The Importance of a Safety File – A safety file is a record of information that focuses on health and safety management on various construction sites. It is specifically aimed at both the contractors and sub-contractors appointed to the site. The main purpose of safety files is to provide training and information to the employees and provide compliance with the Occupational Health and Safety Act and Regulations.
Each contractor, as well as subcontractor, must have a safety file which is always available, as stipulated in the Occupational Health and Safety Act (85 of 1993) along with the Construction Regulations (2014).
According to both the Occupational Health and Safety Act as well as the Construction Regulations, the following is applicable:
- Construction Regulation 3(6) – The client (employer) must ensure that the principal contractor keeps a copy of the construction work permit contemplated as per sub-regulation (1) in the Occupational Health and Safety file for inspection by an inspector, the client, an authorized agent of the client, or an employee.
- Construction Regulation 5(1)(s) – The client (employer) must ensure that the health and safety file as per regulation 7(1)(b) is kept and maintained by the principal contractor.
- Construction Regulation 7(1)(b) – The principal contractor must open and keep on-site health and safety file, which must include all documentation required, in terms of the Act and these regulations, which must be made available upon request to an inspector, the client, an agent of the client, or a contractor.
- In addition, the health and safety file must be maintained by safety personnel on-site and audited by a person who has been deemed competent.
A Safety File could be your worst enemy as most people would have you believe, however it’s actually your best friend in the worst situations. Proof of evidence is a very important part of any business’s Occupational Health and Safety Management System and is the best defense regarding liability and vicarious liability.
As per the Occupational Health and Safety Act a book, record or other documents needs to be kept. This can be done by paper records (Health and Safety File) or even an OHS Management software .
If you need to use the latter, the following items are a good place to start in supplying an inspector, client or auditor with the following documentation:
Site Specific Health and Safety File:
Your safety file and all documents within needs to be specific to the site and the specific task at hand.
Always have an index that clearly states the content of your file. This makes it easier for a person looking for specific documentation to find what they need. There are 3 very important things to remember, your health and safety file is a legal document, a public document and Auditors love an Index that makes it easy to find the correct document.
Client Safety Specification:
Depending on your business and scope of work, your client needs to issue you with a Safety Specification. This document will determine what your Health and Safety File needs to consist of and should be the foundation of the file. Also, with this document the client can request more that is required by law as it is then seen as best practice. What’s good for the goose is good for the gander.
Scope of Work:
State your exact scope of work in this document. An overview of your business is fine for internal use, however this needs to be task or job specific if being used on construction sites and performing other specialised work.
Letter of Good Standing:
Ensure that you have a Letter of Good Standing with the Workman’s Compensation Commission. Always! Think of this as insurance to assist you in the event of an injury on duty. This piece of paper can save your business a lot of money.
The document on which your whole OHS system is built on, is your Baseline Risk Assessment. This should always be easily available for any person to read and evidence of the communication to all employees of your business.
We all have responsibilities towards Occupational Health and Safety and your legal appointments are appointments, required by law, to ensure that commitment is made in writing. This will include, but not limited to, appointments for a 16.1, 16.2, Safety Officer, Risk Assessor and Incident Investigator etc.
Inventory needs to be kept on all items used for a task. Registers will assist you in keeping track of tools, knowing what Hazardous Substances are on site and how they are controlled. This can even assist in preventing incidents by identifying faulty equipment and having it repaired or even removed from the work area.
Proof of competency:
Always have proof of competency in the file for the staff on site. This includes, but is not limited to training certificates for First Aid, Fire Fighting, SHE Representative, Scaffold Erector etc. These can also be needed as proof to some competency based legal appointments.
Make sure you have a copy of all your staff’s ID document and a W.Cl.2 form in your file. This is your two main documents in the event of an IOD and even hospital treatment. Being prepared with these documents can assist the process in getting your staff faster medical attention in some cases.
These are only but a few items required in your Safety File and to ensure that you are covering all your basis as an employer, employee and/or client. Always remember that these documents are there to protect people and it is there to maintain record of what we have done to ensure a safe and healthy work environment.