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; “…..in 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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22 thoughts on “How to cure the construction safety file syndrome

  1. Doug, out of 10 I give you 25 for this article. I fully agree with you. And worse than this is the fact that health and safety files are being sold to all industries as a legal requirement, and not just construction, where it is the only place mentioned in the entire Act.
    It is exactly this type of exploitation that persuaded me to join NIOCCSA and draw attention to the lack of control in the consulting industry.

  2. Hi Doug, thanks for the article. It’s been a while since i last seen you. One of the major problems that i find, especially in MEGA construction in the middle east, is that the file becomes a static document. I have also seen and noted this in SA.
    For example, one of the most important documents is the Construction Plan, and for me as a HS Practitioner, the Constructability Plan, with the associated how-to planning. I have worked both in companies where such planning becomes a practical exercise before construction, who is in charge, what skilled persons, how do we do it step by step, everyone knows the hazards. Too often the construction plan stays with the site engineer, it is not taken that one step further of “how to”.

    At the present company i am at, we do mega projects, an we have the same problem. I am sure that a specification from client must include the “Constructability Plan”, not only the Construction Plan.
    Great article
    Shane

  3. Doug you are 100% correct. I am a SHE Manager with a construction company and on several occasions I have been frustrated by the so called consultants appointed by clients. They put much emphasis on trivial paper work. What I consider important at the start of a project is a site specific health and safety plan and job specific risk assessments and method statements and the whole file should be developed and updated gradually as the project progresses. In instances where one engages these consultants to come up with the File you will be really surprised with what they will produce for you as their documents will be so generalised to be of an value for the task at hand. My thinking is that more emphasis should be on the health and safety plan and risk assessments conducted by people with understanding of the industry concerned as these people will be able to suggest practical and workable solutions to identified risks rather than just producing volumes and volumes of paperwork which does not offer workable solutions associated with the task being executed.

    1. I Agree, however 90% of that time the RA’s and Method Statements are not actioned, costed, resourced and implemented. We still focus 90% on the safety side, but very few RA’s have adequate Occupational Health RA, and i have never seen an RA for Ergonomics, that goes past the traditional phase, never going into system economics of design, construction etc. I have never seen a site RA for psychosocial risk, which has been clearly documented worldwide as reducing production and productivity, and the effects thereof documented, e.g. increase in physical disorders, hypertension to name one. Ultimately, this is not only unique to RSA, only the very large companies, for e.g. BP (not that we can go by their record), and the like actually do these RAs. Shell is anouther company that does (on high risk projects) extensive RA’s, with execution plans, costed etc. Once again i get back to my term of “Constructability Plan”, the HOW of doing it, which includes the economics of the job, the planning, leadership etc of execution.

      So personally i do not rely on the Safety Plan, RA’s and method statement, because 90% of the time i find them poorly done, rushed to get out, “hierarchy of controls” always seems to revert back to the last resort ‘ give them PPE’, a hardhats will stop the 20ton load from crushing his head?

      Now for the Plan, the H&S plans i normally review or see, is a clollection of documents, that has no start and end. A plan has definite outcome, the means to get their can be compared to building a house, from land/foundation to the end product.
      No go back to what is normally submitted, is it really a H&S PLAN?

      My thoughts on this matter comes from years of experience looking at these plans, and in most cases the H&S Practitioner cannot put the PLAN into place. He/she does not know the economics of the plan, ask for the implementation budget breakdown, or simply his “bill of quantities for HSE Management at that sight.

      Have a good one
      Shane

      1. Hi Shane, Regarding; “We still focus 90% on the safety side, but very few RA’s have adequate Occupational Health RA, and i have never seen an RA for Ergonomics.”;

        In my view, and you are free to disagree with me, but 90% of Health and safety practitioners have 0% occupational health training.
        I base this on the fact that 90% of SHE Practitioners only have a collection of short courses.
        Even programs like NADSAM and B.tech Safety Management covers very little of Occupational Health. On the other hand, B.Tech Environmental Health (NHD Public Health in the good old days) covers very little of Safety.
        I still hold the view that safety is an engineering discipline and health is a medical discipline. The two should not be married into one unless one holds a qualification in both.
        The term Health & safety, as a unit, refers to a management system and not a specialist professional field. The fact that one Act, covers both health and safety requirements, does not make it a unit, but that is a debate on its own and not related to the issue of this post.
        The mere fact that industry, and HR practitioners in particular view Safety, Health, Quality and Environmental management systems on equal value, has convinced business leaders to appoint one person for these four disciplines. The truth is, that each requires a specialist body of knowledge.

