Health and safety consultants do not have to register

Construction health and safety consultants, and health and safety file providers, do not have to register with the SACPCMP.

From Raymond Wienand, health and safety consultant director; I have a few questions regarding the SACPCMP registration criteria and general industry.

I own a business that provides health and safety services to a big variety of industries. We develop, implement and maintain their Sheq management systems for them.

I am not directly involved in the construction industry, and I do not intend to be. I do not manage construction sites, I do not represent any Clients on construction sites, and therefore have no intention in registering at the SACPCMP.

I have some clients in the steel product manufacturing industry, and some other industries, that manufacture and install their products in the capacity of contractor or subcontractor, never as a principal contractor, on construction sites.

I do their health and safety systems and also compile their health and safety safety files for them, not in the safety file ‘factory’ way, but in the proper way.

Will I still be allowed to do it legally, or will I be operating illegally if I provide this service to them? I obviously do not want to loose these clients, but I also do not want to operate illegally.

And would I still be allowed to be appointed as the risk assessor and accident incident investigator?

Health and safety consultants legal answer

Lawyer Shavanya Subromoney responds; Hi Raymond, your conclusion not to register with the SACPCMP is correct, you are not one of the construction health and safety professionals that are required to do so.

In terms of compiling safety files, you would still be able to do it as long as you make sure that the files are in accordance with the Construction Regulation requirements.

There is no requirement on who must compile the files, besides for that person being competent to do so.

The only health and safety professionals who must register with the SACPCMP, are CHS Agents, CHS Managers, and CHS Officers. Their duties are defined on the SACPCMP website.

Risk assessors and incident investigators do not need to be registered either, so yes, you may still be appointed as risk assessor or incident investigator.

* See other posts on health and safety consulting, and health and safety files, on

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