In the construction industry, site establishment often involves critical tasks such as the installation of services, erection of fencing, and other preparatory works. While these activities are viewed as preliminary, they are, in fact, construction work as defined by South Africa’s Construction Regulations, 2014 (promulgated under the Occupational Health and Safety Act, No. 85 of 1993). Unfortunately, it is not uncommon for project managers and clients to overlook the importance of having a safety agent conduct audits during this phase. This oversight can lead to serious compliance and liability issues if contractors are injured and their safety documentation is not in order.
Site Establishment: A High-Risk Undertaking
The Construction Regulations define “construction work” as including any work in connection with:
- The construction, erection, alteration, repair, or dismantling of a structure.
- The preparation of a construction site.
- Installation of equipment or services on a site.
Clearly, activities such as fencing and service installations fall within the scope of “construction work.” These tasks pose risks to workers, including falls, electrocution, and equipment-related injuries. The Client and Principal Contractor bear legal responsibility to ensure safety measures are in place before and during these activities.
What Happens If There’s an Injury During Site Establishment?
Should a contractor get injured during site establishment and the safety file is incomplete or non-compliant, the Client could be held responsible for failing to enforce compliance. The Department of Employment and Labour may investigate and find that the Client neglected their duties under the Construction Regulations.
Why Conduct Safety Audits During Site Establishment?
- Risk Identification and Mitigation: Audits help identify risks that are often underestimated during site establishment, ensuring controls are in place before incidents occur.
- Regulatory Compliance: Regular audits demonstrate due diligence and compliance with the Construction Regulations, safeguarding the Client from legal repercussions.
- Worker Safety: Audits ensure that all workers are operating under safe conditions, reducing the likelihood of injury.
Final Thoughts
Site establishment should never be treated as a low-priority phase in terms of health and safety. Activities performed during this time are construction work and carry inherent risks. By conducting safety audits during site establishment, Clients and Principal Contractors fulfil their duties under the Construction Regulations and create a safer working environment for all involved.
Neglecting this responsibility is legally and financially risky. Proactive safety management is always the better—and legally required—approach.
Remember: Compliance isn’t just about avoiding penalties; it’s about protecting people. Let’s make every phase of construction, including site establishment, a model of safety and responsibility.
