SACPCMP registration debate continues

Can I provide my clients with a full service or not?

The debate about SACPCMP registration for construction safety practitioners has been a hot topic since promulgation of the 2014 Construction Regulations. Some are for it and some are not.

The matter of the fact remains that you have to register if you are a Health and Safety practitioner in the construction industry but there are different view points when it comes to Health and Safety consultants that are not involved in the construction industry in a full time capacity.

I asked Sheqafrica a question about safety files, risk assessments and incident accident investigations. You can read the full blog at Sheqafrica.

What is a risk assessment?

Hazard Identification and Risk Assessment (HIRA) is now generally accepted as the basis of any meaningful risk management plan of your entire business. A risk assessment forms the first two parts of your safety management system.

Before we start we need to look at a few definitions:

  • Hazard
    • The OHS Act defines a hazard as a source of or exposure to danger. It can further be said that a hazard is a condition, activity, object (material) or substance that has the ability to cause harm in certain circumstances.
  • Risk (As defined by NOSA)
    • Risk is the chance or likelihood of a hazard causing harm to a person, to property or the environment. The extend of the risk depends not only on the severity of potential harm to a person or the environment but also on other factors such as the number of people exposed, etc. Simply put: if one thinks of the hazard as that which has the potential to source harm, then the risk is the actual harm that may occur as a result.

Three of the types of risk assessments are baseline, issue-based and continuous risk assessments.

  • Baseline risk assessments:
    • The baseline risk assessment is done to determine the risk for the first time, i.e. to establish a broad-based risk profile. Depending on the results of the baseline risk assessment specific aspects or issues will be highlighted. The baseline risk assessment must be reviewed on regular intervals to re-establish the baseline profile as to minimize the risks in the organisation.
  • Issue-based risk assessments
    • This is when baseline risk assessments are assessed in far more detail using the appropriate issue-based risk assessment techniques such as HAZOP, FMEA, Fault Tree Analysis, etc.
    • An issue-based risk assessment will be performed due to highlighted aspects or issues, new processes, new machines or the ongoing risk assessments in an organisation.
  • Continuous risk assessments
    • These risk assessments are part of all forms formal and informal inspections and observations that take place daily or on regular intervals.

Make sure to read our next blog on the importance of risk assessments. Please contact us at for all of your risk assessment and Health and Safety requirements.

Safety File Index

The most confusing part part for many people when they compile a safety file for the first time is the contents and that’s why they want a safety file index.

The question that I get asked most often is for an example safety file or for a “Generic” safety file.The contents of a safety file will vary from site to site and from industry to industry. There is no general “Generic” safety file.

There are however documents in a safety file that will be in all safety files, no matter what industry you are in or what work will be performed on site. The biggest influence on the contents of a safety file is the OHS Act and Regulations and then of course the client site specifications (for construction sites).

The contents of the file and it’s index relating to the contents can become a very long and in depth list but for simplicity reasons I will give a very BASIC index example. Note that this is just for informational purposes and should only be used as a guideline.

a.Mandatory agreement
b.Emergency Plan and Procedures
c.Tax Clearance Certificate
d.Letter of Good Standing
e.Client health and safety specifications
f.SHE policy

2.    Plans (A few examples)
a.SHE plan
b.Fall protection plan
c.Emergency evacuation plan

3.    Risk assessments

4.    Legal Appointments

5.    Registers and inspections

6.    Toolbox talks (A few examples)
b.Hand Tools
c.First Aid
d.Safety Signs
e.Snake Awareness
f.Road Safety Vision
g.Living with HIV AIDS

7.    Personal
a.I.D. copies

8.    COID
a.Incident Reporting Procedure
b.Incident Recording
c.Accident / Incident Report
d.Motor Vehicle Accident Report
e.Resumption Report

9.    Acts & regulations

As I said, the list can become long and detailed. This is only an extract of an index. There are a lot of details that can only be done once an analysis of your scope of work has been done and the scope of work compared to the OHS Act & Regulations.

I hope this has helped you to gain a better understanding of the contents of a Safety File.

Please contact us, we are here to help.



What is a safety file?

You have submitted your quotation and just received the confirmation that the project is yours, maybe the excitement is even bigger because it’s the first time that you are doing a project for this client. It’s a big client and you have been trying for ages to get onto their vendor list, but the excitement is short lived, they have asked you for your safety file. Your what?

Confusion sets in

You have no idea what a safety file is or where to start. You open Google and start searching, you think this cant be so difficult, it’s probably only some type of document that they want. Then you start realizing it’s not so straightforward. You click on link after link on your search results, you read blogs, you search more and more but you cant find the quick solutions that you where hoping for. The more you search the more you get confused and the more your frustration grows. You just can’t seem to find a clear description of what a safety file is.

You are not alone

You are not the only one asking this question. Most contractors, especially the smaller contractors, have no idea what a safety file is, why it exists, what should be in it or what it is used for. Hundreds upon hundreds of contractors are in the exact same situation. Some of them due to pure ignorance, others due to a lack of knowledge.

The problem

For many years contractors, big and small, got away with presenting a safety file when they perform a job for a client. It was in general an accepted practice to quote or tender for a project, get the job and get on site and do the work. Over the years this started changing. Every day more workers got injured on sites and more fatalities occurred. The Department Of Labour simply had no option but to get more strict with the enforcement of Health And Safety Regulations.

The main contractors where the first to get up to date with their health and safety purely because the spotlight was on them and not on the smaller contractors. The result is that subcontractors in general were left uneducated regarding Health and Safety and specifically safety files.

So what is a safety file then?

In short it is a file that consists of a collection of documents regarding your business, the type of work you do and completed for that specific site, yes that’s correct, every safety file is site specific and cannot be used for all sites.

Let’s see what Legislation says. The Construction Regulations defines it as follows –  “health and safety file” means a file, or other record containing the information in writing required by these Regulations;”

In Construction Regulation 7 (1)(b) it stipulates that a principal contractor and contractor must – “open and keep on site a health and safety file, which must include all documentation required in terms of the Act and these Regulations, which must be made available on request to an inspector, the client, the client’s agent or a contractor; …”

What it comes down to

Every contractor, principal, big or small must have a completed safety file for the construction site that they are working on. It does not make a difference if you are new to contracting or have done the same work for a 100 years, whether you have 1 or 1000 employees on site. There is no legal way around it.

But what if you use subcontractors?

The same implies. They become a contractor and must have their own safety file. There is a very general misconception that you can make use of subcontractors and just slot them into your safety file as if they were your own employees, the truth is that you cannot and should not. You might get away with it a few times, until their is an incident on a site. The subcontractor is an entity on it’s own, they are not your employees.

They are not covered by your Workman’s Compensation and in most cases not by your Public Liability Insurance. In short, you are playing with the future of your business if you make use of subcontractors and they are slotted into your safety file without having any file or records of their own or even worse, You don’t even have a safety file of your own.

You can watch the video version here.

So what is in a safety file

That will be the topic of our next blog but in the meantime please contact us with all of your Health And safety queries, concerns or questions.

We are here to help.