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TAKE NOTE: The DoL has made more changes to the SACPCMP registration!

by , 31 July 2015
They say laughter is good for your health.

So when I need a really good laugh, I just read about the new Construction Regulations and the DoL's feeble attempts to get things right.

I'm starting to think that the implementation of the Construction Regulations 2014 is never going to happen. Or maybe they should just rename it 'Construction Regulations 2014/2015/2016/?'

Let me go into a bit more detail...

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Construction health and safety registration exemptions to 2016

According to sources at sheqafrica.com, current SACPCMP registration applicants will receive interim construction health and safety registration exemption verification letters on 3 August. This will allow them to exempt their employers for a year, up to 31 July 2016, provided that the required fees were paid, and required documents were submitted.

Projects of more than R130 million now require construction permits.

Only about 300 projects are expected to require permits for the rest of the year, and then the level will be lowered:
  • Permits for projects above R130-m, or CIDB level 9, are required now, from 7 August 2015.
  • Permits for projects above R40-m, or CIDB level 8, would be required from 7 February 2017.
  • Permits for projects above R13-m, or 365 days, or 3600 person days, would be required from 7 August 2018.
The earlier requirement as promulgated would have stopped work on many sites. All this because of the DOL's inability to process the permit applications required in the Construction Regulations Amendment. And for lack of the newly required registered CHS Agents and Officers.

The permit exemptions, and registration verification letter exemptions, will be officially published in July 2015. Other health and safety laws apply as usual.

What isn't changing about SACPCMP registration

Construction Health and Safety Practitioners must already be competent in terms of the SAQA unit standards, based on training, skills, and experience.

If you're a CHS Practitioner, you should still register if you haven't already. But since the DOL inspect and prosecute based on competence, as defined by the Construction Regulations and the SACPCMP, you should be okay if you still need to follow the registration process.

But don't leave it too late because there are several registration enforcement points for CHS Agents and CHS Officers - not just the permit phases. Some employers have already been prosecuted for lacking competent Construction Health and Safety appointees.

The SACPCMP says it has only one registration assessor, and uses some voluntary assessors via voluntary associations. They seem to be struggling to recruit Assessors, and are now even offering Assessor training to volunteers!

Read on for some feedback on the registration process so far…

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Feedback on SACPCMP registration

The SACPCMP reports that Construction Health and Safety Agents have applied in 'sufficient numbers' but at a slow pace. One Official said there were 3856 applications, where another said there were 2500 applications.

Only twelve applicants are eligible for writing registration exams, the rest are 'in process'.

Most applications lack payment of some of the relevant fees; or lack proof of experience; or have submitted poor or experience reports; or await SACPCMP capacity.

Recommendations from the safety registration seminar

Among the recommendations were:

  • Combine permits for construction, engineering, and other work;

  • Inspectors should register with the SACPCMP;

  • Compensate health and safety practitioners who paid various registration fees in anticipation of the August 2015 deadline;

  • Standardise the cost of hiring registered construction health and safety Agents;

  • Allow CHS Officers to work under registered CHS Agents;

  • Allow organisations such as consulting companies to act as CHS Agents, provided one of the consultants is a CHS Agent;

  • Construction contracts should cite health and safety costs;

  • Present more free DOL workshops with CPD points; and

  • Make a guidance video on the registration process.

Recommendations would be considered for possible inclusion in the DOL Construction Regulations 2014 guidelines for implementation. The guidelines are already six months overdue.

Construction permit exemptions to 2017 and 2018

Construction permit applications require three documents:

  • Construction Health and Safety specification;

  • HS plan with timeframes; and

  • Baseline risk assessment.

DoL officials, however, check 17 documents before issuing a construction permit, including registration of the CHS Agent, if applicable. CHS Managers don't need to register.

Single storey developments of high value will be added to the projects requiring permits, and the focus will shift to smaller projects later.
With less than a week to go, make sure you're complying with the Construction Regulation implementation in August. Get your complete Construction Regulations 2014 guide.

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