  4. I have just consulted with a few Chartered Civil Engineers in my organisation, and for clarity on my Term “Consructability Plan”, i have been advised to rephrase it for the sake of clarity.
    At pricing and design the Constructability Plan includes the design, costing etc. In the UK the CDM Co-ordinator would also be involved. The Construction plan is then submitted with the HSE Plan. This is where i find that start of the problem, and was well expressed by one of the civil engineers regarding the HSE Plan: “it really is a statement is it not, its not really a plan”. We normally then take this construction plan and place into a schedule, Ghantt Chart. If we then look at the individual “bars”on the schedule, does each of them have the correct method statements attached to it, the correct skilled human resource, equipment certified to that scheduled task, training, etc. This is what i term the HSE Constructability Plan, the HOW TO, at each stage, “bar” item. Has this been done before, the answer is yes, very successfully on high risk jobs that i have done, both in refineries, with leading companies who have understood, and contributed to the methodology of execution successfully.

    I hope this bring more clarity to my term used.
    Regards
    Shane

  5. Doug, a very good and a very valid article. I agree with what you said.
    Compiling safety files is a big part of my business and yes I do make a handsome profit out of it. I have seen competitor prices ranging from R2,000.00 up to R13,000.00 and I do agree that there are a lot of people compiling “generic” safety files purely for the money and for what it’s meant to be.

    The smaller contractors mostly don’t have the knowledge or capability to compile a safety file. For most its a pain, an irritation and a waste of money. Numerous contractors can’t even provide a scope of work nonetheless a method statement of how they are going to do the work. For these guys I do see the need and the solutions of making use of a SHE agent / consultant to compile the file on their behalf.

    Sometimes the client provides the contract specific Health and Safety specifications without me asking for it and for a lot of sites never receive it. I do receive answers in the likes of “you should know what goes in a safety file” for my requests.

    On some projects the safety file does get audited and scrutinized as its supposed to but mostly it is “audited” to make sure that all the required documents are present and they as the client are “covered” should a DOL inspector make a surprise visit.

    It is unfortunate that we are in a construction safety file syndrome. Like a lot of things it started out as a good thing but turned into a project “ritual” as time went by. There are some of us that does try our best to compile a construction safety file for what its meant to be but it’s not always easy if you don’t get cooperation from the contractor or client.

    P.s. What do you think is a fair price for a construction safety file?

    1. As a file should be site specific, one should not have a standard price. The complexity, the need etc should be evaluated into the price. Unless one just changes a logo, address etc, and spits out the same generic stuff to all, which is seen in many cases.
      Regards

  6. With compliments of Mr Gavin Bruwer – Technical Director ComPrac Group:
    Yip……once again this age old problem is highlighted. What these consultant bashers seem to forget, although unfortunately accurate in their assessment, is the following:

    · The contractor has very little or no idea what the OHS Act is about, never mind the requirements in terms of the CR.
    · Even if issued a specification they either ignore it or fail to understand it because the client has made it totally unintelligible. (They hope it just simply goes away – WOW and it normally does because why, this was also drafted by a consultant with no real insight in terms of the inception, conception, design….etc.)
    · The contractor usually tries and delivers a very lame and equally unintelligible SMP and risk assessment. (Often wonder how they got to become professionals if they don’t understand their own methodology – have you ever tried getting a contractor to give you a WBS for a method statement??)
    · By the time the contractor decides, shit my half-baked attempt isn’t working, he is already two weeks behind schedule, been allowed to start work by the client because they now feel the schedule pinch and been informed that unless their safety submission is in place they won’t be paid. (Again WOW – now the contractor is coerced into finding someone to help him get paid, not perform safely)
    · Now he phones a consultant, finds the cheapest, and expects a project specific set of OHS submissions without allowing the consultant to perform the required pre-emptive work. (Again WOW – why doesn’t this work)
    · The consultant, knowing that his submission is not going to satisfy the intention of the law, proceeds to prepare a set of generic submissions, which more often than not are accepted by the client. (Again WOW – so it’s about who prepares it and not really how its researched and prepared?)

    Please note above comments represent a generalization as there are a number of role players who actually understand the intention of the law, and have provided for the required structures to actually ensure its realization. (This percentage is however very low in terms of the trade contractors obviously referred to in this article)

    Note: Consultants – Have no basis in terms of any OHS legislation yet the biggest driver in terms of OHS in SA?? Consultants should assist industry in terms of continuous improvement, but should never be used as a surrogate to the organizations OHS obligations. (This proxy has no foundation in law)

    The question is why is this happening and how can it be changed?

