PSCS Obligations During the Construction Phase: A Practical Checklist for Site Managers
The PSCS role carries significant ongoing obligations throughout the construction phase.
# PSCS Obligations During the Construction Phase: A Practical Checklist for Site Managers The Project Supervisor for the Construction Stage (PSCS) carries significant legal responsibilities under the Safety, Health and Welfare at Work (Construction) Regulations 2013. These responsibilities do not end when the Construction Phase Safety and Health Plan is written — they continue throughout the entire construction phase, from the first day on site to the handover of the Safety File. This guide provides a practical checklist of the PSCS's ongoing obligations during the construction phase, written for site managers and safety professionals who need a clear reference for day-to-day compliance. ## Who Is the PSCS? The PSCS is the person or organisation appointed by the client to coordinate health and safety matters during the construction phase of a project. On most projects, the PSCS is the main contractor, though the client can appoint a separate organisation to fulfil the role. The appointment must be made in writing before construction work begins. The PSCS must be competent to carry out the role — they must have the knowledge, skills, and experience necessary to coordinate health and safety on the specific project. ## The Construction Phase Safety and Health Plan The PSCS's first major obligation is to prepare the Construction Phase Safety and Health Plan before construction work begins. This plan must be based on the Preliminary Health and Safety Plan prepared by the PSDP (Project Supervisor Design Process) and must set out the specific arrangements for managing health and safety on the project. The plan is a living document. It must be reviewed and updated throughout the construction phase as circumstances change. The PSCS must ensure that the plan reflects the actual conditions on site at all times. ## Ongoing PSCS Obligations: A Practical Checklist The following checklist covers the PSCS's main ongoing obligations during the construction phase. It is not exhaustive — the full requirements are set out in the Construction Regulations 2013 — but it provides a practical framework for day-to-day compliance. ### Coordination of Health and Safety - [ ] Coordinate the implementation of the Construction Phase Safety and Health Plan - [ ] Ensure that all contractors on site are aware of the plan and their obligations under it - [ ] Coordinate the activities of different contractors to prevent conflicts that could create safety risks - [ ] Ensure that the general principles of prevention are applied throughout the project - [ ] Monitor compliance with the plan and take action where non-compliance is identified ### Contractor Management - [ ] Ensure that all contractors appointed to the project are competent to carry out their work safely - [ ] Check that all contractors have their own Safety Statements and that these are relevant to the work they are carrying out - [ ] Ensure that all contractors have received the relevant parts of the Construction Phase Safety and Health Plan - [ ] Coordinate the activities of contractors working simultaneously on site - [ ] Ensure that subcontractors appointed by main contractors are also competent and have appropriate Safety Statements ### Site Safety Management - [ ] Ensure that the site is set up safely before work begins — welfare facilities, access routes, exclusion zones - [ ] Ensure that the site is maintained safely throughout the construction phase - [ ] Ensure that all workers on site have received a site induction - [ ] Ensure that appropriate personal protective equipment is available and being used - [ ] Ensure that site rules are communicated to all workers and enforced consistently ### Risk Assessment and Method Statements - [ ] Ensure that risk assessments and method statements are prepared for all high-risk activities before they begin - [ ] Review risk assessments and method statements to ensure they are suitable and sufficient - [ ] Ensure that workers carrying out high-risk activities are aware of the relevant risk assessments and method statements - [ ] Ensure that risk assessments are reviewed and updated when circumstances change ### Permit to Work Systems - [ ] Implement permit to work systems for high-risk activities — confined space entry, hot work, work on live electrical systems, excavation near buried services - [ ] Ensure that permits are properly completed, authorised, and closed out - [ ] Ensure that workers understand the permit system and comply with it ### Inspections and Monitoring - [ ] Carry out regular site safety inspections and record the findings - [ ] Ensure that any deficiencies identified during inspections are rectified promptly - [ ] Monitor the implementation of the Construction Phase Safety and Health Plan - [ ] Carry out or arrange for specialist inspections — scaffolding, excavations, lifting equipment — as required ### Accident and Incident Management - [ ] Ensure that all accidents and near misses are reported, recorded, and investigated - [ ] Report notifiable accidents to the HSA in accordance with the requirements of the Safety, Health and Welfare at Work Act 2005 - [ ] Ensure that the lessons learned from accidents and near misses are communicated to all workers and incorporated into the Construction Phase Safety and Health Plan ### HSA Notification - [ ] Ensure that the HSA has been notified of the project before construction work begins (for notifiable projects) - [ ] Update the HSA notification if there are significant changes to the project — a change in the PSCS, a significant change in the programme, or a significant change in the scope of work ### Safety File - [ ] Collect and maintain the information needed for the Safety File throughout the construction phase - [ ] Ensure that all contractors provide the information needed for the Safety File - [ ] Prepare and hand over the Safety File to the client on completion of the project ### Toolbox Talks and Training - [ ] Ensure that toolbox talks are carried out regularly and that records are kept - [ ] Ensure that all workers have received the training required for their specific tasks - [ ] Ensure that training records are maintained ## Common PSCS Failures The HSA's enforcement activity in the construction sector identifies a number of recurring failures by PSCSs. Being aware of these common failures can help site managers avoid them: **Failure to update the Construction Phase Safety and Health Plan.** The plan is often prepared before construction begins and then not updated as the project progresses. The plan must reflect the actual conditions on site at all times. **Failure to coordinate subcontractors.** The PSCS is responsible for coordinating the activities of all contractors on site, including subcontractors appointed by main contractors. This is often neglected in practice. **Failure to check contractor competence.** The PSCS must ensure that all contractors are competent. In practice, this often means checking that contractors have relevant qualifications, experience, and safety management systems — not just that they have a Safety Statement. **Failure to maintain the Safety File.** The Safety File is often left until the end of the project, by which time much of the information needed has been lost. The PSCS should collect Safety File information throughout the construction phase. **Failure to report accidents.** Not all reportable accidents are reported to the HSA. The PSCS must ensure that all notifiable accidents are reported promptly. ## Conclusion The PSCS role carries significant ongoing obligations throughout the construction phase. Meeting these obligations requires active engagement with the project — not just the preparation of documents before work begins, but continuous monitoring, coordination, and management throughout the construction phase. If you need assistance fulfilling the PSCS role on your project, or if you need a competent PSCS appointed for an upcoming project, Safety Check can help. Contact us at [safetycheck.ie/contact](https://www.safetycheck.ie/contact). ## References [1] Safety, Health and Welfare at Work (Construction) Regulations 2013. Available at: https://www.irishstatutebook.ie/eli/2013/si/291/made/en/print [2] Health and Safety Authority - PSCS Duties. Available at: https://www.hsa.ie/eng/your_industry/construction/legislation_and_guidance/construction_regulations_2013/ [3] Safety, Health and Welfare at Work Act 2005. Available at: https://www.irishstatutebook.ie/eli/2005/act/10/enacted/en/html