The Construction Phase Safety and Health Plan: Who Writes It, What It Must Contain, and When It Must Be Updated

Who is responsible for the Construction Phase Safety and Health Plan in Ireland, what must it contain, and when must it be updated?

The Construction Phase Safety and Health Plan is one of the most important documents on any notifiable construction project in Ireland, and it is also one of the most frequently misunderstood. I have reviewed hundreds of these plans over the years, and the same problems come up time and again. Plans that were written before the project started and never updated. Plans that are generic templates with the project name pasted in. Plans that are stored in the site cabin and never referred to. Plans that do not reflect the actual work being carried out on site.

The Construction Phase Safety and Health Plan is not a bureaucratic exercise. It is the primary document through which the PSCS (Project Supervisor Construction Stage) coordinates safety across all contractors on the site. When it is done properly, it is a living document that drives safety management on the project. When it is done poorly, it is a liability.

This post covers who is responsible for the Construction Phase Safety and Health Plan, what it must contain under the Construction Regulations 2013, and when it must be reviewed and updated.

Who Is Responsible for the Construction Phase Safety and Health Plan?

The Construction Phase Safety and Health Plan is the responsibility of the PSCS. Regulation 17 of the Safety, Health and Welfare at Work (Construction) Regulations 2013 (S.I. No. 291 of 2013) requires the PSCS to prepare a Construction Phase Safety and Health Plan before construction work begins on a notifiable project.

The PSCS cannot delegate this responsibility to a subcontractor or a safety consultant, although they can engage a safety consultant to assist with the preparation of the plan. The PSCS remains legally responsible for the content and implementation of the plan.

On projects where the main contractor is also the PSCS (which is common on design-and-build projects), the main contractor's safety manager typically prepares the plan. On projects where the PSCS is a separate appointment, the PSCS prepares the plan in consultation with the main contractor.

What the Construction Phase Safety and Health Plan Must Contain

The Construction Regulations 2013 do not prescribe a specific format for the Construction Phase Safety and Health Plan, but they do require that it contains sufficient information to enable the safe management of the construction phase. In practice, a compliant plan should address the following areas:

Project description and key contacts: A description of the project, the client's details, the PSDP's details, the PSCS's details, and the contact details of key personnel including the site manager, the safety officer, and the emergency services.

Site rules and induction arrangements: The rules that apply to all persons on the site, including requirements for personal protective equipment, speed limits, smoking areas, and access control. The plan should also describe the induction process for new workers and visitors.

Arrangements for managing the construction work: How the PSCS will coordinate the activities of different contractors to prevent accidents. This includes arrangements for permit-to-work systems, hot work permits, confined space entry permits, and other high-risk activities.

Arrangements for managing specific risks: The plan must address the specific risks associated with the project, including working at height, excavation, use of plant and machinery, working with hazardous substances, and any other significant hazards identified in the Preliminary Health and Safety Plan prepared by the PSDP.

Emergency procedures: The arrangements for dealing with accidents, fires, and other emergencies, including the location of first aid equipment, the names of first aiders, the location of the nearest hospital, and the emergency assembly point.

Welfare arrangements: The welfare facilities provided on site, including sanitary accommodation, changing facilities, rest rooms, and drinking water.

Arrangements for site inspections: How often site safety inspections will be carried out, who will carry them out, and how the findings will be communicated to contractors and acted upon.

Arrangements for safety coordination meetings: The frequency and format of safety coordination meetings between the PSCS and the principal contractors and subcontractors on site.

Arrangements for reviewing and updating the plan: How and when the plan will be reviewed and updated to reflect changes in the work being carried out on site.

When the Construction Phase Safety and Health Plan Must Be Updated

The Construction Phase Safety and Health Plan is not a static document. It must be reviewed and updated whenever there is a significant change in the work being carried out on site, or whenever new information becomes available that affects the safety management of the project. In practice, this means reviewing the plan:

Before each new phase of work begins: If the project involves distinct phases, such as groundworks, structural frame, and fit-out, the plan should be reviewed and updated before each phase begins to ensure that it addresses the specific hazards of that phase.

When a new contractor starts on site: When a new contractor begins work on the site, the plan should be reviewed to ensure that it addresses the hazards associated with their work and that the coordination arrangements are adequate.

After a significant incident: If a serious accident, dangerous occurrence, or near-miss occurs on the site, the plan should be reviewed to identify any gaps in the safety management arrangements that may have contributed to the incident.

When the PSCS changes: If the PSCS is replaced during the project, the incoming PSCS must review the plan and update it to reflect their approach to managing safety on the site.

At regular intervals: Even if none of the above triggers apply, the plan should be reviewed at regular intervals, typically monthly on active sites, to ensure that it remains current and relevant.

Making the Construction Phase Safety and Health Plan Work

The most common failing I see with Construction Phase Safety and Health Plans is that they are prepared before the project starts and then forgotten about. The plan is submitted to the client, filed in the site cabin, and never referred to again. This is not compliance; it is box-ticking.

To make the plan work, the PSCS needs to use it as the basis for their day-to-day safety management activities. The site induction should be based on the plan. The site rules should be derived from the plan. The safety coordination meetings should review progress against the plan. The site inspections should check compliance with the plan. When the plan is used in this way, it becomes a genuine tool for managing safety rather than a document that satisfies a legal requirement.

What the HSA Looks For

When the HSA visits a construction site, the Construction Phase Safety and Health Plan is one of the first documents they will ask to see. They will check that the plan exists, that it is specific to the project, that it is current, and that it addresses the work being carried out on site at the time of the inspection. They will also check that the workers on site are aware of the plan and that the safety arrangements described in the plan are actually being implemented.

A plan that is out of date, generic, or not being implemented is a serious finding that is likely to result in an improvement notice or a prohibition notice. If the HSA finds that a notifiable project is being carried out without a Construction Phase Safety and Health Plan, they have the power to stop work on the site until the plan is prepared and implemented.

Conclusion

The Construction Phase Safety and Health Plan is the PSCS's primary tool for managing safety on a notifiable construction project. It must be prepared before construction begins, it must be specific to the project, and it must be reviewed and updated throughout the construction phase. If you are a PSCS and you are unsure whether your Construction Phase Safety and Health Plan meets the requirements of the Construction Regulations 2013, contact Safety Check for a review.