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For many small and medium-sized construction businesses, employing a full internal Health & Safety team isn’t practical.
Instead, they rely on an external Health & Safety consultant to provide competent advice and support with areas such as H&S policies, risk assessments, RAMS, training and ongoing compliance.
This can work extremely well.
But there is an important distinction every construction employer should understand:
You can outsource Health & Safety support. You cannot outsource your responsibility for managing Health & Safety within your business.
There is also another question worth considering:
Does the support you receive cover the competence requirements arising from everything your workforce actually does?
Your external H&S consultant can provide valuable expertise, advice and assistance.
However, responsibility for managing Health & Safety remains with the employer.
That means appointing a consultant shouldn’t become a reason to assume:
“Health & Safety is covered.”
Your consultant can only advise effectively based on their knowledge of your business, the work you undertake and their own areas of expertise.
Construction is particularly challenging because one workforce can undertake numerous activities requiring different levels of training, knowledge, experience and competence.
The question for employers is therefore not whether you have an H&S consultant.
It is:
How do you satisfy yourself that the arrangements they support you with reflect the work your people actually undertake?
Having an annually reviewed H&S policy is important.
So are suitable risk assessments, method statements and procedures.
But documentation alone doesn’t demonstrate that the people undertaking the work are competent to do it.
Similarly, a good accident record doesn’t necessarily provide that evidence.
A business may have operated for years without a serious incident.
But if you were audited by a client tomorrow – or if something did happen – could you demonstrate why you considered the person undertaking that particular activity competent?
Experience may be part of the answer.
Depending on the activity, training, practical assessment, qualifications, cards, supervision and other evidence may also be relevant.
This is one of the simplest checks a construction employer can make.
Don’t just look at:
Carpenter – CSCS blue skilled Worker card – Asbestos Awareness – Manual Handling – Working at Height.
Look at the person’s actual working day.
Do they:
Their primary occupation may only tell you part of the story.
Workforce competence should reflect the activities and responsibilities people actually undertake.
The following areas provide a useful starting point when reviewing your arrangements with an external H&S consultant.
If employees work on buildings constructed before 2000 – particularly refurbishment, maintenance and installation work – asbestos should be an important consideration.
Asbestos awareness helps workers recognise the risks and understand how to avoid disturbing asbestos.
But ask what happens in practice.
An annual asbestos-awareness certificate is useful evidence of training.
But the bigger question is:
What prevents one of your employees from unknowingly disturbing asbestos tomorrow?
If your workforce excavates, breaks ground, drills or undertakes work where underground services could be encountered, consider who is responsible for locating them.
Ask:
Don’t simply ask whether somebody has a CAT & Genny certificate.
Ask what evidence of competence sits behind it.
Working at height can mean anything from occasionally using a stepladder to accessing roofs or using harnesses, towers and specialist access equipment.
Your requirements should reflect what people actually do.
If “Working at Height” appears on your annual refresher programme, ask whether that adequately addresses the equipment and activities employees encounter in practice.
If employees operate plant, establish:
A spreadsheet containing card expiry dates is useful.
A system that also identifies what people operate and whether their competence remains appropriate is considerably more valuable.
Don’t treat “lifting” as a single competence.
Different people may be responsible for:
Make sure competence reflects the responsibility the individual actually holds.
Where workers are exposed to silica, wood dust or other hazardous substances, suitable controls should be in place.
Where RPE forms part of those controls, consider selection, face-fit testing, correct use, checks and maintenance.
The question isn’t simply:
“Have we supplied masks?”
It’s whether the risk has been appropriately assessed and controlled and employees understand how to use the protection provided.
Industry cards can provide important evidence of occupational competence.
But don’t assume one card demonstrates competence across every activity an employee undertakes.
An electrician may hold the correct ECS card but also work at height, encounter asbestos, use RPE, work around underground services or supervise other employees.
A CSCS card, ECS card, NPORS card or other industry card should therefore form part of the competence picture rather than automatically being treated as the whole picture.
Competence requirements don’t stop with operatives.
Who within your business:
Training such as SSSTS or SMSTS may be relevant, but occupational qualifications can also provide evidence of competence against the role someone actually performs.
Ask the same question of managers that you ask of operatives:
What are they responsible for, and how can we demonstrate they’re competent to do it?
Smaller construction businesses can sometimes underestimate the roles they undertake.
Depending on the project, you may be acting as a Contractor, Principal Contractor, Designer or Principal Designer.
Ask:
Don’t assume these questions are automatically answered because an external consultant maintains your H&S documentation.
Discuss them with your consultant.
If you rely heavily on an external H&S consultant, try working through these questions together.
Look beyond job titles and identify the activities employees regularly undertake.
Don’t limit the review to subjects already appearing on your training matrix.
Consider skills, knowledge, training and experience – not simply course attendance.
Is it based on experience, training, practical assessment, qualifications, cards or a combination?
If a client, Principal Contractor or regulator asked, what could you demonstrate?
Particularly consider multi-skilled workers, supervisors and people whose responsibilities have developed over time.
Think about asbestos, underground services, plant, lifting, work at height, RPE, temporary works, passive fire and other activities relevant to your work.
Don’t focus solely on operatives.
And can you demonstrate the competence of the people fulfilling them?
Not simply:
“When was our H&S policy last updated?”
But:
“When did we last review what our workforce actually does and whether our competence arrangements still reflect it?”
None of this means an outsourced H&S consultant isn’t providing a good service.
In fact, these are exactly the conversations worth having with them.
Ask your consultant:
“When we review our Health & Safety arrangements, are we also reviewing workforce competence against the construction activities our people actually undertake?”
If they are, great.
If some areas sit outside their specialist expertise, that doesn’t mean you need to replace them.
It may simply mean bringing in additional construction-specific support.
At Workforce Skills Support, we regularly work with construction employers that already have internal or external H&S support.
We’re not looking to replace that relationship.
Our role is different.
We support employers with the construction-specific workforce competence sitting alongside their wider H&S arrangements, including:
Where relevant, we can also help identify CITB grants and funding available to support workforce development.
And where a requirement sits outside our provision, we’ll point you towards appropriate specialist support where we can.
Outsourcing Health & Safety can provide smaller construction businesses with access to expertise they couldn’t justify employing internally.
But appointing a consultant shouldn’t mean stepping away from the conversation.
The employer remains responsible.
Your H&S consultant can help you manage that responsibility.
A construction workforce competence partner can complement that support by helping you understand whether the training, qualifications, cards and competence evidence within your workforce reflect the work you’re actually asking people to undertake.
The starting point is a simple question:
If we were asked tomorrow to demonstrate that our people are competent for the work they undertake, how confident are we in the answer?
If you’re unsure, contact us and we can help you review the picture and identify where there are genuine gaps – and where what you already have in place is sufficient.