The Site & Project Management HSE Questions

1. What is your opinion of health, safety and environmental issues within the construction
industry?

2. What is your personnel view on health, safety and the environment, and do you see it as a
hindrance or benefit in your work?

3. What are the positive impacts that good health, safety and environmental practises can have
on a business?

4. How do you feel that health, safety and environmental issues on the contract are best
managed?

5. Have you ever worked under CDM, and what are your experiences?

6. Have you ever worked under ISO Standards and are you aware of the requirements under ISO?

7. What other health, safety and environmental regulations would apply to the works on an
Atkins T&D site?

8. When were the CDM Regulations last changed, and what were the main areas of change?

9. What is the main piece of legislation that governs health & safety within this country?

10. Describe what is meant by a controlling mind?

11. What are “The Five Steps” to a risk assessment and what is the purpose of a risk assessment?

12. What would you include in a method statement contents and what is the purpose of a Method
Statement?

13. What would you do if you witnessed an unsafe act on site?

14. What would you do if site operatives would not conform to site rules and safe systems of
work?

15. What would you do if you witnessed a “Near Miss” on site, and what is the importance of near
miss reporting?

16. What PPE would you expect an operative to wear using a Sthil saw in the highway?

17. Describe “As low as is reasonably practicable (ALARP) or so far as is reasonably practicable
(SFAIRP)” & Reasonably Practicable?

18. When initiating a site set up, what elements in regards to the health and safety must you take
into account?

19. What is the definition of the terms “Hazard” and “Risk”?

20. What is the definition of the term “Near Miss”?

21. Describe the principals of ERIC-PD

22. Describe the mechanism of HSG 65

23. Describe the Bird Triangle theory.

24. Describe the Bradley curve and its implementation

25. Describe the development, distinctions & mechanism of a site waste management plan and
how to manage waste from site.

26. Describe the Domino Theory in relation to accident investigations.

27. Name the duty holders and their responsibilities under the CDM regulations.

28. What is the purpose of the construction Phase Health And Safety Plan?

29. What is the Health & Safety File and its purpose?

30. What are the duties of “Employees” under the Health And Safety At Work Etc Act 1974?
The Site & Project Management HSE Question(Answers)

1. The candidate should be showing a positive impression of HSE issues and perhaps demonstrate
this with an example of good practise they have seen within the industry.

2. The candidate should always answer with HSE legislation and good practice is a benefit to the
workplace ethically, morally and financially.

3. The candidate should show that good HSE management will provide cost savings and improve
moral and encourage a low staff turn over and improve quality. This could lead to client
satisfaction and further work and fewer work related injuries and loss time.

4. An open team orientated approach to the HSE management, with a team involvement approach to
ownership and responsibilities. A shared and managed system and process should be the answer
that the candidate submits to this question.

5. Ask the candidate what CDM stands for (Construction Design Management Regulations) and what
sort of work they have been involved with that has fallen under these regulations and their
thoughts of these regulations.

6. Ask candidate if they have worked with ISO standards and to what level they have an awareness
of the standards required. They should give examples of audits, customer care reports, project
files, damage reports, material order procedures, variation reports, progress reports etc. They
should show awareness of systems, procedures and understand the importance and purpose of
the audit trail.

7. Some of the legislation that should be highlighted is, CDM, LOLER, PUWER, PPE, Noise At Work,
Confined Space, Work At Height, COSHH, Manual Handling, Control Of Vibration At Work,
Hedgerows, Control Of Pollution, Health And Safety At Work Etc Act, Environmental Act, Water
Act, New Roads And Street Works Act, Highways Act Etc.

8. The candidate should be aware and be able to demonstrate knowledge of the latest changes in
legislation that affect their role. The CDM Regulations were changed in 2007 with a number of key
changes. These are highlighted below.
 Regulations are re-ordered to group duties together by duty holder and to show whether individual
provisions apply to all projects, only notifiable projects, or only non-notifiable projects. (The
definition of ’Notifiable‘ is unchanged, but the application provision relating to fewer than five
workers on site has been removed).
 Work for domestic clients no longer needs to be notified.
 The client’s agent and developer provisions are removed. Under CDM 2007, a group of clients
involved in a project can now elect one or more of its members to be the only client(s).
 The role of planning supervisor ceases to exist. The ’CDM co-ordinator’ is introduced to support
and advise the client and to co-ordinate design and planning.
 The appointment of a CDM co-ordinator, principal contractor and a written health and safety plan
are only required for notifiable projects (but demolition work requires a written system of work).
 Duty holders cannot accept an appointment/engagement unless they are competent to carry it out.
Additionally, they cannot arrange for, or instruct anyone, to carry out or manage design or
construction work, unless that person is competent (or being supervised by someone who is).
 Assessment and demonstration of competence is simplified, with new core criteria and specific
ACoP material on individual and corporate competence.

 There are general co-operation and co-ordination duties on everyone involved in a project (relating
to others on the same or adjoining sites). This is a specific requirement to implement any
preventive and protective measures, on the basis of the principles specified in the Management of
Health and Safety at Work Regulations 1999.
 Clients now have the duty, (which already exists in the Health & Safety at Work etc. Act 1974 and
Management Regulations) to take reasonable steps to ensure that managerial arrangements made
by duty holders (including time and other resources) enable construction work to be carried out,
(any related structure designed for use as a place of work can be used), without risk to health or
safety. Clients have the duty to ensure that the arrangements are maintained and reviewed
throughout the project.
 Clients must tell designers and contractors how much time they have, before the start of work on
site, for planning and preparing construction work.
 For notifiable projects, designers are prohibited from doing anything more than initial design work
before the CDM co-ordinator has been appointed. In preparing or modifying a design they are
required, so far as is reasonably practicable, to avoid risks to the health or safety of any person
using a structure designed as a workplace. They must eliminate hazards which may give rise to
risks and reduce risks from any remaining hazards.
  The civil liability exemption has been removed in relation to the employer/employee relationship.
The management regulations have already been amended along these lines.
 Various definitions have been changed, including those of ’client’, ‘construction phase plan’,
‘construction work’, ‘contractor’, ‘design’ and ‘designer’, ‘place of work’ and ‘structure.
9. The Health And Safety At Work Etc Act 1974, (HASWA).

10. A company can only be prosecuted for manslaughter if an individual (who is being prosecuted for
manslaughter) is considered to be a "controlling mind" or a "directing mind and will" of the
company. How can you determine whether or not an individual is such a person.

