Academic defends health and safety registration

Construction management academic Prof John Smallwood defended safety registration schemes, and accused consulting body NIOCCSA of lack of support.

“Dear NIOCCSA, Your grammatically incorrect and unfounded communications are not in the interest of health and safety (as opposed to safety).

“Please provide proof of the statement that you have “sufficient support that the majority of practitioners in South Africa does not want the SACPCMP to be the regulator, due to its lack of transparency, costs, and CPD that would prevent further education of practitioners to be addressed at the proper level in the Department of Education”.

“Regards, Professor John Smallwood, PhD (Constr Man), Pr CM, Pr CHSA, MACHASM, MACPM, FCIOB, MESSA, MICOH, MIoSM, MSAIOSH, Head, Department of Construction Management, Programme Director, MSc (Built Environment) Programme, Nelson Mandela Metropolitan University, Port Elizabeth.”

Prof Smallwood copied his email in support of health and safety registration to SACPCMP Registrar Nomvula Rakalote, DOL Director General, DOL Construction head, DOL Chief Inspector, and other academics, including Occumed.

He is also well known for criticising some organisations and providers for neglecting the occupational health component of Sheq mangement and training.

Consultants explain their proposal
NIOCCSA director Andrew Winder responded; ”Dear Professor Smallwood, our statement might be grammatically incorrect, but it is not unfounded, nor against the interests of health and safety.

“Client Agents are not affected here, they are the only professional category in this entire fiasco, and that should be enforced [regulated].

“The new Construction Regulations Amendment does not put enough responsibility on Clients to ensure the effective management of OHS on construction sites.

“Some clients have opted to call entire provinces their construction sites in order not to appoint a Construction Manager on each site or having to issue a site specific OHS specification. Client Audits are still as generic as alphabet soup. We have achieved nothing to date.

“Non-Construction related companies like Telkom, Vodacom, Eskom, Sasol, etc, perform construction work on a daily basis, yet have full-time OHS personnel acting as Agents.

“The Scope of Services of CHS Officers (those with two week courses or less) you will not find them involved in the upstream construction processes. These levels of practitioners are NOT professionals, as the SACPCMP designation also implicated with the omission of the ‘Pr’ Pre-nomen.

“Even Agents admitted that Officers cannot perform these functions as they are not properly educated.

“Registering these individuals will not serve the purpose of the Occupational Health and Safety Act, but will allow for the Construction Clients to appoint these lower level practitioners at agent level to keep costs down.

“The registration process is not designed to entice them to further training into tertiary level, but will create a “short-cut” via CPD.

“We want DOL to register these level practitioners in a once off, affordable process in similar fashion as electrical contractors.

“We want the Department of Higher Education to step up the establishment of the QCTO, so that those practitioners with two week courses can get credits for study and experience to enter into the Tertiary institutions.

“We want Universities like your NMMU to offer degree courses aligned to the unit standards on the NQF so that RPL can take its proper place in the education system and to make it accessible for the full-time employed.

“We want a pathway to be created where SACPCMP registration as Pr CHSA is the ultimate goal to achieve, with proper study; not some hogwash CPD. Reserve CPD for those already qualified at Agent level. That is what it is designed for in the international market.

“Officers and Managers should study to get there, not attend conferences and workshops which are not related to the NQF.

“You may have forgotten that the bulk of the individuals we are referring to and affecting with the registration process are from designated groups. If you and the supporters of professionalism want to make a change, get their employers to pay for their education, and make their education worth the effort. There is hardly enough skills in OHS for the Construction Industry.

“Why eliminate the little we have? The SACPCMP has issued an extension of time for CMs and CPMs who have been functioning as Candidates since 2009, to become properly registered by 2018. The same will happen for CHSOs. We will have Candidates working for the next 10 years and NO formal education will take place.

“I assure you that our efforts to stop and prevent HEALTH and safety officers (with no Occupational Health training in any of the courses listed) being subjected to an ill-fated registration process.

“I am surprised by your response, Prof Smallwood, as I expected you to understand our logic and objective in requesting health and safety officers to be removed from the “profession” until such time as they STUDY to get their Agent status.

“You have only succeeded in motivating us more to stop the process. Do not alienate the “worker ants” of the Construction Industry. They are not to blame for mall and slab collapses.

“Rather address the fact that Construction Managers, Project Managers, Architects, Engineers are not required by the Construction Regulations to be registered with the SACPCMP.

“Rather address the fact that local authorities are not adequately empowered in the OHS Act to assist in law enforcement on Construction sites. -Kind regards, Andrew Winder, NIOCCSA.

• The alternative proposal on health and safety registration to the DOL, is also posted on

• See comments in and below the post ‘Comments on safety registration’ or these other forums;

Comments on health and safety registration

Labour Department silent on request from OHS Practitioners

or email to

Related Posts Plugin for WordPress, Blogger...
The following two tabs change content below. is Africa's largest independent SHEQ Magazine, hosting over 2 000 articles and news items since 2007. is owned by the Cygma Group, a global provider of risk management and compliance solutions. is registered as a digital publication with the ISSN.

