The construction industry is no stranger to health and safety regulations, and rightly so – ensuring safety is paramount. However, an emerging practice among some safety professionals raises serious concerns: insisting that contractors compile their safety files in a specific, often rigid format dictated by the safety professional. This practice, while seemingly well-intentioned, carries significant downsides that warrant scrutiny.
1. Is This Overreach?
Under the Construction Regulations 2014, contractors are required to maintain a safety file containing all the necessary documentation to manage health and safety on site. The regulations, however, do not specify a particular format. Contractors must ensure the file complies with legal requirements and is available for inspection, but there is no explicit legal authority granting a safety professional the right to dictate how the file should be compiled.
By insisting on a prescribed format, the safety professional may be overstepping their role, creating unnecessary administrative burdens for contractors and introducing requirements not envisaged in the law.
2. Additional Requirements = Additional Costs
If the safety professional’s preferred format was not clearly stipulated in the project’s health and safety specification or agreed upon during the tender stage, this constitutes a change in scope. Requiring the contractor to redo an entire safety file – often at the eleventh hour – is not just unreasonable but should also come at an additional cost to the client. After all, any new requirement outside the contract’s original terms is, by definition, a variation order.
Expecting contractors to absorb these costs undermines the principles of fairness and accountability in project management.
3. Project Delays and Inefficiency
Forcing contractors to redo safety documentation can lead to significant delays. Time spent reformatting and reorganising the safety file is time not spent actively managing safety on site. This administrative distraction can postpone project milestones, especially when the safety professional rejects documents repeatedly for non-compliance with arbitrary formatting preferences.
4. Impact on Safety Culture
Contractors often develop and refine their own safety file formats over time, ensuring they align with their internal processes and are practical for daily use. Introducing a completely new format disrupts this familiarity, causing frustration among staff and potentially undermining the contractor’s safety culture. Workers and supervisors may struggle to locate key documents, negatively affecting the implementation of safety practices on site.
5. Practicality vs. Aesthetics
Contractors use their safety files daily as a working tool, whereas an external safety professional typically audits the file once a month. This raises an important question: whose convenience should the file serve? Logically, the file should prioritise the needs of the contractor, who relies on it as a day-to-day safety management resource. An external safety professional’s preference for an aesthetically pleasing or standardised format should not come at the expense of functionality and practicality.
6. ISO Certification: A Barrier to Arbitrary Changes
Many contractors operate under stringent quality management systems, such as ISO 45001, which require all documentation to go through an internal approval process before changes can be made. Mandating a new format may conflict with these certification requirements, further complicating compliance. Contractors cannot simply adopt a new format overnight; doing so could jeopardise their certification and introduce risks of non-conformance.
7. Does This Actually Improve Safety?
The goal of any safety file is to enhance on-site safety by ensuring that risks are well-documented, mitigated, and monitored. However, prescribing a format does nothing to improve actual safety outcomes. Whether a document is presented in Template A or Template B is irrelevant if it contains the necessary information and is implemented effectively.
This raises a critical question: is format fetishism adding value, or is it just bureaucracy for its own sake?
8. Is This an Ego Trip?
One cannot ignore the possibility that such practices are driven by ego rather than necessity. An external safety professional who insists on their own format may believe it showcases their authority or expertise, but this attitude risks alienating contractors and creating unnecessary conflict. True leadership in health and safety involves fostering collaboration, not imposing unilateral decisions that add no real value.
Contractors should not hesitate to challenge such practices, especially when they serve no practical purpose. Clients, too, must be vigilant against allowing their safety professionals to impose additional requirements without just cause. At the end of the day, safety documentation should be about substance, not style. Let’s focus on what truly matters: creating safer workplaces, not prettier paperwork.