The test for this was set out in the case of HL Bolton (Engineering) Co Ltd v TJ Grahams & Sons
Ltd. This stated the following:

"A company may in many ways be likened to a human body. It has a brain and nerve centre which
controls what it does. It also has hands which hold the tools and act in accordance with directions
from the centre. Some of the people in the company are mere servants and agents who are nothing
more than the hand to do the work and cannot be said to represent the mind and will. Others are
directors and managers who represent the directing mind and will of the company, and control
what it does. The state of mind of these managers is the state of mind of the company and is
treated by the law as such."

There is however uncertainty about how this general test can be applied. In the House of Lords
case of Tesco Supermarkets Ltd v Natrass, three different judges gave three slightly different
interpretations:

Lord Reid sated that the following individuals were controlling minds of a company:

"the board of directors, the managing director and perhaps other superior officers of a company
[who] carry out the functions of manslaughter and speak and act as the company"

Viscount Dilhorne gave a more limited interpretation saying that a controlling mind is a person:

"Who is in actual control of the operations of a company or of part of them and who is not
responsible to another person in the company for the manner in which he discharges his duties in
the sense of being under his orders."

And Lord Diplock stated that the people who are the controlling minds are those:

"who by the memorandum and articles of association or as a result of action taken by the directors
or by the company in general meeting pursuant to the articles are entrusted with the exercise of the
powers of the company."

11. As per the HSE guidance, the candidate should identify the following 5 steps as follows.
Step 1 – Look For Hazards.
Step 2 – Decide Who May Be Harmed, And How.
Step 3 – Evaluate The Risks And Decide If The Existing Controls Are Adequate Or If Further
Controls Are Required.
Step 4 – Record The Findings.
Step 5 – Monitor, Review And Revise.

The purpose of a risk assessment is to identify possible causes of harm, the likelihood of harm
actually occurring and any measures needed to reduce that likelihood  - before an accident occurs.

12. As per the HSE guidance, the candidate should highlight the following key areas of a method
statement.
 1 – Description of the work
2 – Sequence of the works
3 – Resources (Plant, Materials, Equipment, Operatives)
4 – Access and working areas
5 – COSHH and PPE
6 – Special Considerations
7 – Protection for the public and third parties
8 – Site specific rules
9 – Site Security
10 – Temporary systems
11 – Emergency systems and procedures
12 – Acceptance and received record.

A Work Method Statement, sometimes referred to as a Safe Work Method Statement or a Safe Work
Procedure. The term is predominately used in construction to describe a document that gives
specific instructions on how to safely perform a work related task, or operate a piece of plant or
equipment. It is law to have Work Method Statements in place to advise employees and contractors
on how to work safely.

The Statement is generally used as part of a Safety Induction and then referred to as required
throughout a workplace.

13. The candidate should state that the action would be immediately brought to a safe controlled stop.
The candidate should state that the safe system of work would be immediately reviewed and an
investigation initiated. Works would not commence again until a safe system of works had been
approved and the investigation had produced a recommendation. The candidate should also state
the communication line for reporting the incident would be through his line manager, SHEQ Dept
and near miss/incident reporting procedure.

14. The candidate should state how the work should be stopped straight away and brought to a safe
controlled end. The candidate should state how they would warn the individuals of their behaviour
on site and remind them of their future conduct on site and their legal obligation to use safe
systems of work provided and obey site safety works. If persistent offending was then observed
the candidate would state they would stop all works remove the offenders from site and instigate
the disciplinary procedure through his line manager for gross misconduct.

15. The candidate should state how important “Near Miss” reporting is and state that they would use a
reporting system, talk to the persons involved in the “Near Miss” and rectify the situation if safe to
do so. The candidate should identify the importance as using the “Near Miss” as a learning
opportunity for the contract and highlight it to SHEQ dept to produce an action. The candidate
should state a Near Miss is an indication that something is wrong and should be accepted as a
WARNING or a free lesson. The difference between a Near Miss and a full blown incident is often
good luck, however good luck does not last forever, the next time it may lead to an accident.
Candidates should see reporting “Near Misses” as a method of accident prevention and a positive
way of continues improvement.

16. The candidate should be highlighting the required PPE as follows:

- Goggles suitable for the task
- Ear defenders suitable for the task
- Highways appropriate high visibility vest
- Safety footwear
- Gloves suitable for the task (for HAVs and chemicals when refuelling etc)
- Face mask suitable for the task (RPE)
- Coveralls
- Hard hat

17. The two terms mean essentially the same thing and at their core is the concept of “reasonably
practicable”; this involves weighing a risk against the trouble, time and money needed to control it.
 Thus, ALARP describes the level to which we expect to see workplace risks controlled. Using
“reasonably practicable” allows us to set goals for duty-holders, rather than being prescriptive.
This flexibility is a great advantage but it has its drawbacks, too. Deciding whether a risk is ALARP
can be challenging because it requires duty-holders and us to exercise judgment. In the great
majority of cases, we can decide by referring to existing ‘good practice’ that has been established
by a process of discussion with stakeholders to achieve a consensus about what is ALARP. For
high hazards, complex or novel situations, we build on good practice, using more formal decision
making techniques, including cost-benefit analysis, to inform our judgment.

The concept of “reasonably practicable” lies at the heart of the British health and safety system. It
is a key part of the general duties of the Health and Safety at Work etc. Act 1974 and many sets of
health and safety regulations that we and Local Authorities enforce. HSE’s policy is that any
proposed regulatory action (Regulations, ACoPs, guidance, campaigns, etc.) should be based on
what is reasonably practicable. In some cases, however, this may not be possible because the
Regulations implement a European directive or other international measure that adopt a risk
control standard different from “reasonably practicable” (i.e. different from what is ALARP).

You may come across it as SFAIRP (“so far as is reasonably practicable”) or ALARP (“as low as
reasonably practicable”). SFAIRP is the term most often used in the Health and Safety at Work etc
Act and in Regulations. ALARP is the term used by risk specialists, and duty-holders are more
likely to know it. We use ALARP in this guidance. In HSE’s view, the two terms are interchangeable
except if you are drafting formal legal documents when you must use the correct legal phrase.

The definition set out by the Court of Appeal (in its judgment in Edwards v. National Coal Board,
[1949] 1 All ER 743) is:

“‘Reasonably practicable’ is a narrower term than ‘physically possible’ … a computation must

be made by the owner in which the quantum of risk is placed on one scale and the sacrifice
involved in the measures necessary for averting the risk (whether in money, time or trouble) is
placed in the other, and that, if it be shown that there is a gross disproportion between them –
the risk being insignificant in relation to the sacrifice – the defendants discharge the onus on
them.”

