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If you provide Health & Safety consultancy to construction companies, your clients may rely on you for everything from H&S policies and risk assessments to RAMS, training and ongoing compliance advice.
But construction presents a particular challenge.
Employees may undertake multiple activities across different sites and environments, creating competence requirements beyond their primary occupation.
No H&S consultant can reasonably be expected to specialise in every construction qualification, card scheme, training standard or occupational competence requirement.
The important thing is knowing when a client’s activities warrant a deeper competence conversation – and where to obtain specialist support when required.
Here are some of the questions worth asking when supporting construction clients.
Outsourcing H&S support does not transfer the employer’s legal responsibilities to the consultant.
External consultants can provide valuable competent advice and assistance, but the employer remains responsible for managing Health & Safety within the business.
For construction employers, there is another important distinction:
Having access to competent H&S advice isn’t the same as demonstrating the competence of the people carrying out construction work.
A company may have professionally prepared policies, RAMS, annual refresher training, industry cards and experienced employees.
But can it answer:
How do we know our workforce has the appropriate skills, knowledge, training and experience for the activities they actually undertake?
Construction competence shouldn’t be reduced to simply asking whether somebody has completed a training course.
HSE refers to the skills, knowledge, training and experience required to carry out work safely.
For organisations, competence also involves having the organisational capability necessary to fulfil their role.
That means a training matrix is useful but it doesn’t necessarily tell the whole story.
A better starting point is:
What work does this person actually undertake?
Then consider:
What are the risks?
What do they need to know or be able to do?
What training, qualifications or experience are appropriate?
How has their competence been established?
What evidence does the employer retain?
This is particularly important for multi-skilled construction workers whose responsibilities extend beyond their primary occupation.
Many construction employers provide annual refresher training covering subjects such as asbestos awareness, manual handling, slips and trips and working at height.
This can form a useful part of an employer’s H&S arrangements.
The question is whether the depth and type of training reflect the work employees actually undertake.
Two employees might both have completed working-at-height awareness. One occasionally uses a stepladder; another regularly accesses roofs, uses a harness or works from specialist access equipment.
Their competence requirements are unlikely to be identical.
Rather than simply asking:
“Have they completed their annual H&S training?”
consider:
“Does their training and competence evidence reflect what they actually do?”
This is particularly important for contractors working in existing buildings particularly when doing refurbishment and maintenance.
Joiners, maintenance workers, roofers, demolition workers, electricians, plumbers and other trades may encounter asbestos-containing materials during their work.
Asbestos awareness training is designed to help workers understand the risks and avoid disturbing asbestos.
It does not provide the competence required to intentionally undertake work with asbestos-containing materials.
For H&S consultants supporting construction clients, useful questions include:
The key question isn’t simply:
“Has everyone completed asbestos awareness?”
It is:
“What prevents an employee from unknowingly disturbing asbestos during the work they undertake?”
This is another useful area to explore with clients.
Annual refresher training is common, but that doesn’t necessarily mean repeating the same full course every 12 months is the appropriate solution.
Refresher requirements should reflect factors such as the individual’s role, exposure, existing knowledge and any changes to working practices.
For an employee regularly undertaking refurbishment work, for example, it may be more valuable to establish whether they understand the company’s actual asbestos procedures than simply confirm that another annual awareness certificate has been issued.
Training should support the safe system of work – not become a substitute for it.
Asbestos awareness is intended for people who may encounter asbestos but are expected to avoid disturbing it.
Where employees undertake activities that could intentionally disturb asbestos-containing materials, additional information, instruction and training may be required.
This is where understanding the client’s actual work becomes critical.
Don’t start with:
“What asbestos certificate do they have?”
Start with:
“What do they actually do when they encounter asbestos or asbestos-containing materials?”
The answer determines the competence requirement.
If a client’s workforce excavates, breaks ground or carries out other work where underground services may be encountered, cable avoidance and underground-service competence should be considered.
Questions might include:
This is an important distinction.
Issuing an in-house certificate isn’t automatically inappropriate.
The question is what sits behind it.