Latest posts by sheqafrica (see all)


12 thoughts on “Academic defends health and safety registration

  1. Did this professor not call the H&S people a “bunch of morons” at the Birchwood Conference Centre in Boksburg during the launch of the construction regulations? Or was it aimed at the Ministers and the SACPCMP?
    Was he not ousted by the SACPCMP for pushing his own agenda?
    Is this now sucking up or what?

  2. Let me emphatically state that I, Koos Duvenhage, did not hereby support NIEKAKSE se request for the ending of registration.

    I support the call for the overhaul of DoL and its failing ability as government regulator and enforcer. This is backed up by a paper I recently quoted from which has Prof. Smallwood’s name on it. In this regards, initiatives put in place by DoL are fundamentally flawed.

  3. I beg to differ, professor. We have the likes Rudy Maritz facilitating workshops on the above, a move which is aiming at up skilling and as well as seeing that we have more practitioners compliant to the new law.
    How is it that you say they are not supportive.
    The point they have its reality and asking the Government to be more realistic and practical.

  4. About “Rather address the fact that Construction Managers, Project Managers, Architects, Engineers are not required by the Construction Regulations to be registered with the SACPCMP.”;
    Andrew, there is no need to addresses this in a regulation, its is addressed in Acts of Parliament which take preference over regulations.

    As for the article – Good on you professor, and kudos to the editor for publishing a high profile objection to NIOCCSA’s continued unfounded claims.

    1. Good comment Craig, I actually support the idea of the registration process as standards need to improve. But what I don’t like is the potential corruption and poor health and safety regulation, nepotism etc. I believe there are some persons who do work for SACPCMP who have not had to jump through the hoops to get registration. The tough questions to be asked are – how many DoL health and safety experts would get registration themselves?
      In fact, how many DoL health and safety experts would get international recognition of t heir “skills”, “training”, “knowledge” and “experience”? Could they achieve CMIOSH or CSP? Perhaps that’s where they should start, then start looking at rolling out education programmes locally and setting standards for professionals until they are certain they have they competence.
      This is a mess and it will get worse – mark my words. How do I know? Look at the rest of the government departments and organisations. Good luck.

      ==== Editor notes; So noted. For the record, are you [] Pro registration; [] Pro registration provided some things are fixed; [] Anti registration; [] None of the above; [] Whole different idea; [] I want to be a registrar too; [] Fix the state before you try to register anything.

      About ‘standards need to improve’; by definition they do not, they are standards, of which implementation or conformity could lag or improve. Changing standards is a bigger process, just ask the ISO. If you mean common or garden ‘raising standards’, Koos, such as the business and employment practice of hiring the cheapest for minimum ‘compliance’ and liability, how would registration change that?
      We value your opinion partly because your vision is unclouded by the deepening mess we are in. The general reputational risk, and potential individual victimisation, will not affect your incorrigible morality.

      1. No, I disagree, South African standards are not the same as British standards. Standards can be deficient. For instance, the Construction Regulations under the OHS Act of 1993 outline the requirements and therefore set a standard to be followed. If you are in agreement these regulations or standards are fundamentally flawed, you will then need to agree these need to be reviewed and revised. The registrations debacle has not been started by SACPMP – it has been started by DoL. They have clearly not taken the time to research the subject, establish industry views and perhaps consensus attempting to get buy-in to the process. Why have DoL thought it necessary to introduce registration – well, because the industry has failed to self-regulate, and combining this with large scale incompetent health and safety advisory / consultancy services has created a situation where the national construction accident figures are probably no better than when they were introduced (if such records can be trusted) – therefore the regulations are flawed and this points to an incompetent regulator and enforcer. In this scenario I am partly pro-registration because at least it is a step in the right direction of trying to weed out incompetent operators who are actually causing quite a lot of damage and not taking the industry forward.

        I am anti-registration if the process is flawed and there is a possibility that some people can “buy” their way in – a scenario which is likely given South Africa is known for corruption. So, a double-edged sword. Given the health and safety profession has so far FAILED to self-regulate – compare this to the recognition UK IOSH and the USA Board of Certified Safety Professionals has achieved without regulatory mandate – is evident by the number of EMPLOYERS who will not employ persons without relevant membership. Does this happen in South Africa? No. Why? Because the base level of qualifications, which help develop initial competence, are severely few and far between. Neither SAIOSH or ISoM have emerged clearly to show the profession is capable of self-regulation – I’m sure both would love a regulatory mandate – that would be great for business or those who stand to benefit in some way by holding the reigns.

        What is Koos vision for health and safety in South Africa?

        Firstly, a government regulator and enforcer that has credibility. DoL on the world stage have nothing to give.
        If you compare DoL to the HSE it is like comparing a sub A pupil to a Professor. Want evidence? Compare the websites and what information you get from them.

        The Health and Safety profession is here to stay in one form or another – and there are many types of roles where this discipline is required – advisors, managers, consultants, engineers (never mind trainers and auditors).
        Standards need to be set in terms of the required training, qualifications, experience and skills required – generally, this has tended to come from self-regulation – industry rather than regulators have led the way in this regard. Is there room for regulation? I think in a market that can’t self-regulate, yes. However, this will only be effective if it is enforced. How many health and safety practitioners get fined or go to prison? It happens in the UK.