In essence, making sure a risk has been reduced ALARP is about weighing the risk against the
sacrifice needed to further reduce it. The decision is weighted in favor of health and safety because
the presumption is that the duty-holder should implement the risk reduction measure. To avoid
having to make this sacrifice, the duty-holder must be able to show that it would be grossly
disproportionate to the benefits of risk reduction that would be achieved. Thus, the process is not
one of balancing the costs and benefits of measures but, rather, of adopting measures except
where they are ruled out because they involve grossly disproportionate sacrifices. Extreme
examples might be:

 To spend £1m to prevent five staff suffering bruised knees is obviously grossly
disproportionate; but
 To spend £1m to prevent a major explosion capable of killing 150 people is obviously
proportionate.

Of course, in reality many decisions about risk and the controls that achieve ALARP are not so
obvious. Factors come into play such as ongoing costs set against remote chances of one-off
events, or daily expense and supervision time required to ensure that, for example, employees
wear ear defenders set against a chance of developing hearing loss at some time in the future.
It requires judgment. There is no simple formula for computing what is ALARP.

18. For the site set up for a project the candidate must highlight the following areas to be
addressed at this stage:
- Pre Start Surveys Have Been Completed
- Site Specific Work Pack Containing:
- Site Specific Method Statements, Risk Assessments & Permits.
- Site Specific Construction Drawings
- Site Specific Utility Drawings & Previous As Laid Information
- Appropriate registers of inspection
- Pre Start Surveys
- Feasibility Study
- Traffic Management Plans
- Storage And Lay Down Areas
- Temporary Site power distribution plans
- Suitable Welfare Facilities Including:
- Hot & Cold Water
- Drinking Water
- Means For Heating A Hot Beverage
- Washing Facilities Including Soap/Means For Drying/Sink
- Toilet Facilities
- Separate Eating And Drinking Areas
- First Aid
- Lighting
- Issues Regarding The Site Security And Segregation. Ensure Public & Third Parties Safety.
- Issues Regarding The Site Delivery Points, Storage Areas And Site Access Points.
- Issues Relating To Site Signage And Highway Signage.
- Issues Regarding Competence Of Staff And Suitability For Task.
- Site Specific Staff Induction Constructed For The Site And Issued.
- Emergency Procedures Are In Place, Checked, Tested And Suitable.
- Site Communications And Lines Of Reporting Are In Place And All Persons Are Aware.

19. The candidate should give the recognised definitions as follows:

“Hazard” – A hazard is something with the potential to cause harm. This can include articles,
substances, plant or machines, methods of work, the working environment and other aspects
of work organisation.
“Risk” – A risk is the likelihood of potential harm occurring form the identified hazard.
The extent of the risk will depend on:
- The likelihood of that harm occurring
- The potential severity of that harm i.e. of any resultant injury or adverse effect
- The number of people which may be affected by the hazard.

20. For the term “Near Miss” the candidate should give the following recognised definition:
- “A near miss is an unplanned incident or an event that did NOT result in injury, illness,
damage or environmental harm – but something that had the potential to do so”

21. ERICPD is an acronym. It defines the hierarchy of control and stands for:
Eliminate
Reduce
Isolate
Control
________________________
Personal Protective Equipment
Discipline

The hierarchy of control is used to remove of reduce hazards and risks from the workplace. It
should be used during a risk assessment to identify means of making the
workplace safer for employees, contractors and the public. The idea is that you start by
choosing methods from the top of the list 'so far as is reasonably practicable' and work your
way down if needed. The top four will make the workplace safer but below the line you are
only addressing the safety of the individual employee - PPE and discipline will not serve to
protect passers-by of any sort.

Eliminate - get your supplier to cut MDF to the right size and let them deal with the dust
Reduce - share the use of the vibrating hand tool amongst more than one employee
Isolate - put the noisy washing machine in a separate room
Control - have interlocks fitted to ensure safe operation
________________________
Personal Protective Equipment - safety glasses to stop grinding dust from entering the eyes
Discipline - train rail workers how to work safely near to a live rail.

ERIC/PD is derived from the Principles of Prevention in schedule 4 of the

Management Regs
22. HSG-65 “Successful Health & Safety Management” is a guidance (H&S management
model), developed by HSE (Health & Safety Executive) - UK.

The HSG 65 model which is not certifiable, was first prepared by the HSE in 1991 as a practical
guide for directors, managers, health and safety professionals and employee representatives
who wanted to improve health and safety in their organisations.

The message it conveys is simple: organisations need to manage health and safety with the
same degree of expertise and to the same standard as other core business activities, if they
are to control risks effectively and prevent harm.

The guide provides sound advice on good practice in health and safety management. Some of
the actions it advocates go beyond what is strictly required by legislation, for example, there is
no general, legal duty to audit.

In any management system, involving employees and their representatives can make a key
contribution to securing the objectives, such as improving health and safety.

The system framework, together with legal requirements, also provides the basis for
Inspectors when auditing an organisation's arrangements for managing health and safety.

HSG 65 has five key elements:

 policy;
 organising;
 planning and implementing;
 measuring performance; and
 auditing and reviewing performance.
23. In 1969 Frank Bird devised an accident ratio triangle, he had researched that for every 600
incidents with no visible injury or damage there would be one serious or disabling injury.

24. The Bradley Curve is a tool developed by Du Pont to measure the injury rates against
behaviours and culture within a business. You start off with an organization in the
Reactive stage, where workers are reacting to incidences instead of thinking about how to
prevent them.  Once employees begin to view safety as something important to them and
something which they value, you move to the Independent stage.  This is where they are
practicing safety because they want to do it, not because they are being told to do it.  The
ultimate goal is the Interdependent stage when every employee is looking out for the
other.  It's a "brother's keeper" mentality.  At this stage, any employee should be
comfortable to call out a safety issue to the point where they will stop a line if they see a
problem or stop a manager who, for example, isn’t wearing a hard hat.

