Health & Safety Requirements for Sub-Contractors

Sub-contractors are coming under ever increasing pressure to demonstrate their competence and compliance with the requirements of health and safety legislative in the construction industry. In part, this is coming from the HSE’s initiative to see a reduction of accident rates in the industry which, unfortunately, appears to be on the increase once again. Pressure is also coming from within the construction industry itself, principally from the Main Contractors’ Group (MCG) that is seeking improvements on a number of fronts.

Main Contractors' Group

The MCG was established in 1996 to represent the interests of the largest UK construction companies. Its 19 members carry out more than £20 billion worth of construction work each year. They have committed themselves to operating construction sites that are safe and free from health hazards for construction workers and members of the public. Specifically, they have committed to:

10% year-on-year reduction in reportable accidents and incidents.
10% year-on-year reduction in work related ill health.
Site specific induction process before anyone is allowed to work on site.
Worker consultation on health and safety matters.
Best practice workshops on health and safety.
Published annual safety performance.

As might be expected, to achieve these aims, main contractors are demanding more stringent standards of health and safety when selecting sub-contractors. As leading consultants in Construction Health and Safety, we have been observing increasing pressure on sub-contractors to be fully compliant with health and safety legislation. Clear evidence of adherence to the requirements of the Health and Safety at Work Act, along with its associated Regulations and Codes of Practice, has become a primary requirement for sub-contractors.

General Application

Whilst in this article we are concentrating on the construction industry, these demands are spreading so that all organisations that are bidding for sub-contract work are increasingly being asked to demonstrate that they have robust health and safety management in place.

Checklist of Requirements

For an idea of what is required, we have listed the basic checks that main contractors are applying in the building industry

Organization and Arrangement
You will need to provide the following:
- Copy of your Health and Safety Policy.
- Name, qualifications and contact details of your health and safety advisor.
- Name and contact details of your Director/Manager directly responsible for health and safety matters.
- Name of your Manager/Supervisor responsible for health and safety on site.
Risk Assessments, Safe Systems of Work & Method Statements
- Risk assessments for the work for which you are responsible, along with safe systems of work as appropriate.
- Copy of the Temporary Works proposals and design calculations where temporary works are involved (below or above ground).
- COSHH Risk Assessments.
Competence & Training
- Evidence of competence and training for managers, supervisors, trades and operatives, in accordance with relevant registration schemes.
- Evidence of project specific training and competencies.
Plant and Equipment
- Inspection certification for plant and equipment.
- Evidence of testing (3 monthly) of electrically operated portable tools, which are normally restricted to 110volts.
- Recognition of your responsibility under the Provision & Use of Work Equipment Regulations (PUWER).
- Scaffolding, access systems, mobile towers, etc erected by competent trained personnel in accordance with Construction Industry Scaffolders’ Record Scheme (CISRS) where appropriate.
Cooperation, Coordination & Communication
This aspect covers a whole range of activities about which the Main Contractors will require clear assurances, such as:
- Compliance with the principal contractor’s coordination and communication procedures.
- Induction training, toolbox talks and provision of information on all matters likely to cause danger
- Control over numbers of personnel on site at all times
- Compliance by all personnel with "Site Rules".
- Consultation arrangements with all levels of the workforce
- Immediate reporting of accidents, near misses, incidents of ill health etc. to the principal contractor.
- Provision of relevant information for inclusion in the Health and Safety File.
- Strict disciplinary procedures for non-compliance with safety requirements.
Health & Welfare
- Provision of adequate and suitable welfare facilities
- Disciplinary procedures to manage abuse of drugs and alcohol on site and to control incidents of violent or threatening behaviour
- Compliance with Working Time Regulations.
Young Persons
- Training, instruction and supervision arrangement for young persons on site
- Prohibition of persons under 16 years of age on site without specific authorisation.
Notification
Specific notification and permission must normally be obtained for:
- Work to be undertaken outside normal working hours, including weekends.
- Sub-letting any part of the work packages.
- Individuals on site who have communication difficulties. Evidence must be provided that health and safety management issues for such persons have been adequately addressed

The list of requirements has been abbreviated somewhat for inclusion in this newsletter and, of course, it is specific to the construction industry. However, it should be sufficient to provide a good indicator of the scrutiny sub-contractors can expect in future when bidding for work so there has never been a better time to get your health and safety house in order.

Contact EDP HS&E Consultants for all your health, safety and environment needs. We can check your current arrangements and advise you about any changes or improvements you need to make.

To discuss your requirements, without any obligation on your part, please gives us a call on 01744 766000 or complete the Enquiry Form on our website.

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