Does the employer have reasonable evidence that the person can safely undertake the activity, or does it simply have evidence that they attended some training?
“Working at Height” can cover very different activities.
Does the workforce use ladders, towers, MEWPs, harnesses, scaffolds, roof access or other specialist access systems?
Generic awareness may form part of the employer’s arrangements, but additional equipment or task-specific competence may be appropriate.
Again, start with what employees actually do, rather than the title of the course they’ve attended.
Where employees operate construction plant, consider:
This is another area where experience, training, assessment, qualifications and cards can all form different parts of the competence picture.
Lifting operations can involve several different responsibilities.
Establish who is:
Someone being competent to undertake one role doesn’t automatically demonstrate competence for another.
Understanding the individual’s actual responsibilities is therefore essential before recommending training or qualifications.
Construction workers may be exposed to silica, wood dust and other hazardous substances.
Providing RPE doesn’t, on its own, demonstrate that the respiratory risk has been adequately managed.
Industry cards can provide valuable evidence of occupational competence, qualifications or training.
But a card shouldn’t necessarily be treated as evidence of competence for everything an employee does.
An electrician, for example, may hold the appropriate ECS card for their occupation while also working at height, encountering asbestos, using RPE, working around underground services, supervising workers or penetrating fire-resisting construction.
The occupational card answers an important question.
It doesn’t automatically answer all of the others.
For H&S consultants, comparing an individual’s recognised occupation against their wider activities and responsibilities can uncover areas worth exploring.
Construction competence doesn’t stop with operatives.
Consider who is supervising workers, managing sites, coordinating contractors, planning work or taking responsibility for lifting operations, temporary works or site inspections.
Training such as SSSTS or SMSTS may be appropriate in many situations.
Occupational qualifications can provide additional evidence of competence against the role actually being undertaken, from Occupational Work Supervision and Site Supervision through to Site Management, Site Inspection and Senior Management.
The important question remains:
What is this person responsible for – and how can the employer demonstrate they are competent to fulfil that responsibility?
Construction businesses may undertake several dutyholder roles, including Contractor, Principal Contractor, Designer or Principal Designer.
Smaller contractors don’t always recognise the extent of these responsibilities.
Consider:
This is increasingly important where clients and Principal Contractors expect their supply chain to provide clearer evidence of competence.
When reviewing a construction client, consider asking:
What activities do your employees actually undertake – including activities outside their primary trade?
Could employees disturb the fabric of buildings containing asbestos, and what prevents accidental disturbance?
Who locates services and how has their competence to do so been established?
What equipment and access methods are actually being used?
Who operates plant, what categories do they use and what evidence of competence is held?
Who plans, supervises and undertakes lifting operations?
Where RPE is required, are selection, face fit, use and maintenance appropriately managed?
Do qualifications and cards reflect the work employees actually undertake?
Who supervises construction work and how is their competence demonstrated?
What dutyholder responsibilities does the business undertake and who is competent to fulfil them?
Does the business undertake specialist work requiring additional training, qualifications or competence?
And perhaps the most important question:
If the client was asked tomorrow to demonstrate the competence of a person undertaking a particular activity, what evidence could they provide?
Providing competent H&S advice doesn’t mean having to personally deliver every course, understand every CSCS card route or keep track of every construction NVQ.
Recognising when specialist input is required is part of providing good support.
Workforce Skills Support works alongside H&S consultants rather than replacing them.
Our focus is construction workforce competence, including:
We can also help employers explore relevant CITB grants and funding, where eligible.
And where something falls outside our own provision, we’ll point you towards the appropriate specialist support where we can.
For H&S consultants, the opportunity isn’t necessarily to provide more training yourself.
It is to recognise when a construction client’s activities raise a competence question that requires specialist input.
You continue to provide the wider Health & Safety support and advice your client relies upon.
We can support you with the construction-specific training, qualifications, cards and workforce competence sitting alongside it.
If you support construction businesses and have a client whose competence requirements you’re unsure about, speak to our team.
Sometimes additional training or a qualification will be appropriate. Sometimes the arrangements already in place will be sufficient. The important thing is knowing the right questions have been asked.