Safety Excellence Requires A Culture Shift

Na Involvement / Ownership by All Employees
tu
ra
l In
sti
nc
ts

Sup
Injury Rates

erv
isio
n

Self

Teams

Reactive Dependent Independent Interdependent

• Safety by Natural • Management • Personal Knowledge, • Help Others Conform
Instinct Commitment Commitment, & • Others’ Keeper
• Compliance is the • Condition of Employment Standards
• Networking
Goal • Fear/Discipline • Internalization Contributor
• Delegated to Safety • Rules/Procedures • Personal Value • Care for Others
Manager • Care for Self
• Supervisor Control, • Organizational Pride
• Lack of Management Emphasis, and Goals • Practice, Habits
Involvement
• Value All People • Individual Recognition
• Training
Copyright © 2007 DuPont. All rights reserved. The DuPont Oval Logo, DuPont™, and The miracles of science™ are registered trademarks or trademarks of DuPont or its affiliates.
25. Candidates should demonstrate the knowledge of the construction and continual
development of the SWMP and the categories of waste and how to dispose of the
materials in the correct manner. Guidance to this is as follows:

SWMP aim is to address the two key issues:

1. improving materials resource efficiency, by promoting the economic use of

construction materials and methods so that waste is minimised and any waste that is
produced can be re-
ways before disposal options are explored; and
2. reducing fly-tipping, by restricting the opportunities available for the illegal disposal of
waste by ensuring compliance with existing legal controls and providing a full audit trail
of any waste that is removed from the construction site.

Although it is a legal requirement to write and implement a SWMP, the greatest cost
savings are likely to be achieved as a result of the consideration of materials resource
efficiency which will be a necessary part of the preparation, before the SWMP is drafted.
The flowchart below shows how this might work during the various stages in a
construction project.

You will need a SWMP if the construction work you are planning will cost more than
£300,000. SWMPs can save you money, but only if you use them to challenge the way you
use your resources. By thinking about minimising waste from the outset you can save
money on materials, disposal costs and
labour and make a real difference to your bottom line. They should also make tracking
your waste more straightforward as you will keep or log all waste paperwork in one
document. This will help you to comply with the waste duty of care and reduce the risk of
fly-tipping.

How to write and implement a SWMP

Your legal duty

The requirement to prepare, update and implement a SWMP is set out in the Site
Waste Management Plans Regulations 2008 (SI 2008 no.314) which came into effect on 6
April 2008. In accordance with these Regulations any client intending to carry out a
construction project on one site1 with an estimated cost greater than £300,000 must,
before work begins, prepare a SWMP. Under the transitional arrangements, if a project is
planned before 6 April 2008 and the construction work begins before 1 July 2008 then the
requirement to prepare and implement a plan does not apply. Evidence of consent,
building regulations approval or relevant contract documents.

The cost of the construction project is the price agreed by the contractor and client in the
accepted tender. If there is no tender, the cost must include labour, plant and materials,
overheads and profit, but VAT is excluded (cost of consultants need not be included).
Standard costings for these different
elements are readily available from sources such as the British Cost Information Service
(BCIS).
Since the plan must be in place before work begins, if the cost of the project is less than
£300,000 at the start, but subsequently increases, there is no legal requirement to
produce one retrospectively. However, as a tool for minimising waste and ensuring
compliance with the waste controls, construction companies may find it helpful to use the
SWMP process to manage later changes to the project, especially where this affects the
use of materials or handling of waste on-site.

The plan must be implemented and then updated as construction proceeds, with a greater
level of detail for projects that cost more than £500,000. All waste transactions must be
recorded or referenced in the plan to prevent the likelihood of fly-tipping. Finally, once the
project is completed, the plan should be reviewed and must record the reason for any
deviation from the planned arrangements.

However, as long as all the information requirements in the Regulations are included, the
layout of the plan can be varied to suit existing site management records. For example,
some of the required information may already be held in other documents such as the
health and safety file. Such information may simply be ‘cut and paste’ across, otherwise
copied into, or adequately referenced in, the SWMP.

In the plan you will need to describe a set of waste management estimates against which
you will compare performance as the construction project progresses. First you will need
to forecast how much waste is likely to be produced on site and then for each type of
waste, the proportion that will be re-used or recycled on site, or removed from the
construction site for re-use, recycling, recovery or disposal elsewhere.
Types of waste

“Waste” is defined in Article 1(1)(a) of the Waste Framework Directive (2006/12/EC) and
means “..any substance or object…which the holder discards or intends or is required to
discard”. All waste that falls within the scope of this definition should be recorded in the
Site Waste Management Plan. “Holder” means “the producer of the waste or the natural or
legal person who is in possession of it”. It rests, in the first place, with the producer or
holder of a substance or object to decide whether it is being discarded and is waste.
There is now a substantial body of case law by the European Court of Justice (ECJ) on
the interpretation of the definition of waste and the meaning of “discard”. In a Site Waste
Management Plan, as a minimum, you will need to classify any waste produced on the site
as either inert, non-hazardous, or hazardous2.

Hazardous waste

If the construction project is producing hazardous waste, before allowing any waste to be
removed you must first notify the Environment Agency that you are a hazardous waste
producer.
During the construction phase the principal contractor must update the plan as waste is
disposed of, re-used, recycled, or otherwise recovered. In this way the SWMP should
become a ‘living’ document that describes the current state of progress against the waste
management forecasts contained in the plan.

When waste is removed from the site you, as principal contractor, must show in the
SWMP that you are complying with the waste management licensing, waste duty of care
and waste carrier registration regimes. The duty of care requires you to take care of your
waste while it is in your control, check that the person to whom you give your waste is
authorised to receive it, complete, exchange and keep waste transfer notes when the
waste is handed over and take all reasonable steps to prevent unauthorised handling or
disposal by others.

For higher cost projects, all registration and waste transfer documents should be in the
SWMP or referenced in the plan. Persons authorised to remove or receive waste may
include council waste collectors, registered waste carriers, holders of a waste
management licence or pollution prevention and control permit or holders of an
exemption from the need for such a licence or permit. Checks should be carried out on
sub-contractors before they come on-site to ensure they are legally compliant.

Waste duty of care

The waste Duty of Care is a legal requirement under Section 34 of the Environmental
Protection Act 1990. Detailed requirements for waste transfer notes are set out in the
Environmental Protection (Duty of Care) Regulations 1991. A guide to these duties
entitled ‘Waste Management – the Duty of Care Code of Practice’ was published by the
Government in March 1996.

In order to secure longer term improvements in materials resource efficiency, you should
review performance against the SWMP following completion of the project. For projects
between £300,000 and £500,000 you should describe in the plan any deviation between
the first draft of the SWMP and the final outcome.

For projects that cost more than £500,000 a more detailed analysis is required, both
confirming that the plan has been periodically updated, and calculating the difference
between proposed waste management and actual performance. You
should also estimate the cost savings that you have achieved through the SWMP process.