    · The legislator is either not willing to or incapable of enforcing its very own regulations. (Many reasons why this is failing and not worth discussing – world class standards on paper though)
    · Clients fail to coordinate OHS, as regulated, and simply transfer their responsibility – legislator actually ascribes to this point of view by allowing for a principal/safety agent.
    · Contractor doesn’t understand the law, fails to understand the project requirements because these have been developed in isolation and often without any insight in terms of the construction process.
    · Consultant provides a plug and play solution, which might satisfy the letter of the law, but dismally misses the mark in terms of intention.

    · Change must come from the top – enforce legislation – entrench its requirements into company registrations, annual evaluations, quarterly returns similar to VAT and other corporate reporting requirements.
    · Actively pursue individual and corporate prosecution – unfortunately need a competent infrastructure to further this option.
    · Company’s must ensure OHS is interned into the structure of their organization – external assistance in terms of methodology and training is obviously required. (OHS responsibility should not be allowed to be transferred even if we guise this by saying that the client retains overall accountability – we know this is often a matter of appointment)
    · No contractor should be appointed without a minimum hour defined exposure to OHS – they must understand the OHS principals in the same way as they are expected to understanding the engineering and construction principals.
    · Consultants must act responsibly and embrace their true importance, which is to empower their clients to actually give life to the true intention of the law. (All meal tickets eventually disappear into the mist as will this one unless we embrace our true responsibility in terms of OHS)

    Knowledge – Commitment – Enforcement, in that order, is the only way we will overcome this perception and engage real change in terms of OHS.

    It’s not only the consultants fault, it’s an epidemic of he said she said and none of us understood or did anything.

  7. The process is far simpler than most consultants have modified it to be.
    As Doug correctly states above, there are only three phases followed by approval and monitoring.
    The way I have viewed it, is as follows.
    It starts with a Method Statement – How to build a house.
    Following on that, we have to assess the hazards that will be encountered in building the house.
    The risks are assessed and then, the METHOD STATEMENT is revised to remove the risks.
    Commonly known as Design Risk Management.
    Only NOW, do we prepare a Health & Safety Specification, which highlights the risks that could not be removed during the design stage. This we then issue to the Bidding Principals.
    The Bidding PC’s then need to decide what they can build themselves and what needs to be built by Sub-contractors. Each subcontractor must then repeat the process.
    Subbie 1 – Method statement 1 = How to cast a foundation,
    Subbie 2 – Method statement 2 = How to cast a floor,
    Subbie 3 – Method statement 3 = How to build a wall
    Subbie 4 – Method statement 4 = How to install a door, window etc.
    Method Statement 10 = How to install a garage door opener.
    At the end each contractor will have created a method statement, that if combined, it will create a house.
    Each method statement must be accompanied with a detailed HIRA and H&S Plan. This must be submitted to the bidding PC, who will then evaluate and select the subbie with the best plan, most suitably qualified people and best track-record etc etc.
    The combined plans, are then consolidated by the PC, highlighting how it will go about managing the project and the subbies. Only then is the quote submitted and the client can select the PC.
    During the selection of contractors, the negotiating takes place. Nope, inspecting hand tools on an annual basis is not good enough, can we do it monthly? Can we adjust the costing?
    The negotiating is not about the quote, but about consensus of the H&S Plan’s effectiveness in achieving project objectives – Zero accidents. It is also to allow for the provisioning of costs to achieve these objectives.
    I have often seen Specification for H&S Files, that have to include VAT, and BBBEE Certificates, Insurance policies etc etc, stuff that is not H&S related, but forms part of the Vetting process of the contractors. While the actual content needed to achieve project H&S Objectives are no where to be found.

    Approval
    Approval of the H&S Plan should be based on three elements:
    1. It covers the Method Statement in its entirety,
    2. It addresses all hazards identified, health, safety, ergonomics, chemicals, equipment, energy sources, traffic, pedestrians etc.
    3. It demonstrates a monitoring program.

