Planning your Health, Safety and Environment file

One of the banes in the lives of contractors and people employing contractors is the “Health, Safety and Environment file” that the law requires.

This file is a legal agreement between the contractor and the customer. It is called a “File” because the paper required will not fit into a single document. The last thing you want is a contractor’s worker to be injured or killed on your premises and then have to argue with the Department of Labour, or the police, about who is responsible.

Like insurance policies, no one cares if the policy (in this case, the file) is in place, or up to date, until something goes wrong. Then everyone cares. (Speaking of insurance companies, they are quick to say, “I’m sorry, but we cannot pay your claim as you were breaking the law at the time of the incident,” For example; my local fire department told me of a company that had had a fire. The insurance company tried to get the fire department to say that the company was breaking the law by having pallets stacked too close to the wall of the building that burnt. The pallets had absolutely nothing to do with the fire.) The contents, or lack of contents, of the Health, Safety and Environment file could lead to insurance companies being able to reject claims.

DISCLAIMER: I am not a lawyer, nor do I know your business, so the contents of the Health, Safety and Environment file below is there for illustrative purposes only. You may need more or less than is suggested in the list below.

Contents of the Health, Safety and Environment file

Here are my suggested minimum contents of the Health, Safety and Environment file. The order is not important – make it work for you. I suggest that if some of these items do not apply to you, you list them anyway and say they do not apply. For example, I would say, “Fall Protection Plan, not applicable as we are not working at heights.”

1. Fall Protection Plan
2. Scaffolding Plan
   
   
3. General Administrative Requirements

• Notification To The Department Of Labour (Within 7 days of award of contract where applicable)
• Letter Of Good Standing with the Department of labour
• Tax Clearance Certificate
• Public Liability Insurance Certificates
• Company Safety And Environmental Policy (Signed By CEO)
• Schedule D Notice where applicable

4. Appointment Documents

• Organogram for project (personnel working on specific project)
• All applicable appointments in terms of the Occupational Health and Safety Ac, including appointments as required in the Construction Regulations
• Copies of relevant training certificates. Attach these behind appointment letters where applicable
  
  

5. Risk Assessments

• Hazard Identification and Risk Assessments for project – baseline and issue based. Do this after a visit to the customer’s site, and preferably with the customer. I will write a separate article on Hazard Identification and Risk assessment
• Site risk register. This follows from the Risk Assessment
• Planned job observations
• HIRA Training attendance documents
  
  

6. Training

• Safety induction- proof on file
• Site safety rules- proof on file
• Training attendance registers
• Training certificates
• Toolbox talks and registers/ proof of training
  
  

7. Health and Safety Committees

• Agenda for meetings
• Minutes for meetings
• Attendance registers
• Minutes of daily start up meetings (where applicable)
  
  

8. Registers and Checklists
   (as a minimum, all relevant and applicable registers and checklists to be put into place prior to commencement)

• Start-up checklists if you are running equipment
• Tools and equipment
• Personal protective equipment
• Ladders and scaffolding, if used
• Vehicle, if used
• Lock out
• Electrical
• Portable electrical equipment
• Environmental
• Incident register
• First aid register
  
  

9. Hazardous Chemical Substances

• List of all chemicals used on site, including paints, thinners etc.
• Hazardous chemical substances risk register for all chemicals used on site (this includes cleaners, oils, degreasers, oil and water based paints).
• Complete material safety data sheets for all chemicals used on site

10. Incident Management

Incident reporting procedure and investigation reports

• Employers report of an accident
• Resumption Report
• Annexure 1 and company investigation forms

10. Emergency Planning

• Emergency plan
• Evacuation procedures
• Evacuation alarms (where applicable)
• Emergency planning (for example, what to do if a person falls while still suspended to safety harness)
• Emergency contact numbers
• Contractors details list with names and contact numbers

11. Environmental

Environmental Impact Assessment studies. I usually do this at the same time as the Hazard and risk Assessment

• Risk assessment. This follows the study above
• Procedure for disposal of chemicals
• Certificates of safe disposal where applicable
  
  

12. Personnel Record and Medicals

• List of all contractor personnel working on site for project
• Certificates indicating fitness to work, risk based medicals
• If employees are working at heights, medical certificates to indicate that employees are fit to work at heights.
  
  

13. Contractors and Subcontractors

• List of all contractors and sub-contractors working on site, including copies of identification documents
• Contact details for all contractors and subcontractors
• Mandatory agreements between contractor and sub-contractors
  
  

14. Time Keeping

• The contractor will provide a weekly time sheet indicating hours worked by all contractor personnel and sub-contractors. Keep this in the file
  
  

15. Audit Schedule

• Audit schedule and audits conducted
• Audit reports (weekly or monthly where applicable)
  
  

This is a formidable list, but it does get easier after you have done it a few times. Some items repeat themselves.

Author

Mike Morrison