        My feeling is the health and safety discipline in South Africa has largely developed in isolation – how do I know this? Well once upon a time, NOSA used to brag about how global they were – and those of us who had only been in South Africa sucked it all right up. Where are they in the big leagues? Perhaps on the African continent one of the best (perhaps 30 years ago). Now? The market is too fragmented. When I was in South Africa I had little clue about what was happening externally – yes I read National Safety Council books, but that’s about the extent. South Africa – DoL need an injection of the best regulatory minds money can buy – there will be a few around – the chief exec of the HSE recently went across to the New Zealand regulator. That transfer of knowledge and experience could transform how the national agenda and strategy for health and safety is set – then the zuma’s of this world must allocate sufficient resources to implement that strategy. simples. I fear, they will just fall into the trap as the other comments I have read on here saying we will do it our way. If its not based on scientific research it will fail and any profession that tries to operate in that environment will be compromised.

    2. Thank you for your wisdom Craig Parker aka Section 18(1)(c)
      Your Acts of Parliament has this effect:
      “. In terms of this notice, those Candidates who registered as such prior to the coming into effect of the Registration Policy and Procedures (1 May 2009) are being advised that Council resolved at its sitting of Friday the 28th of November, 2014 that they would be allowed to still continue as Candidates without being in possession of the aforesaid qualifications for purposes of migrating to professional status only up to the 31″ of December 2018”

      That is what your Act of parliament (PCMP Act) achieved since 2009. Those who registered without qualifications as candidates can practice from 2009 until 2018.

      Note: this applies to CM and CPM categories and not CHSO.

  5. Danny, show some respect where it is due. This prof is one of very few people in SA capable of giving us tertiary CPD. I do not even expect him to be politically correct. He knows construction, business, and DOL maladies as well as any of us, and he can put stats to it. He revealed some things about employers and about the DOL that we should study and ponder.
    About the ‘room full of fools and the flat earth’, some scientists and navigators were misled by authority, and some just toed the line. It takes deep study as well as independent research to separate fact, dogma, and politics, and then it takes wisdom to act appropriately. As Galilei muttered when he slouched away from the Inquisition to house arrest, ‘I agreed the earth does not move, yet without my permission the earth still moves’.
    Prof Smallwood is already part of the research and tertiary training solution, and my gut feeling is that he would eventually be part of solutions at lower levels too.

  6. Proper education, not CPD, should be encouraged if we are to get anywhere with the mitigation of slab collapses. Those who have qualifications and who want to became health and safety managers are rejected by the council, citing theoretical knowledge. This thing has became a hassle for most of the people who are eager and committed to health and safety.
    The council has more reasons for why they cannot accept you to practice, than reasons for why you could be allowed to practice. It looks like their assessors are trained infinding faults rather than checking whether the person can do the work or not. It is unfortunate that these people put their egos in front of everything else, while people are dying in the construction industry.

    ==== Editor notes; I removed some of your comments that were based on flawed information, and too personal.
    As several commentators have noted, Officers do not have the skills or even opportunity to ensure structural integrity.
    Your comments remind us that the SACPCMP has not sold its legitimacy to applicants. Even some registered people have doubts, and none have sung the praises of the supposed value that the system would add to practitioners or professionals.

  7. About “It looks like their assessors are trained in finding faults rather than checking whether the person can do the work or not. It is unfortunate that these people put their egos [and bank accounts] in front of everything else, while people are dying in the construction industry.”;

    The fewer persons accepted, means more scope and potential work for the chosen few. The assessors have buddies, registered buddies whom they can farm work out too, for a fee. So why should they even bother checking, BUT, more importantly CONFIRMING, whether the person can do the work or not.

    ==== Editor notes; The registration racket is more sophisticated than just artificially reducing the supply of OHS skills, and tipping off buddies. Some of the ooms (members of voluntary boards) have offered to let some tjommies (candidate ooms) work under them, and to sign off on their work for part of the pay. It’s a pyramid scheme.
    This is one of the ‘solutions’ to be offered to employers after the artificial registration crisis of August 2015. Beware the Ides of August.

  8. With all due respect, did anyone notice the link between ACHASM, the respected professor, and the SACPCMP? It seems there is a nurse on the SACPCMP board to cover HEALTH, and a wannabe safety engineer with no notable qualifications mentioned on the SACPCMP website, to cover SAFETY.
    Reminds me of where SAIOSH and RAYSISM shares a bed (not literally implying ACHASM directors or SACPCMP councillors).
    I am forming SARCHASM, who wants to join? I give free CHAMOIS, and you can get a COUGHPROF or a ROCSPAM designation.
    Vote SARCHASM – South Africans Resisting Construction Health And Safety Madness!!!

Comments are closed.

Facebook IconLinkedInLinkedInLinkedIn
error: Contact the Cygma Group for Copyright licence.