Who should write and implement a SWMP?

The client is responsible for ensuring that the plan is prepared before construction work
begins. For many projects it will be appropriate for the designer to write the SWMP on
behalf of the client, as this will assist in recording any decisions that have been taken at
the design stage. The plan should then be passed to the principal contractor, who must
update it as work progresses and ensure that workers on the site are aware of the plan
and co-operate with it. This will include providing suitable site induction, information and
training. Contractors will in turn need to engage their employees and sub-contractors to
ensure that any waste management objectives in the SWMP are understood and achieved.

The roles of client and principal contractor are already well-established in the
Construction (Design and Management) Regulations 2007. It is the responsibility of the
client to appoint a principal contractor for the purposes of the SWMP Regulations if one
or more contractors are working on the project3. Where a project does not use a
contractor, responsibility for updating the plan remains with the client.
It is important to remember that responsibility for compliance with the SWMP
Regulations rests not solely with an individual but ultimately with the client or
principal contractor company. If there is a change of personnel during the course of the
project, the details of those responsible for the plan must be kept up-todate.
Responsibility for carrying out the waste management tasks in the SWMP should fall to
the relevant contractors and sub-contractors. Such tasks should be written into the terms
of contracts to ensure understanding and accountability at all levels.

This is consistent with recent changes in waste legislation that have

removed the defence of acting under the instructions of an employer. It makes good
business sense to make payments for waste disposal only when evidence of delivery to
an authorised site has been provided. Periodic checks and audits will also help to
minimise the risk of fly-tipping. Although the principal contractor is responsible for
updating the SWMP and ensuring compliance and co-operation amongst the workers, the
client will continue to have a role in ensuring its effective implementation.

The client must give any reasonable direction to contractors that is necessary to ensure
compliance, for example, in setting contractual obligations. A SWMP needs to be a
working document which is comprehensible to all users. As a result, it needs to be both
accurate and clear.

Both the client and the principal contractor are responsible for reviewing, revising and
refining the SWMP as necessary, in particular, to ensure that roles and responsibilities
are clear as the project progresses. They must also ensure that adequate security
measures are put in place to help avoid waste being disposed of illegally at the site.

What should be recorded in a SWMP?

A SWMP will need to forecast how much of each type of waste will be produced on site
and how it will be managed. But before this, decisions may already have been taken on
the design, construction method and materials that will reduce the amount of waste. Such
decisions should be recorded in the plan before addressing the waste that cannot be
avoided. For this residual waste, explore the options for reusing or recycling on-site
before you consider any off-site possibilities for re-use, recycling, other types of recovery
or disposal. The plan also needs to identify the location of the site and the individuals
responsible for preparing and implementing it. A summary of the details required in the
first draft of the plan is set out below:

Responsibilities
1. The client
2. The principal contractor
3. The person who drafted the plan
Description of the Construction Works
4. The location of the construction site
5. The estimated cost of the project
Materials Resource Efficiency
6. Any decision taken before the SWMP was drafted to minimise the quantity of waste
produced on site.

This statement should provide information on any consideration given to

materials resource efficiency in designing and planning the construction. This
may include design specifications, the choice of materials used or method of
construction, such as pre-fabrication. Preliminary records of decisions taken on materials
resource efficiency may begin at the earliest stages of the project, and copies of related
documentation can be used to help complete this section of the SWMP.

Waste Management
7. Describe each waste type expected to be produced during the project
8. For each waste type estimate the quantity of waste that will be produced
9. For each waste type identify the waste management action proposed
(including re-use, recycling, other types of recovery and disposal)
As a minimum the description of waste types should be recorded as inert, nonhazardous
or hazardous, with further identification of individual waste streams allowing the
proposed waste management route to be determined for each. The quantity of waste
should usually be specified either in m3 or tonnes. Tools are available to help in
estimating waste volumes.
Proposed waste management actions

“Recovery” is defined in Article 1(1)(f) of the Waste Framework Directive

(2006/12/EC) as meaning any of the operations provided for in Annex IIB to the Directive.
However, the list in Annex IIB is not exhaustive and the ECJ has ruled that “…the
essential characteristic of a waste recovery operation is that its principal objective is that
the waste serve a useful purpose in replacing other materials which would have had to be
used for that purpose, thereby conserving natural resources”. “Re-use” and “recycling”
are forms of waste recovery. “Disposal” is defined in Article 1(1)(e) of the Waste
Framework Directive as meaning any of the operations provided for in Annex IIA to the
Directive.

Waste Controls and Handling

A declaration that all waste produced on the site is dealt with in accordance
with the waste duty of care.4
A declaration that materials will be handled efficiently and waste managed
appropriately.

Both the client and principal contractor are specified in these declarations which must be
written into the plan, confirming that both parties are responsible for ensuring the
effective management and handling of materials and waste on site and that any waste
disposal is carried out legitimately. Section 2.1 of this guidance outlines the requirements
of the waste duty of care, and by completing the SWMP and following the
recommendations and advice in this guidance, clients and principal contractors will be
able to demonstrate that they have taken reasonable steps to ensure compliance.
4 Section 34 of the Environmental Protection Act 1990 and the Duty of Care Regulations
1991.

Appropriate management of waste will include ensuring that other legislative

requirements are complied with, in particular, the need to provide ’basic
characterisation’ of any wastes destined for landfill, proposals to meet the
obligation for the pre-treatment of wastes prior to landfilling, securing any
necessary waste management licences or exemptions, and compliance with the
hazardous waste controls. Information about agreed practices for the handling and
storage of materials should also be included in the plan.

Under landfill legislation each type of waste to be accepted at a landfill shall be

characterised to ensure all information necessary for the safe disposal of the waste in the
long tem is available. The information needed for basic
characterisation includes, but is not limited to, the information that needs to be recorded
on the waste description, including fulfilment of the Duty of Care.

Also under the Landfill Directive only waste that is subject to treatment may be landfilled.
Treatment means a physical, thermal, chemical or biological process, including sorting,
that changes the characteristics of the waste in order to reduce its volume, or hazardous
nature, facilitate its handling or enhance recovery. The treatment requirement may not
apply to inert waste for which treatment is not technically feasible. The EA has also
produced ‘Your waste - your responsibility’ guidance for Businesses.

The requirements of the Hazardous Waste Regulations include the notification of

premises producing hazardous waste to the Environment Agency, the completion of
consignment notes to accompany the movement of the waste, the keeping of records and
a prohibition on mixing waste.

