Resolving Critical Safety Roles on Site
A Trusted Safety Advisor
From November 2020, Coyle Group were performing a Safety Advisor role for our customer’s Project Delivery Central team. The consultant fulfilling this role was responsible for making sure safety paperwork was in place and safety roles were appropriately appointed for customer projects according to regulation and good practice.
Whilst in this role, our consultant appointed the role of PSCS to a contractor to complete civil engineering work on a particular project in Ireland.
Spotting Role Duplication
Some months later, in June 2021, the same Coyle Group consultant was engaged on another piece of work for the same customer’s Customer Delivery department. Coincidentally, this job was on the second phase of that same project. Our consultant was working with another supervisor, who was taking on the PSCS role on the same sub-station.
Our consultant immediately identified an issue with these PSCS roles. Whilst there had been verbal agreement between the contractor and the customer supervisor to hand-over PSCS roles, there was no paperwork confirming this or communication of this change to other stakeholders with an interest in the work in this location.
It is important to have clear and singular PSCS role appointments on site, to ensure responsibility for health and safety coordination is defined and being managed by a single authority.
The Importance Of The PSCS Role
The Project Supervisor Construction Stage (PSCS) is a role that must be appointed by a client when work of a certain specification is done on a site.
This is defined in the Safety, Health and Welfare at Work (Construction) Regulations 2013. It is then the PSCS’ responsibility to fulfil safety requirements during the construction stage.
Usually there can be just one PSCS role appointed to a site, to ensure a single health and safety authority.
In some circumstances, it is possible to have two appointed PSCS roles but clear segmentation between their projects and roles must be defined in writing.
Bringing People Together To Solve The Problem
To resolve this critical issue our consultant highlighted the problem to the site’s stakeholders. She led a meeting to explain the issue and agree a solution.
Agreement was gained to terminate the contractor from the role of PSCS on the project, and to appoint the Customer Delivery supervisor as the new PSCS. Our consultant then enacted the paperwork to achieve compliance within a week.
This meant that the Customer Delivery supervisor would now be responsible for coordinating health and safety on the site.
A Safer Site And A Safer Business
In this case, Coyle Group identified and resolved a health and safety breach that would otherwise have gone unnoticed. This highlighted the risk that the same issue could be occurring on other sites.
Our consultant subsequently worked with the Project Delivery team to complete a comprehensive review of health and safety role appointments on other customer projects to check that roles were appointed to one entity alone and that documentation was up to date.
Now our customer can be assured that project roles are appointed correctly, ensuring that health and safety is being managed appropriately on site and that they are compliant with regulation.
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RIDDOR and COVID-19
Many employers are concerned about their reporting obligations for COVID-19/Coronavirus/SARS-CoV-2 under RIDDOR in the ongoing pandemic. You may be pleased to know that you do not have to report everything to the Health and Safety Executive (HSE). We'll provide more info about when, what, and how to report.
The most common concern we've seen recently from employers is whether they need to report all COVID-19 and coronavirus testing results to the HSE. The short answer is no. According to the HSE: “There is no requirement under RIDDOR (The Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013) to report incidents of disease or deaths of members of the public, patients, care home residents or service users from COVID-19. The reporting requirements relating to cases of, or deaths from, COVID-19 under RIDDOR apply only to occupational exposure, that is, as a result of a person's work.”
Generally speaking, the ordinary RIDDOR rules already cover COVID-19. You should only make a report under RIDDOR when one of the following circumstances applies:
• an accident or incident at work has or could have caused the release of coronavirus (SARS-CoV-2). (Report as Dangerous occurrence)
• a worker is diagnosed with COVID-19 due to occupational exposure. (Report as Disease)
• a worker dies because of occupational coronavirus exposure. (Report as Work-related death due to exposure to a biological agent)
The bottom line is that existing rules cover most COVID-19 measures, and most of the COVID-19 guidance comes from public health authorities rather than the HSE. The environment remains chaotic, but you can minimize your legal exposure by continuing your existing compliance steps. This will include communicating with your insurer about risks, following public health guidance, and communicating regularly with your workers or unions on any of their concerns.
© Gavin Coyle, 2021