    Monitoring
    Client Agents often rock up on site, and checks the FILE, and either attempt to throw you off site, or throw their own toys out of the cot.
    The purpose of the Client Audit is not to demonstrate the size of one’s ego, but to ensure the contractor sticks to the Approved PLAN. If the Plan stated that hazard communication will take place every week on a Monday, show me. If the plan stated that the Fall protection supervisor will have training according to Unit Standard xyz, the Show me.
    But no, my letter of good standing expires in July 2014, and every two weeks, I must prove that it still expires in July 2014. As if the date will change to Jan 2014.
    So Raymond, I have to agree with the smaller contractors, The way H&S practitioners currently manage the entire process is an irritation, and a waste of money. For instance, a contractor might be a sole proprietor, but needs a 16(1), a 16(2) and a 6(1) and 6(2) appointment letter, all signed by himself, appointing himself. And let us not add all the letters of appointment according to the spec. One person signs up to 21 letters. And in full “SHE-lingo”. I, the 16(1), hereby appoint me as the 16(2) in terms of blahblahblah of section bwhahaha, and they even sign it twice.
    Not only is it a waste of time, it is making a mockery of H&S.
    But, having said that, when you tell the client it will take around 21 hours at R750 per hour to compile a proper health & safety plan, with a comprehensive risk assessment and properly defined method statement, you get the weirdest of looks. Oh, but why, I can get it on gumtree for R1200?
    And yes, WHY indeed. Marilyn Monroe’s Resume passed the test, why should you spend that much money? If the SHEReps acting as PC agents accepts it, why bother doing it properly? I still struggle with that question. But when the inspectors rock up on site, it is my client’s files that are always presented to the inspectors. Am I that good? Perhaps, but perhaps it is the better of all evils.

    1. Gavin, it’s no good blaming the DoL, In short we the HS profession have created the monster, we in the H&S profession have to slay the monster before it slays us.
      Back to basics, Health and safety should be about protecting people and not the best looking, thickest H&S file. It needs to add value and when the process does that then maybe the industry will start taking us seriously again.

    2. Rudy, I think part of the misunderstanding of the process is the assumption that the construction regulations are written in the order that it should follow. This is totally not the case. Look at Sectiion 8 for instance. It does not start with a risk assessment.
      SA law is extremely ambigious and rightfully so, as prescption results in liability and if the law maker becomes prescriptive, it creates a public liability for itself. We have seen this many times, where state departments are sued for losses because of prescriptive legal requirements that cannot be adhered to within a particular industry sector. Not all have been successful though.

    3. Rudy,

      You have hit the nail on the head with the methodology. That is precisely want a meant by a construct-ability plan. But you explained it better.
      We fail dismally normally in construction with this issue.
      As for your comment that 90% of Safety people know nothing about health, i agree that it is a problem, but it is also a problem caused by past educational bodies. Why did we not keep up with the international trend by having a BSc(Occupational Health and Safety). We still separate the professions, i even prepared a syllabus, and gave it to a few people to look at. The problem being, it would include subjects that are core, like chemistry, physics, statistics, anatomy. This is not in the NADSAM. And people tend to backoff as soon as scientific subjects are introduces

      Until educational institutions start to change the degree,s towards our profession we will always have this debate.
      It is somewhat addresses however in a good IPD system, that does introduce the need for health.

      I suppose, it is also the professional bodies role to do this. I will put it on my list of “to Do’s”.

      Regards

  8. Hi Les, as a consultant myself, I often stand offended at the comments made at consultants, but then in retrospect, I cannot blame people. In Gavin’s write-up, I would offer a disagreement to “Consultants – Have no basis in terms of any OHS legislation yet the biggest driver in terms of OHS in SA??
    In order to appoint a consultant and give them authority in terms of the OHSAct, there is only one piece of legislation that can be used, and that is Section 16(2). This gives the consultant the same authority as the CEO or business owner to enforce compliance. In the Construction Sector, this could possibly change with the new construction regulations, but with limitations.

    I have been in the consulting industry for 14 out of my 27 year career, and the demise of the consulting industry in specifically H&S has reached an all-time low. We are experiencing a huge influx of substandard consultants.

  9. I agree because i see this “SAFETY FILE SYNDROME” on a daily basis within my company, the legislator should focus more on the HIRA Process and safe work practices rather than on a safety file which in itself will not safe a life but a proper working system will be able to safe lives. I do agree that a safety file is necessary whereby one can measure management commitment towards health and safety, but we must focus more on where the work is performed and improve on working systems then incidents will starts to decrease.

  10. In relation to the 20% pass mark, I had a similar experience when I took my file into the offices of TFMC. I was told in no uncertain terms that my file will not pass the first round and I should contact a crtain consultant as he knows what is needed.
    For instance, starting off with the approval, the one SHE would ask the other SHE, “Company reigstration number 2000/xxxxx/23, are you happy with that?, and will then tick it off if the SHE agrees that he is happy.
    Another intance…
    They have an item on the tender documents – Company information – so you put your company information in the file, address, telephone, CK registration etc, on a letterhead as you would with a normal tender. then they wanted a tax clearance certificate instead and failed me. Why not ask for a tax clearance certificate if that is what you wanted. But no, fail me so you and your buddy consultant can share the fees? Not!!!