When should a SWMP be updated?

A SWMP should be updated as often as necessary to give a current picture of how work is
progressing against the waste estimates contained in the plan. So for waste that is re-
used or recycled on site, the SWMP should be updated to describe how much of the
estimated volume or tonnage has been processed. For waste that is removed from the
site the SWMP must be updated to record the identity of the person removing the waste,
the type (and quantity) of waste and the site to which it has been taken. For lower value
projects between £300,000 and £500,000 you will only need to
provide summary information, whereas for projects over £500,000 more detail will be
required. The level of detail in SWMP updates for lower and higher cost projects is set out
below:

Projects between £300,000 and £500,000

Whenever waste is removed from the site the principal contractor (or client, if
there is no principal contractor) must record on the plan the identity of the person
removing the waste, the type of waste and the site to which it is being taken. The ‘person’
will usually be the waste management contractor appointed to deal with that waste, and
the name of the company should be recorded.
Projects over £500,000

For higher cost projects, whenever waste is removed from the site the principal
contractor (or client, if there is no principal contractor) must record on the plan the
identity of the person removing the waste, the waste carrier registration number of the
waste carrier and a copy of, or reference to, the written description of the waste. The
written description will either be a waste transfer note or for hazardous waste, a
hazardous waste consignment note. The site that the waste is being taken to and whether
it is a licensed or exempt site must also be recorded.
Further detail is then required on the actual waste management actions. The
plan must be updated at least every 6 months to record the types and quantities of waste
that are:
(i) re-used (and whether on or off-site)
(ii) re-cycled (and whether on or off-site)
(iii) sent for another form of recovery (and whether on or off-site)
(iv) sent to landfill
(v) otherwise disposed of

Figures on the amount of re-use and recycling, and whether this takes place on or off-site,
should be provided wherever possible. Category (iii) should then be used to record waste
that is sent for any other type of recovery, for example, this may include:
• physical sorting (where this results in recovery of one or more components
of the sorted waste)
• chemical or biological treatment
• composting
• incineration with energy recovery
• remedial treatment of soil

Category (v) should be used for any other type of disposal, including burning
without recovery and where it is not possible to record known quantities of mixed waste
that are destined for options (i)-(iv).
If significant changes are made during the course of the project, or the plan
requires substantial revision, the Regulations allow for a further plan to be
produced.

What happens once the project is completed?

At the end of the project the completed SWMP with records of all waste
management actions needs to be reconciled against what was planned before work
began. Regular updating during the construction phase should make this a relatively
straightforward process. This final review will also allow the construction company to
identify where forecasts were exceeded or missed, and to learn lessons for the next
project. Companies might also use this opportunity to estimate the level of cost savings
achieved, and this is required for higher cost projects.

For projects between £300,000 and £500,000 in cost the following information must be
added within three months of the work being completed:

1. confirmation that the SWMP has been monitored on a regular basis to ensure that work
is progressing according to the plan and that the plan was updated appropriately; and
2. an explanation of any differences between the first draft of the SWMP and
actual performance.

For projects over £500,000 in cost as well as the information above, the
following information must be added within three months of the work being
completed:

3. an estimate of the cost savings that have been achieved by completing and
implementing a SWMP.
There is no requirement for firms to produce an action plan for each project
detailing how lessons learnt may be addressed in future, however, drawing on such
learning can help maximise the benefits and savings to be gained from SWMPs. Clients,
principal contractors, designers and others involved in the planning and execution of
projects may therefore wish to consider the most appropriate way of integrating the
outcome of SWMPs into further construction work. It may be helpful, for example, to
undertake a regular audit or review process of company SWMPs involving all key players,
or to produce an overarching action plan building on the findings of a number of projects.
Keeping SWMPs

You must keep your SWMP somewhere where it is accessible by anyone

carrying out a regulatory compliance check. During construction you must keep the
SWMP at the site office, or where there is no site office, at an appropriate place on the
construction site (electronically or on paper). You must ensure that every contractor
knows where it is kept and must make it available to any contractor carrying out work
described in the plan. For practical reasons it might be advisable to make multiple copies
of the planned waste management actions, but if you do, make sure that there remains
just one master copy and that all duplicates are dated and updated accordingly. In line
with other waste management legislation, you are required to keep the SWMP for two
years5 after completion of the project at the principal place of business or the site of the
project.

1 There is no legal requirement for a project of contract value greater than £300,000 but
undertaken over multiple sites (clearly geographically separate) to undertake a SWMP although
the client/contractor may decide that it is in their interests to do so.
2 Hazardous waste is defined in Regulation 6 of the Hazardous Waste Regulations 2005
SI2005/894).
3 Clients are, in any case, required to appoint a principal contractor for all notifiable projects
under the CDM Regulations 2007.

Conception and design

(client, in conjunction with designers and planners)
􀂃 Consider materials and methods of construction that produce the minimum amount of waste.
Site design and tendering
(client, in conjunction with designers, planners and, once appointed, the principal contractor)
􀂃 Draft SWMP identifying waste types
􀂃 Record design stage considerations
􀂃 Build waste management targets into tender specifications
Construction Phase
(principal contractor, in conjunction with all contractors on site)
􀂃 Regular toolbox talks with workers
􀂃 Adequate ordering, delivery, and storage of materials
􀂃 Update SWMP as waste is processed or removed
Post-completion
(principal contractor and, for lessons learnt, all parties)
􀂃 Reconcile final waste data with SWMP
􀂃 Calculate resource savings
􀂃 Apply lessons learnt for future projects
26. Basic Theories of Accident Causation

Accident causation models were originally developed in order to assist people who had to
investigate occupational accidents, so that such accidents could be investigated
effectively.
Knowing how accidents are caused is also useful in a proactive sense in order to identify
what types of failures or errors generally cause accidents, and so action can be taken to
address these failures before they have the chance to occur.

The Domino Theory

In 1931, the late H.W. Heinrich (Heinrich et al, 1980) presented a set of theorems known as
‘the axioms of industrial safety’. The first axiom dealt with accident causation, stating that
‘the occurrence of an injury invariably results from a complicated sequence of factors, the
last one of which being the accident itself.’
Alongside, he presented a model known as the ‘domino theory’ as this accident sequence
was likened to a row of dominoes knocking each other down in a row. The sequence is:-

 Injury, caused by an;

 Accident, due to an;

 Unsafe act and/or mechanical or physical hazard, due to the;

 Fault of the Person, caused by their;

 Ancestry and Social Environment.

