The Preliminary Health and Safety Plan: What It Must Contain and When It Must Be Prepared

The Preliminary Health and Safety Plan is a legal requirement on notifiable construction projects in Ireland.

What Is the Preliminary Health and Safety Plan?

The Preliminary Health and Safety Plan (PHSP) is a document prepared by the Project Supervisor Design Process (PSDP) for notifiable construction projects in Ireland. It is one of the key documents in the Irish construction safety management system and serves as the bridge between the design stage and the construction stage of a project. The PHSP communicates information about the project's hazards and risks to the Project Supervisor Construction Stage (PSCS), who uses it as the basis for developing the Construction Phase Safety and Health Plan.

The PHSP is not a generic document. It must be specific to the project and must reflect the particular hazards and risks that have been identified during the design process. A PHSP that consists of generic boilerplate text without project-specific content does not meet the legal requirements.

The Legal Basis

The requirement for a Preliminary Health and Safety Plan is set out in Regulation 9 of the Safety, Health and Welfare at Work (Construction) Regulations 2013 (S.I. No. 291 of 2013). Regulation 9 requires the PSDP to prepare a PHSP before the construction phase begins. The PHSP must be provided to the PSCS before the PSCS takes up their appointment, so that the PSCS can take account of the information in the PHSP when planning the construction phase.

The PHSP is required on notifiable projects, that is, projects where the construction phase will last longer than 30 working days with more than 20 workers simultaneously, or where the volume of work will exceed 500 person-days. Most projects of any significant size will be notifiable.

When Must the PHSP Be Prepared?

The PHSP must be prepared before the construction phase begins. In practice, this means it should be developed progressively during the design stage, starting from the earliest stages of the project when the key design decisions are being made. The PHSP should be updated as the design develops and as new hazards are identified or existing hazards are resolved through design changes.

The PHSP must be sufficiently developed to be useful to the PSCS before the PSCS is appointed. If the PSCS is appointed before the PHSP is complete, the PSCS cannot properly plan the construction phase. In practice, the PHSP should be substantially complete before the project goes to tender, so that tenderers can take account of the health and safety requirements when preparing their bids.

What Must the PHSP Contain?

Schedule 2 of the Construction Regulations 2013 sets out the minimum content requirements for the Preliminary Health and Safety Plan. The PHSP must include the following information:

Project description. A description of the project, including the nature of the work, the location, the programme, and the key milestones. This gives the PSCS an overview of the project and its scope.

Existing hazards. Information about any existing hazards on or near the site that could affect the construction work. This includes information about underground services, overhead power lines, contaminated land, asbestos, existing structures that may be unstable, and any other hazards that are known at the time the PHSP is prepared. The PSDP should obtain this information from the client, from utility companies, from ground investigation reports, and from any other relevant sources.

Design hazards. Information about hazards that arise from the design of the structure. This includes information about the construction sequence, temporary works requirements, structural instability during construction, and any other design decisions that have implications for the safety of construction workers. The PSDP should record the design decisions that have been made to eliminate or reduce these hazards, and the residual risks that must be managed during the construction phase.

Specific measures required. Details of any specific health and safety measures that will be required during the construction phase. This might include requirements for specialist contractors for particular activities, requirements for specific permits to work, or requirements for specific monitoring or testing.

Welfare arrangements. Information about the welfare facilities that will be required on the site, including sanitary facilities, washing facilities, rest facilities, and facilities for changing and storing clothing.

Emergency arrangements. Information about the emergency arrangements that will be required on the site, including the location of the nearest hospital and emergency services, and any specific emergency procedures that are required because of the nature of the project or the site.

The Relationship Between the PHSP and the Construction Phase Safety and Health Plan

The PHSP is the starting point for the Construction Phase Safety and Health Plan (CPHSP), which is prepared by the PSCS. The PSCS takes the information in the PHSP and develops it into a detailed plan for managing health and safety during the construction phase. The CPHSP must address all the hazards identified in the PHSP and must specify the controls that will be put in place to manage those hazards.

The PHSP and the CPHSP are complementary documents. The PHSP focuses on the hazards that arise from the design and the existing site conditions. The CPHSP focuses on the hazards that arise from the construction activities themselves and the measures required to manage them.

Common Deficiencies in Preliminary Health and Safety Plans

The Health and Safety Authority has identified a number of common deficiencies in Preliminary Health and Safety Plans on Irish construction sites. These include plans that are too generic and do not address the specific hazards of the project, plans that do not include information about underground services or other existing hazards, plans that are not updated as the design develops, and plans that are not provided to the PSCS before the construction phase begins.

A PHSP that does not meet the legal requirements exposes the PSDP to enforcement action by the HSA and, more importantly, means that the PSCS does not have the information needed to plan the construction phase safely.

Conclusion

The Preliminary Health and Safety Plan is a critical document in the Irish construction safety management system. It must be project-specific, must be prepared progressively during the design stage, and must be provided to the PSCS before the construction phase begins. A well-prepared PHSP sets the foundation for a safe and well-managed construction project.