Construction health and safety specification should inform OHS plans, but clients, project managers and designers lack competence to compile the specs.
In practice, among better performing construction contractors, H&S specifications merely repeat Construction Regulations phrases, found Prof John Smallwood of the Department of Construction Management at the Nelson Mandela Metropolitan University, in a scientific survey.
Construction H&S specifications are marginally project specific, relatively lengthy, regurgitate the Construction Regulations, and contain more client than designer H&S information, explains Prof Smallwood in a paper presented at The Second Built Environment Conference and first posted on the Kwazulu Natal Master Builders website.
Furthermore, designers are not following a hierarchy of control in terms of mitigating hazards and reducing risk, however, H&S specifications are seen as ‘a useful form of reference’.
Construction clients, designers and project managers and even H&S consultants, are generally incapable of compiling H&S specifications.
Part of the problem is that Construction Regulations do not state the specific nature and content of H&S specifications, however, they imply the requirements of various regulations on what ideally should be included.
What contractors say
Contractors agree that cost, quality, and time are more important than H&S.
In practice, H&S specifications are only marginally project specific, and relatively lengthy, implying that they restate legislation.
Contractors are expected to provide H&S plans when inappropriate H&S specifications are provided.
Information in H&S specifications is more client based than designer based.
H&S specification recommendations
Prof Smallwood recommends that Construction Regulations should be amended, to schedule the nature and contents of H&S specifications.
Tertiary education of project managers and designers should address construction H&S, and include an H&S design module.
Labour OH&S inspectors should conduct focused inspections on H&S specifications, and visit design practices to determine the extent of design hazard identification and risk assessment.
Occupational H&S lacking
The Construction Regulations of 2003 require that clients provide principal contractors (PCs) with an H&S specification. They also require a range of H&S related designer interventions and outputs, to be formally communicated. These requirements may not be explicit with respect to the contents of H&S specifications, but they are implicit and allude to what should be included, among other, residual risk.
Construction industry bodies recognise the need for consideration of H&S during design and integration of design and construction H&S.
Construction Regulations refer to H&S requirements only in the definition of an H&S specification, as opposed to prescribed or recommended content.
SA Construction Regulations are based on European Directive 92/57, which also inspired legislation in the European Union and the UK.
Worldwide, architects and engineers consider client and end user ergonomics and H&S in designs, but disregard opportunities to improve occupational health and safety of construction workers.
H&S design is a familiar concept to occupational hygienists, who use engineering controls to reduce exposure and other hazards and risks.
Designers influence pre-planned Health and Safety
Designers dictate the configuration and components of a facility by design documents, as well as design specific, supervisory, and administrative interventions.
Design specific interventions include concept design; general design; selection of type of structural frame; site location; site coverage; details; method of fixing, and specification of materials and finishes, as Prof Smallwood had found in earlier research work.
Designers influence pre-planned H&S. Pre-planning identifies ingredients of and resources required for H&S programmes.
SA construction legislation
Prior to the promulgation of the Construction Regulations, designers were required to address H&S in terms of Section 10 of the Occupational Health and Safety Act to ensure that every ‘article’ is safe and without risks to health.
Construction Regulations schedule requirements with respect to clients, designers, and contractors, which requirements have implications for H&S specifications.
Construction client duties include:
• Prepare H&S specifications for the construction work. Given that designers may specify materials that are hazardous due to the non-availability of alternative non-hazardous substance containing materials, or require hazardous processes, for which there are no alternatives, an H&S specification constitutes the appropriate medium in which to record the hazards.
• Ensure that principal contractors (PCs) have made provision for H&S costs in their tenders. A design may require a specific method and sequence of construction as scheduled by the designer, and therefore the designer may need to assess the contractors’ financial provision at tender or bidding stage. An H&S specification constitutes the appropriate medium in which to record such a specific method and sequence of construction.
• Provide PCs with any information that might affect H&S. An H&S specification constitutes the appropriate medium in which to record say the actual position of a high voltage cable.
Construction designer duties include:
• Make available all relevant information about the design such as the soil investigation report; design loadings of the structure, and methods and sequence of construction. The rationale for the latter being that a design may require a method and sequence of construction, which is hazardous and which cannot be averted, in which case the risk can be mitigated through specific interventions. However, the intention of this is that designers deliberate a design in terms of the hazards and the risk. The H&S specification constitutes the appropriate medium in which to record such H&S information.
• Inform principal contractors of any known or anticipated dangers or hazards or special measures required for the safe execution of the works – the high voltage cable referred to above is an example. The H&S specification constitutes the appropriate medium in which to record such H&S information.
• Modify the design or make use of substitute materials where the design necessitates the use of dangerous structural or other procedures or materials hazardous to H&S. Should designers not be able to substitute materials or amend the design, then they should record the residual risk – the H&S specification constitutes the appropriate medium in which to record such risk.
UK requires planning supervisor
Key differences between UK Construction (Design and Management) Regulations, and SA Construction Regulations, is that the UK requires appointment of a planning supervisor to integrate design and construction relative to H&S, and ensure that a pre-tender stage H&S plan is produced (at the time of presentation of this paper).
Pre-tender H&S plans are continually developed to outline hazards and risks and be circulated with tender documents.
UK planning supervisors are not required to produce pre-tender stage H&S plans, but may well do so, including;
• Client H&S stipulations, H&S goals, management arrangements, and liaison arrangements.
• Significant constraints or other hazards from the existing site or neighbourhood such as asbestos or contaminated land.
• Significant hazards which the designers was unable to avoid, and the precautions suggested for dealing with them.
• Significant assumptions made by the designer regarding work methods, sequences, and the related precautions.
In the SA Construction Regulations, H&S Specifications are the equivalent of the UK pre-tender stage H&S plan.
Only 59% of South African construction projects provide H&S specifications. H&S specifications are more non-specific than project specific. The length of H&S specifications provided, ranges from one to in excess of fifty-one pages.
Issues addressed ‘sometimes to often / often’ include daily removal of waste, security cards, client specific H&S requirements like permit to work procedures, and existing services like high voltage cables.
Construction H&S issues addressed ‘rarely to sometimes / sometimes’:
• Client restrictions, like traffic, that may have implications in terms of resources and budgeting and therefore need to be communicated;
• Environmental hazards e.g. contaminated ground: contractors cannot be expected to be knowledgeable of such a situation;
• Client’s activities e.g. sewerage works: certain activities may have health and / or safety implications;
• Details of existing structures e.g. fragile materials: certain elements of existing structures may constitute a hazard;
• ‘Designer’ design and construction method statements e.g. reference to temporary works required: this is a specific requirement in terms of Regulation 9 ‘Structures’ of the Construction Regulations. Furthermore, the integration of design and construction complements H&S;
• H&S file e.g. format and frequency of amendment: the requirements may have implications in terms of resources and budgeting and therefore need to be communicated;
• Project location details e.g. adjoining structures or geographical features: these impact on the deployment of plant and equipment;
• Health hazards e.g. sewerage works: the hazards may have implications in terms of resources and budgeting and therefore need to be communicated;
• Materials containing hazardous chemical substances (HCSs): the presence of HCSs in many materials, and the lack of focus on the health component of H&S;
• Geo-technical reports: incidence of trench collapses;
• Design principles and assumptions e.g. stages of instability: incidence of structures collapsing, and
• Permissible design loadings for stages of structures: incidence of structures collapsing.
This report is an extract from a referenced paper presented at an SA Built Environment Conference, and was first posted on the Kwazulu Natal Master Builders website.
PHOTO; Prof John Smallwood is at the Department of Construction Management at the Nelson Mandela Metropolitan University.