The accident is avoided, according to Heinrich, by removing one of the dominoes,

normally the middle one or unsafe act. This theory provided the foundation for accident
prevention measures aimed at preventing unsafe acts or unsafe conditions.

The first update of the Domino Theory was presented by Bird & Loftus [ Heinrich et al,
1980; Bird & Germain, 1986]. This update introduced two new concepts;

 The influence of management and managerial error;

 Loss, as the result of an accident could be production losses, property damage or

wastage of other assets, as well as injuries.

This model (known as the International Loss Control Institute or ILCI model) is shown in
the figure below:
 The domino model has been noted as a one-dimensional sequence of events. Accidents
are usually multi-factorial and develop through relatively lengthy sequences of changes
and errors’. This has led to the principle of multiple causation.

According to Peterson (1978), behind every accident there lies many contributing factors,
causes and sub-causes. The theory of multiple causation is that these factors combine
together, in random fashion, causing accidents. So, during accident investigations, there
is a need to identify as many of these causes as possible, rather than just one for each
stage of the domino sequence.
The accident model is in reality an amalgam of both the domino and multi-causality
theories, such as that shown below.

ROOT CAUSE BASIC CAUSE IMMEDIATE CAUSE INCIDENT

(Lack of Control) LOSS
 cause a   cause d   cause f 
 cause b  cause e
 cause c
  

Conclusion

 All accidents whether major or minor are caused, there is no such thing as an
accidental accident!!

 Very few accidents, particularly in large organisations and complex technologies are
associated with a single cause.

 The causes of accidents are usually complex and interactive.

27. CDM 2007 categorises five main duty holders, namely clients, designers, contractors and, for
"notifiable" projects only, a CDM co-ordinator and a principal contractor. The previous division
between "notification" and "application" under CDM 1994 has been replaced with a division
between "notifiable" and "non-notifiable" projects. A project is notifiable (and additional
requirements apply) if the construction phase is likely to involve more than 30 days or 500 person
days of construction work.

All duty holders have various general obligations, including:

they may only appoint competent duty holders (ACoP includes detailed requirements);
cooperating with others concerned in the project to enable compliance with CDM 2007; and
coordinating their activities with one another to ensure the health and safety of all those
involved in or affected by the construction work.
Clients
Clients are now obliged to take reasonable steps to ensure there are adequate management
arrangements for health, safety and welfare at a site. It is no longer possible for a client to appoint a
"Client's Agent" to assume the client's responsibilities (including any criminal liabilities), although
a group of clients can appoint one or more of them to be the client for CDM purposes (the other
clients retain certain obligations).
For all projects (whether notifiable or nonnotifiable) the client's obligations include:

taking reasonable steps to ensure management arrangements are put in place and maintained
which ensure there is (as far as reasonably practicable) no risk to the health and safety of any
person; and
ensuring every designer and contractor is given pre-construction information.

Additional obligations for notifiable projects include:

appointing a CDM co-ordinator and principal contractor (if there are no such appointments the
client is deemed to fulfil these roles);
providing pre-construction information to the CDM coordinator;
ensuring construction does not begin until the principal contractor has prepared a suitable
construction phase plan and welfare facilities can be provided
ensuring the CDM co-ordinator has all the health and safety information necessary for the health
and safety file

Contractors
For all projects (whether notifiable or nonnotifiable) a contractor's obligations include:
ensuring before starting work that the client is aware of its CDM duties and that reasonable
steps have been taken to prevent unauthorised access to the site;
planning and managing their work so that, as far as reasonably practicable, it is carried out
without risks to health and safety;
ensuring that any contractor he engages in connection with a project is informed of the
he begins construction work; and
providing workers under its control with suitable information, training and welfare facilities.
Additional obligations for notifiable projects include:
not commencing work until he has the names of the CDM co-ordinator and principal contractor
and he has the relevant part of the construction phase plan and knows that notice has been given
to the Health and Safety Executive (the "HSE");
supplying health and safety information and names of any subcontractors to the principal
contractor;
complying with the site rules and directions of the principal contractor
taking all reasonable steps to ensure that construction work is carried out in accordance with
the construction phase plan.

Designers
Under CDM 1994, designers had no duty to ensure that their designs were safe to use. However,
CDM 2007 requires the designer to (amongst other things):
ensure before starting work that the client is aware of its CDM duties;
where possible eliminate hazards giving rise to risks and reduce residual risks
provide design information to assist others to comply with their CDM duties.
Additional obligations for notifiable projects include:
 not commencing work(other than initial design work) until after a CDM co-ordinator is appointed.
One of the changes brought in by CDM 2007 has been to broaden the definition of designers. There
is now a remote risk that a landlord under an agreement for lease or
licence to alter who approves or disapproves of its tenant's works may fall within the new
definition. If the landlord is held to be a designer and is found to have breached the designer
duties, they will be liable to a fine. As a result, landlords must take care not to have any input into
the design process.

CDM Co-ordinator
On notifiable projects the client must appoint a CDM co-ordinator as soon as practicable after initial
design work or other preparation for construction work begins.
The CDM co-ordinator must notify the project to the HSE and (amongst other things):
assist and advise the client on their CDM duties, the competence of appointees and adequacy of
arrangements for controlling risks;
facilitate coordination of health and safety measures by those involved
in the project.
prepare, collate and distribute health and safety information including the health and safety file.
Only initial design work should be done before the CDM co-ordinator is appointed. As project
originators are legally the client at the start of the project, clients need to consider the early
appointment of a CDM co-ordinator if anything more than initial design work is to be carried out.
For example, public sector bodies using competitive dialogue processes may need to appoint a
CDM co-ordinator early in those processes (before a successful tenderer is selected).
 Principal Contractor
On notifiable projects the client must appoint a principal contractor as soon as practicable. Their
duties are primarily the same as for contractors, though the principal contractor must also
(amongst other things):
prepare, review and update a construction phase plan which ensures, so far as reasonably
practicable, that work can be executed without risk to health and safety (if necessary it must
consult contractors as relevant before finalising the plan);
draw up site rules;
plan and monitor construction to ensure that, so far as reasonably practicable, it is carried out
without risks to health and safety.
give reasonable directions to contractors and ensure contractors have sufficient information to
carry out their work without risk to health and safety.

