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How to appeal an SACPCMP registration decision

SACPCMP registration of construction health and safety officers, managers or agents is long, costly, and open to dispute (see criticism below).

Among the hurdles facing practitioners after formal training, are applications, fees, annual fees, reports (essays), finding a suitably qualified mentor to sign off on a logbook of experience, exams, interviews, and some flimsy online CPD ‘development’ procedures.

Competition Commission could stop construction safety registration

Here is a real example of an SACPCMP registration decision to decline and downgrade the applicant to Candidate status, pending a further two years of experience logged by a mentor. After the eventual decision, follows the appeal of the applicant.

“OUTCOME of application for registration as a professional construction health and safety manager. After careful review of your application, SACPCMP council has made the following recommendations based on the information you submitted;

“That you register as a Candidate CHS Manager for two years, for these reasons;
• You have demonstrated knowledge of construction, however this exposure is included to project management and does not demonstrate sufficient CHS Management experience.
• Your project reports demonstrated generic theoretical knowledge rather than applied experience in CHS Management.

“SACPCMP Council further wishes to advise you that in order to eventually qualify for professional status, you will need to maintain a logbook during your candidature period. This would need to be submitted annually after endorsement by your mentor, to demonstrate you acquisition of experience.

“You are also required to work under the supervision of a professional construction project manager in terms of section 18(3) of the CPMP Act, and be invited for an interview.

“To register as a Candidate CHS Manager, pay for registration and the annual fee. You may appeal within 30 days upon proof of payment of the appeal fee of R3695.

Appeal against SACPCMP registration decision

“To the Registrar, PO Box 6286, Halfway House, 1687. Dear Sir or Madam; APPEAL against the outcome of an application for registration as a professional construction health and safety manager, in terms of section 35 of the Act.

“After carefully studying the recommendations by your council regarding my application, I came to the conclusion to appeal your decision.

“I appeal based on your criteria for registration as construction health and safety manager, where you indicated that if the candidate has a National Diploma in the built environment, the applicant needs a qualification with small components of OHS plus additional health and safety training, and more than five years relevant post-qualification experience in construction.

“You recommended that I have demonstrated knowledge as per your requirements, as attached. It is confusing to hear from you that I have insufficient experience. You indicated that I was more inclined towards construction project management.

“I ensured that appointees did comply with the OHS Act and Construction Regulations. I dispute the view of your assessors that I have not acquired enough construction health and safety management experience.

“You also recommend that I have generic theoretical knowledge rather than applied experience in construction health and safety management. Did you assess my report. I have indicated that for the first two years after I graduated I was employed by Central Karoo District Municipality as the first health and safety officer there.

“I started all the health and safety systems, developed specifications, did incident investigations, conducted inspections, trained OHS reps, etc. In all my years of service I have been involved in safety management.

“I am completing my National Diploma in Safety Management and I believe that I have concrete applied knowledge in construction health and safety management.

“I recently helped the Ndlambe Municipality in the matter related to the High Court decision to let the owner of erf 20 in Kenton on Sea demolish the structure.

“The municipal consultant managing the process struggled to get the owner to submit a health and safety plan. I advised the consultant to provide the owner with a documented health and safety specification as required by Construction Regulation 4 (a). Let us not become too technical here.

“I wish to put into perspective the pain and frustration I endured during my application process. I applied to the SACPCMP last year in October, only to get feedback in August, almost a year later.

“In May I received an update that the assessors are indecisive and my file would be sent for moderation. I assume they saw me fit to be a construction health and safety Manager, why were their views ignored by the moderator, who took three months to come to a conclusion.

“I had to write several emails. On your roadshow you advertised regulation of the health and safety profession, with a turnaround time of six weeks. In my case it is already ten months.

“Mr Forgey, in our telephonic and email interactions you kept on mentioning that you are under-capacitated and that was one of the reasons for getting outcomes way later than anticipated, yet in your recommendation you do not take into consideration my time lost due to your own doing. I hope you find my appeal in order. Signed….”

SACPCMP registration criticised

Consultant Rudy Maritz responded to this post; “NIOCCSA should list the SACPCMP on the incompetence register. I am out of this game, I cancelled all my registrations.” editor Sheqafrica responded to this post; “I oppose the format of the current health and safety professionalisation process, because it does not address flaws in the NQF, DHE, universities, QCTO, SETAs, legislation, or enforcement, nor in business employment, HR and operational practices. Nor does it compensate or ‘plaster over’ these flaws.

“Registration based on semi-privatisation of pseudo-training functions such as exams, interviews, CPD, workshops, and quality assessment, would perpetuate and magnify systemic flaws such as duplication, OHS generalism, sectoral fragmentation, and low institutional capacity, while an array of boards and contractors flourish on additional fees.

“By moving the focus of health and safety employers and practitioners towards institutions, the state is further weakening our fragile education and training system, and diverting the role of associations into pseudo-training and pseudo-discipline, instead of representation and advocacy.”

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