Our company has been actively conducting close to 1000 site audits per month, predominantly within the construction industry. Recently, we’ve encountered a requirement from clients, particularly municipalities, stipulating that only Professional Construction Health and Safety Agents (PrCHSA) are permitted to carry out safety audits on their sites. While we respect our clients’ prerogative, we feel compelled to express our concerns regarding this directive for the following reasons:

Industry Norm:

Historically, it has been standard practice within the industry for PrCHSA’s to oversee stages 1-4 of projects, with Certified Health and Safety Managers (CHSMs) conducting physical site audits from stage 5 onwards. This approach ensures a collaborative effort where PrCHSA’s manage the project while CHSMs perform audits under their supervision. This division of responsibilities has been effective in maintaining compliance and safety standards on construction sites.

Resource Availability and Reasonable Man Principle:

The implementation of compulsory professional registration in the built environment, particularly within the Construction Regulations of 2014, has led to a limited pool of registered PrCHSA’s. Over a period of nine years, only approximately 150 individuals have been registered as PrCHSA’s. This raises concerns about the industry’s capacity to meet the demand for site audits if only a small number of individuals are authorized to conduct them.

With major entities like SANRAL managing over 500 ongoing projects, the restriction to PrCHSA’s could potentially result in project delays and resource constraints. Furthermore, some PrCHSA’s may be permanently employed by specific organizations, limiting their availability to accommodate external audits.


The restriction to only 150 individuals for site audits raises significant concerns regarding potential cost escalation within the industry. With a limited pool of PrCHSA’s available to undertake these audits, competition for their services may intensify, leading to bidding wars driven by supply and demand dynamics. Consequently, this could result in inflated project costs, placing financial strain on both clients and contractors alike.

Job losses

Another pressing concern is the possibility of job losses stemming from the limitation in the capacity of PrCHSA’s. If projects are unable to commence due to the scarcity of authorized auditors, construction companies may be forced to scale back operations, leading to workforce reductions. This scenario not only impacts job security but also has broader implications for the industry’s economic stability and employment rates.

Professional development

The restriction also presents challenges for the career progression of Health and Safety Managers (CHSMs). To qualify as a PrCHSA, individuals must demonstrate experience in stages 1-4 of construction projects. However, if CHSMs are barred from participating in these early project stages, they are effectively hindered from gaining the necessary experience to advance their careers. This limitation stifles professional development opportunities and undermines the growth potential of aspiring safety professionals.

Construction Regulations

The footnote to the Construction Regulations (CR) affirms that a client has the prerogative to appoint either a Professional Construction Health and Safety Agent (PrCHSA) or a Certified Health and Safety Manager (CHSM). Our stance is grounded in the belief that clients bear ultimate responsibility for site safety and should have the autonomy to select a safety professional based on qualifications and experience. It’s conceivable that a registered PrCHSA may lack experience in a specific field, whereas a seasoned manager may possess decades of relevant expertise. Empowering clients to make informed decisions after evaluating CVs and experience fosters a more tailored and effective approach to site safety.


Our position on this matter is informed by legal considerations outlined in the Project Construction Management Professions Act 48 of 2000. Sections 26(3) and 26(4) of the Act assert that individuals cannot be prohibited from performing work if they operate under the direction, supervision, control, or in association with a registered professional entitled to undertake such work. Therefore, the notion that only PrCHSA’s are authorized to conduct site audits may stem from a document released by the Department of Public Works (DPW) outlining the scope of services for professionals registered with the South African Council for the Project and Construction Management Professions (SACPCMP). However, it’s essential to recognize that legal provisions allow for flexibility and collaboration between registered professionals to ensure the effective execution of safety responsibilities on construction sites.

In conclusion, the challenges posed by the restriction on-site audits to only Professional Construction Health and Safety Agents (PrCHSA’s) underscore the need for a balanced and pragmatic approach to regulatory compliance in the construction industry. While safety standards must be upheld, it is imperative to consider the broader implications, including cost escalation, potential job losses, and limitations on professional development. Empowering clients to choose safety professionals based on qualifications and experience, in alignment with legal provisions, can enhance efficiency and effectiveness while fostering a culture of safety and collaboration. Moving forward, collaborative efforts between regulatory bodies, industry stakeholders, and professionals are essential to ensure that safety measures are robust, practical, and conducive to sustainable growth within the construction sector.