  11. Oh, and did I mention that this all happend six months after I was awarded the tender and have been working ever since without an ‘approved” file?

  12. In the UK – emphasis is placed on competence, whether it is designers, principal contractors, contractors or CDM Coordinators. Part of their competence will include an appreciation of Health & Safety requirements commensurate to the type of work they are undertaking or service they are providing. The system is seriously failing if people are not able to undertake certain H&S related activities in accordance with their function. Further to this, the Health & Safety at Work Act and associated regulations require an employer to have access to competent H&S advice whether this is an internal function or an external consultant. Most large contractors I encounter have established H&S or integrated QHSE management systems. The H&S Manager or advisor or whatever you want to call the person is usually is clever enough to create a system that empowers others to take responsibility – most projects I work on, the project manager or contracts manager will compile the Construction Phase Health & Safety Plan and their internal or external H&S advisors may review and sign off before submitting to the CDM Coordinator for review so that the Client may be advised if there are suitable H&S arrangements in place for construction work to commence.

    The Construction Phase Health & Safety Plan (CPP) is a site specific management system outlining the health & safety arrangements to be put in place specific to that site – including plans for traffic/logistics management, fire and emergency plan etc. A good CPP will cover health risks (e.g. asbestos) and safety risks (e.g. work at height). It is a live document and should be reviewed as the project progresses or in response to audits or issues such as incidents or accidents that require a change in processes. The CPP as a matter of course should outline the process for ensuring there are adequate safe systems of work in place for all packages of work being undertaken. This would include risk assessments, method statements (RAMS), permits to work etc. The process for reviewing and authorising a piece of work should be clearly outlined – and again the system is seriously failing if the people who are familiar with that piece of work are not involved in the review process – the H&S person can add their final seal of approval if that is required.

    All of this cannot happen, if suitable and relevant H&S training is not provided and ALL persons are empowered to play a part in delivering H&S in the construction process, with the H&S Advisors/Managers being the custodians of the process. Failure to do this will result in a lack of ownership and people will always turn their heads with big bambi eyes and say “We thought the H&S guy was taking care of that”, and of course, they will part with large sums of money if they think they can pass on the responsibility and risk to someone else.

    The management system start at the top – governmental strategy and policy which produces legislation – employer create company specific management systems and likewise in construction, this filters down to a site specific health and safety management system – call it what you want – plan or file (the word file to me indicates something you put on a shelf and leave there for the duration as opposed to a working document).

  13. Ja, I agree, I have a file on site where I keeps all the H&S stuff. I’ve labellled it FILE 13. Only I knows whats in there and thats how I like to keep it. They are too many morons trying to fiddle wif SHREQ trying to make a names for themselves, so I keep a close hand on it and if anybody touch my file I klap them straight off my site. No nonsense.

    SHREQ Groete,

    Koos Duvenhage XXXXX
    X-Ray in Safety

  14. Hi

    It is so good to see professional discussing this topic on this site. It would be great if Prof Smallwood would also join this conversation, as the real part of safety and health is the implementation of the PLAN, as mentioned above. The question i ask is then, WHY IS IT NOT IMPLEMENTED? Is it due to.

    The client not will to spend the money
    The client quoted without knowing what he had to do Safety and Health wise
    Are the consultants providing just what is asked – Client determines what he wants delivered
    Is it a RFP issue when it get sent out for tender
    The Skills base is not available or the cost is to high to hire a professional

    Some thoughts,
    Shane

    1. Hi Shane, What I have seen from the majority of sites I’ve been on or involved in, is that the consultant appointed by the client, makes up the rules as he/she goes along. In most cases the client agent’s requirements were never part of the deal to begin with and to make matters worse, is that the client itself seldom knows what the consultant is doing on site. Nobody dares to complain in fear of being penalised or thrown off site and their contracts terminated. Very few knows that it is not as easy as pie.

      In the rest of the cases in my experience, the process fails, in that the consultant is either not engaged, or advising the client at the onset of the project. When the green light then goes on, the H&S functions are rushed to get it approved, resulting in the delays this entire debate is all about.

  15. Very good reading and lots of positive input and lessons but, . . . . . I have yet to come across one tender document that has SITE SPECIFIC health and safety specs. Every tender that comes past my desk has generic specs badly disguised as site specific. It appears that consultants and agents prefer to “cut-and-paste” rather than drive out to site to see the conditions for themselves.

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