiently documented health and safety plan.

This plan should be based on the client’s documented health and safety specifications and provide record of how the factors raised in the specifications will be addressed ensuring the health and safety of the workers on the project.

CR5(1) states that this plan is to be applied from the date of commencement of construction work.  This leads one to believe the Health and Safety specifications must be supplied to the contractor in good time and not on the first day or two weeks after commencement of construction work.

Phase 3; Discussion and negotiation

The construction regulations continue to lead one through a process which at face value does not appear to be unreasonable (see diagram 1) and which continually refers back to the Health and Safety PLAN that was provided.

This suggests that discussion and negotiation regarding the plans content should take place between the parties before final approval of the Health and Safety PLAN for implementation at commencement and for the duration of the construction work.

Construction safety file versus plan

When conducting a word count in the two regulations, CR 4 and CR 5, on the words PLAN and FILE, the word PLAN comes out a clear winner at 15 to 3.

Closer scrutiny of the three usages of the word file discloses that;
• CR 5(7) is the first referral and requires that a file is opened and kept on site by the contractor and “includes” all documentation required in terms of the Act.
• CR 5(8) necessitates that a consolidated health and safety file is handed over to the client by the principal contractor on completion of the construction works.
• CR 5(9) requires that in addition to all the documents required an updated contractors list with agreements between the parties and the type of work done is included.

I would like to believe the legislator does not suggest that all this documentation should be available in the file from the outset of the project.

The documentation referred to would include appointments, risk assessments, inspection reports, inspection registers and minutes of meetings amongst others; all of which could only be generated through the duration of the project substantiating that the contractor has a health and safety plan which is being implemented for the duration of the construction work.

The consolidated health and safety file which is referred to requires more than  health and safety documentation, the regulation states; “… addition to the documentation referred to in subregulation (7), include a record of all drawings, designs, materials used and other similar information concerning the completed structure.”

This suggests a far more comprehensive document than just the standard health and safety file with copies of the monthly inspection reports and minutes of meetings. It sounds to me rather like the contract completion pack?

Experiences suggest that the health and safety FILE rather than the plan comes out a distant “winner” as the culprit for rejection. Some observers even suggesting the person evaluating the file does not even have the courtesy to read the health and safety plan!

Construction safety file functions

Was this the intention of the task team who initiated the Construction Regulations 11 years ago? The Health and Safety FILE has taken on the form of a menacing monster. The Health and Safety FILE is an instrument of frustration for some and a healthy income for others.

In an article titled “There must be a better way”, Dr Brett Solomon of Saacosh states that safety strategies being employed simply have not delivered the results expected. The “bureaucratic approach” into which the safety file syndrome surely falls prescribes in advance, rules and instructions which are often impossible to implement let alone enforce.

Health and Safety becomes entirely management’s responsibility and when an incident occurs we review our policies and procedures rather than identify the root causes.

The time has come for Construction Health and Safety practitioners to reflect on this SAFETY FILE syndrome. We need to interrogate what were the intentions and ask if in its current form the SAFETY FILE is adding value to the business of protecting life and limb.

• Doug Michell is the construction health and safety manager at Master Builders North.

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