Construction Site Safety Management Plan: What It Must Contain

Under the WHS Regulations a construction project is construction work where the cost of the work is $250,000 or more. Every construction project must have a principal contractor, and the principal contractor must prepare a written WHS management plan before work on the project commences (section 309 of the NSW WHS Regulation, regulation 309 in the other WHS jurisdictions). The person who commissions the work is the principal contractor unless they appoint someone else and give that person management or control of the site, which is what a head contract with a builder normally does.

Victoria works under its own law. The Occupational Health and Safety Regulations 2017 require the principal contractor to prepare a health and safety coordination plan for a construction project costing $350,000 or more. The contents are close to the WHS management plan, and a plan written to the outline below satisfies both once the Victorian terms and references are used.

Below the threshold there is no duty to prepare the plan, but the duties it organises still apply: the builder must still manage risks, consult, plan for emergencies and collect a SWMS for any high risk construction work. Many clients, councils and head contractors ask for a site safety plan on smaller jobs for exactly that reason.

The plan must include:

1. The names, positions and health and safety responsibilities of everyone at the workplace whose position or role involves specific health and safety responsibilities for the project. This means named people, such as the site supervisor, the first aiders and the person who issues permits, with what each is responsible for.

2. The arrangements for consultation, cooperation and coordination between the businesses working on the project. In practice: pre-start meetings, toolbox talks, the subcontractor coordination meeting and how issues are raised and closed.

3. The arrangements for managing any work health and safety incidents that occur: who is told, who preserves the scene, who notifies the regulator of a notifiable incident, and how the investigation is recorded.

4. Any site-specific health and safety rules, and the arrangements for making sure everyone at the workplace is told about them. This is the site induction and the rules it teaches.

5. The arrangements for collecting, assessing, monitoring and reviewing safe work method statements. The principal contractor must obtain a SWMS before high risk construction work starts and must see that the work follows it.

A plan that covers these five items meets the regulation. A plan that only covers these five rarely satisfies a client or an auditor, which is where the site-specific sections come in.

The commonest reason a plan is rejected is that it could describe any site. A site safety management plan earns the name when it records the things that are true of this job and no other:

• The site and its surroundings. Address, boundaries, neighbouring properties, schools, public footpaths, overhead power lines and underground services, with a site layout plan showing access points, amenities, first aid, the emergency assembly area, material storage and plant routes.
• The hazards of this project. A project hazard register built from the actual scope: demolition, excavation depth, work at height, cranes, asbestos found in the survey, silica-generating tasks, traffic.
• The high risk construction work on the programme, listed against the subcontractor responsible and the SWMS received.
• Traffic and pedestrian management for deliveries, plant movements and the public interface.
• Emergency arrangements for this location: the nearest hospital, access for emergency vehicles, rescue arrangements for work at height or confined spaces, and the evacuation procedure.
• Permits used on the site, such as hot work, excavation, confined space and work at height, and who is authorised to issue them.
• Amenities, first aid and site security, including after-hours arrangements and public protection.

The principal contractor is responsible for the plan. It may be drafted by a safety adviser or a consultant, but the principal contractor remains accountable for its content and for following it.

Before a person starts work on the project, the principal contractor must make sure, so far as is reasonably practicable, that the person is made aware of the content of the plan that relates to the work they will do and of their right to inspect it. That is normally done through the site induction. The plan must be reviewed and revised as necessary so that it stays up to date, and everyone affected must be told of the revision. A copy must be kept until the project is completed, and for at least two years after a notifiable incident occurs.

The plan and the SWMS do different jobs. The site safety management plan is the principal contractor's document and covers the whole project. A SWMS is prepared by the business doing a particular piece of high risk construction work, such as the scaffolder, the roofer or the excavation contractor, and describes how that work will be done safely. The plan says how SWMS are collected, checked and monitored; it does not replace them. A project with a good plan and no SWMS for its high risk work is not compliant, and neither is the reverse.

1. Project details: project name and address, client, principal contractor, scope, programme and contract value.
2. Health and safety policy and objectives for the project.
3. Roles and responsibilities: named people, positions and specific duties.
4. Site description and layout plan.
5. Project hazard register and the controls for each hazard.
6. High risk construction work and SWMS register: how SWMS are collected, reviewed, accepted and monitored.
7. Subcontractor management: prequalification, insurances, licences and supervision.
8. Consultation and communication: pre-starts, toolbox talks, meetings and issue resolution.
9. Site rules and induction: content of the induction, the induction register and visitor rules.
10. Training, licences and competency: general construction induction cards, high risk work licences and verification.
11. Plant and equipment: registration, inspection and pre-start checks.
12. Hazardous chemicals, asbestos and silica: registers, safety data sheets and control plans.
13. Permits to work used on the project.
14. Traffic and pedestrian management.
15. Emergency procedures and first aid.
16. Incident reporting, notification and investigation.
17. Inspections, audits and corrective actions.
18. Review of the plan and document control.

The WHS management plan guide explains each section in more detail, including what auditors look for under the Federal Safety Commissioner's scheme.

Clients, certifiers and head contractors reject site safety management plans for a short list of reasons: the plan names another project or another state's legislation; responsibilities are given to job titles with no names; the hazard register is generic and misses the obvious hazards of the scope; there is no SWMS register or no process for reviewing SWMS; the emergency section has no site address, assembly point or hospital; and the plan has no revision date. Each of these is fixed by writing the plan for the site, which takes less time than the resubmission.