28. The health and safety plan should set out the arrangements for securing the health and safety of
everyone carrying out the construction work and all others who may be affected by it.
It should deal with:
the arrangements for the management of health and safety of the construction work;
the monitoring systems for checking that the health and safety plan is being followed;
health and safety risks to those at work, and others, arising from the construction work, and from
other work in premises where construction work may be carried out.

What should go in the construction phase health and safety plan?

General
Not all information relating to the project may be available to fully develop the health and safety
plan before the start of construction. This could be because not all the design work may have been
completed or many of the subcontractors who will be carrying out the work may not yet have been
appointed. However, site layout drawings covering the project at different stages, completed
design information and the pre-tender stage health and safety plan will be valuable in developing
the health and safety plan so that:
the general framework is in place (including arrangements for welfare)
it deals with the key tasks during the initial work packages where design is complete.
For projects where a significant amount of design work will be prepared as construction proceeds,
specific arrangements for dealing with this work may need to be set out in the health and safety
plan. This is important to ensure that the health and safety aspects of the design work are
considered and dealt with properly by
designers and the planning supervisor. This will particularly occur under the various design and
build and management contracting forms of procurement.
The health and safety plan will need to be added to, reviewed and updated as the project develops,
further design work is completed, information from the subcontractors starting work becomes
available, unforeseen circumstances or variations to planned circumstances arise, etc.

What should the health and safety plan start with?

The health and safety plan can usefully open with:
a description of the project;
a general statement of health and safety principles and objectives for the project; information about
restrictions which may affect the work (eg, neighbouring buildings, utility services, vehicular and
pedestrian traffic flows and restrictions from the work activities of the client).
What arrangements should be set out in the health and safety plan for managing and organising
the project?
These can include:
1 management
the management structure and responsibilities of the various members of the project team, whether
based at site or elsewhere;
arrangements for the principal contractor to give directions and to co-ordinate other contractors.
2 standard setting
the health and safety standards to which the project will be carried out. These may be set in terms
of statutory requirements or higher standards that the client may require in particular
circumstances.
3 information for contractors
means for informing contractors about risks to their health and safety arising from the
environment in which the project is to be carried out and the construction work itself.
4 selection procedures
The principal contractor has to make arrangements for ensuring that:
all contractors, the self-employed and designers to be appointed by the principal contractor are
competent and will make adequate provision for health and safety;
suppliers of materials to the principal contractor will provide adequate health and safety
information to support their products; machinery and other plant supplied for common use will be
properly selected, used and maintained; and that operator training will be provided.
5 communications and co-operation
means for communicating and passing information between the project team (including the client
and any client’s representatives) the designers, the planning supervisor, the principal contractor,
other contractors, workers on site and others whose health and safety may be affected;
arrangements for securing co-operation between contractors for health and safety purposes;
arrangements for management meetings and initiatives by which the health and safety objectives
of the project are to be achieved;
arrangements for dealing with design work carried out during the construction phase, ensuring it
complies with the duties on designers and resultant information is passed
to the appropriate person(s).
6 activities with risks to health and safety
Arrangements need to be made for the identification and effective management of activities with
risks to health and safety, by carrying out risk assessments, incorporating those prepared by other
contractors, and including the resultant health and safety method statements. These activities may
be specific to a particular trade (eg falsework) or to site-wide issues, and may include:
the storage and distribution of materials;
the movement of vehicles on site, particularly insofar as this affects pedestrian and vehicular
safety;
control and disposal of waste;
the provision and use of common means of access and places of work;
the provision and use of common mechanical plant ;
the provision and use of temporary services (eg, electricity);
temporary support structures (eg, falsework);
commissioning, including the use of permit-to work systems;
protection from falling materials;
exclusion of unauthorised people.
Control measures to deal with these should be clearly set out, including protection of members of
the public.
7 emergency procedures
emergency arrangements for dealing with and minimising the effects of injuries, fire and other
dangerous occurrences.
8 reporting of RIDDOR information
arrangements for passing information to the principal contractor about accidents, ill health and
dangerous occurrences that require to be notified to the Health and Safety Executive (HSE) under
the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 1995.
9 welfare
the arrangements for the provision and maintenance of welfare facilities.
10 information and training for people on site
Arrangements need to be made by which the principal contractor will check that people on site
have been provided with:
health and safety information;
health and safety training; and
information about the project (eg relevant parts of the health and safety plan);
Arrangements also need to be made for:
project specific awareness training;
tool-box or task health and safety talks;
the display of statutory notices.
11 consultation with people on site
arrangements that have been made for consulting and co-ordinating the views of workers or their
representatives.
12 site rules
arrangements for making site rules and for bringing them to the attention of those affected. The
rules should be set out in the health and safety plan. There may be separate rules for contractors,
workers, visitors and other specific groups.
13 health and safety file
arrangements for passing on information to the planning supervisor for the preparation of the
health and safety file.
14 arrangements for monitoring
Arrangements should be set out for the monitoring systems to achieve compliance with:
legal requirements;
the health and safety rules developed by the principal contractor through regular planned checks,
and by carrying out investigations of incidents (whether causing injury, loss, or ‘near miss’) and
complaints.
This may involve:
co-operation and regular meetings between senior management and those who provide health and
safety advice to them.
This may also involve monitoring of:
procedures, eg contractor selection and the management of certain trades;
on-site standards actually achieved compared with those set for the project;
reviews throughout the project, as different trades complete their work and at its conclusion. This
means that the lessons learnt in terms of the standards that were set and those actually achieved
can be taken forward.
29. Health and Safety File
A health and safety file is required for notifiable projects, which must contain information in
respect of the project needed for future construction work, including cleaning, maintenance,
alterations, refurbishments and for demolition to be carried out safely. Various specific matters
must also be addressed by the file. Various parties have legal duties in respect of the health and
safety file, including that:
CDM co-ordinators must prepare, review and amend or add to the file as the project progresses
and provide it to the client at the end of the project; and
clients, designers, principal contractors and other contractors must supply the information
necessary for compiling or updating the file.

30. General duties of employees at work.

7. It shall be the duty of every employee while at work

 to take reasonable care for the health and safety of himself and of other persons who may be
affected by his acts or omissions at work; and
 as regards any duty or requirement imposed on his employer or any other person by or under
any of the relevant statutory provisions, to co-operate with him so far as is necessary to
enable that duty or requirement to be performed or complied with.

Duty not to interfere with or misuse things provided pursuant to certain provisions.

8. No person shall intentionally or recklessly interfere with or misuse anything provided in the
interests of health, safety or welfare in pursuance of any of the relevant statutory provisions.