AF1 Notification to the HSA: When Is It Required and How to Submit It

When must you notify the HSA before starting a construction project in Ireland? This guide explains the AF1 notification requirement, who must submit it,...

One of the most commonly overlooked legal requirements in Irish construction is the obligation to notify the Health and Safety Authority (HSA) before work begins on certain projects. Known as the AF1 notification (or preliminary notification), this requirement catches many contractors and clients off guard, particularly on smaller projects where the need for formal safety appointments is not always obvious. Failure to notify the HSA when required is a criminal offence. This article explains exactly when the obligation arises, who is responsible for submitting the notification, what information is required, and how to submit it correctly. ## What Is the AF1 Notification? The AF1 notification is a preliminary notification to the HSA that a construction project is about to begin. It is required under Regulation 7 of the Safety, Health and Welfare at Work (Construction) Regulations 2013, and it must be submitted before work commences on qualifying projects. The notification is submitted online through the HSA's website. It provides the HSA with basic information about the project, including its location, the client, the PSDP and PSCS appointments, and the anticipated duration and scale of the work. This information allows the HSA to plan its inspection activity and to identify projects that may warrant closer scrutiny. ## When Is the AF1 Notification Required? The notification requirement is triggered when a project meets any one of the following criteria: **Duration:** The construction phase will last more than 30 working days, with more than 20 workers working simultaneously at any point. **Volume:** The construction work will involve more than 500 person-days of work. **Particular risks:** The project involves work that exposes workers to particular risks, as listed in Schedule 1 of the Construction Regulations 2013. These include work involving a risk of burial under earthfalls, work near high-voltage power lines, work involving a risk of drowning, work in compressed air, work involving explosives, and work involving a risk of falling from height where the risk is particularly aggravated by the nature of the work or the processes used. In practice, most medium and large construction projects in Ireland will meet the duration or volume thresholds. Even smaller projects may trigger the notification requirement if they involve Schedule 1 risks. ## Who Is Responsible for Submitting the AF1? The obligation to submit the AF1 notification rests with the **Project Supervisor for the Design Process (PSDP)**. The PSDP must submit the notification before construction work commences. However, the underlying obligation to ensure that the notification is submitted rests with the **Client**. The Client is responsible for appointing a competent PSDP and for ensuring that the PSDP discharges their duties, including the notification requirement. If the PSDP fails to submit the notification, the Client may also be exposed to liability. This is an important point for clients who appoint a PSDP and then assume that all regulatory requirements are being handled. You should confirm with your PSDP that the AF1 has been submitted before work begins, and retain a copy of the confirmation. ## What Information Is Required? The AF1 notification requires the following information: | Field | Details Required | |---|---| | Project description | Brief description of the construction work | | Site address | Full address of the construction site | | Client details | Name, address, and contact details of the client | | PSDP details | Name, address, and contact details of the appointed PSDP | | PSCS details | Name, address, and contact details of the appointed PSCS (if appointed at the time of notification) | | Anticipated start date | The date on which construction work is expected to begin | | Anticipated duration | The expected duration of the construction phase | | Maximum number of workers | The maximum number of workers expected to be on site simultaneously | | Number of contractors | The number of contractors expected to be involved | If the PSCS has not yet been appointed at the time of the initial notification, the notification must be updated as soon as the appointment is made. ## How to Submit the AF1 Notification The AF1 notification is submitted online through the HSA's website at hsa.ie. The process is straightforward: 1. Go to the HSA website and navigate to the construction section 2. Select "Notify the HSA of a Construction Project" 3. Complete the online form with the required information 4. Submit the form and retain the confirmation reference number The notification should be submitted as early as possible before work begins. There is no specified minimum notice period in the regulations, but the HSA expects to receive the notification before construction commences, not after. A copy of the notification (or a notice derived from it) must be displayed at the construction site in a legible and visible manner. This is typically done by printing the confirmation and posting it in the site office or at the site entrance. ## Common Mistakes to Avoid **Assuming the notification is not required for smaller projects.** The thresholds are lower than many contractors expect. A project lasting more than 30 working days with more than 20 workers working simultaneously will trigger the requirement, even if the overall scale of the project is modest. **Failing to update the notification.** If the PSCS was not appointed at the time of the initial notification, the notification must be updated when the appointment is made. Similarly, if the project scope changes significantly (for example, if the duration extends beyond the original estimate), the notification should be reviewed. **Not displaying the notification on site.** The requirement to display the notification (or a derived notice) at the site is a separate obligation from the requirement to submit it. Both must be complied with. **Treating the notification as a one-off administrative task.** The AF1 notification is the starting point for the regulatory framework that applies to the project. It signals to the HSA that the project exists and that the client has appointed the required duty holders. The underlying obligations (competent PSDP and PSCS appointments, Construction Stage Safety and Health Plan, etc.) must be in place and maintained throughout the project. ## The Relationship Between the AF1 and the PSDP/PSCS Appointments The AF1 notification and the PSDP/PSCS appointments are closely linked. The notification cannot be submitted without identifying the PSDP, and the PSDP cannot be identified without having been appointed. This means that the PSDP appointment must be made before work begins on qualifying projects. The PSDP appointment should be made in writing, to a competent person or organisation, before the design process begins. The earlier the PSDP is appointed, the more effectively they can discharge their duties, which include identifying and eliminating or reducing hazards during the design phase. The PSCS appointment must also be made before construction work commences. The PSCS is responsible for developing the Construction Stage Safety and Health Plan, coordinating safety during the construction phase, and managing the site safety file. These responsibilities begin before the first worker sets foot on site. ## Consequences of Failing to Notify Failure to submit the AF1 notification when required is a criminal offence under the Construction Regulations 2013. On summary conviction, the maximum penalty is a fine of €50,000. On conviction on indictment, the maximum is a fine of €3,000,000 and/or two years' imprisonment. Beyond the direct penalties, failure to notify is evidence of a broader failure to comply with the Construction Regulations. An inspector who discovers that a project has not been notified will look more closely at whether the PSDP and PSCS appointments have been made correctly, whether the Construction Stage Safety and Health Plan is in place, and whether the project is being managed safely. ## Frequently Asked Questions **Does the AF1 notification apply to domestic projects?** The Construction Regulations 2013 apply to construction work in general, including domestic projects. However, the notification requirement is triggered by the scale and nature of the work, not by whether the client is a domestic homeowner or a commercial developer. A large domestic extension or renovation project may well trigger the notification requirement. **Who can act as PSDP?** The PSDP must be a competent person with the skills, knowledge, and experience to discharge the role. This can be an individual or an organisation. In practice, the PSDP is often a health and safety consultant, an architect, or an engineer with construction safety expertise. **Can the same person act as both PSDP and PSCS?** Yes, in certain circumstances. However, the roles have distinct responsibilities and it is important that the person appointed is competent to discharge both. On larger or more complex projects, it is generally preferable to appoint separate PSDP and PSCS. **What happens if the project starts before the AF1 is submitted?** Starting a qualifying project without submitting the AF1 notification is a breach of the Construction Regulations. If an inspector discovers this, they may issue an improvement notice requiring the notification to be submitted, and may also investigate whether other regulatory requirements have been met. **Is there a fee for submitting the AF1 notification?** No. The AF1 notification is submitted free of charge through the HSA's website. --- *Safety Check Ltd provides PSDP and PSCS appointments, AF1 notifications, and construction safety management support across Leinster. If you need assistance with your project's regulatory requirements, contact us at info@safetycheck.ie or call +353 85 873 4413.*