Model Policy

Health and Safety Arrangements for the Appointment and Management

of Sub-Contractors

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Reviewed March 2022

Organisations should include this section in their policy’s arrangements section if they are a contractor who uses sub-
contractors to undertake work on client sites. Please note that this policy is applicable to construction work only. Alter
and add to this policy as necessary.

Health and Safety Arrangements for the Appointment and Management of Sub-Contractors

Introduction

We recognise that when we, as the contractor, engage sub-contractors to work on our behalf, we have obligations to
plan, monitor and control their work for the safety of everyone who could be affected by their activities. This includes
not only the safety of the work when it takes place, but the quality of the workmanship which protects those using and
maintaining the premises once the work is completed.

The sub-contractor also holds similar responsibilities and it is therefore our policy to work together with our carefully
selected competent sub-contractors to ensure that work is undertaken safely and without risk to health.

When contracting construction work, we as the contractor recognise our responsibilities under the Construction
(Design and Management) Regulations 2015 (CDM) for work with sub-contractors, which apply as soon as we are
appointed to a project to undertake construction work. Specifically:

 Ensuring that any sub-contractors and workers appointed by us have the skills, knowledge, experience and
training to carry out the work safely (or is in the process of obtaining them).
 Promptly sharing with appointed sub-contractors any pre-construction information provided by the client or the
client’s representative.
 With input from our sub-contractors, drawing up a construction phase plan setting out the health and safety
arrangements and site rules (OR when another company is the principal contractor (PC), contributing to the
construction phase plan and site rules developed by the PC, including providing the PC with input on health
and safety matters highlighted by our sub-contractors).
 Ensuring that none of our sub-contractors, nor our own personnel, commence work until we are satisfied that
the client is aware of the duties owed by them under CDM.
 Planning, managing and monitoring work under our control so that as far as is reasonably practicable, it is
carried out without risks to health or safety (both to workers and members of the public).
 Passing on any directions given by a principal designer (PD) or PC and ensuring that these are complied with,
or, where it is not practical to comply, that the matter is swiftly drawn to the PD or PCs attention.
 Ensuring that there is adequate supervision, instruction and information so that construction work can be
carried out without risk to health or safety, including: (1) a site-specific safety induction; (2) emergency
procedures; and (3) information about risks and precautions as identified within our own or others risk
assessments.
 Ensuring that work does not begin unless reasonable steps have been taken to prevent access by
unauthorised persons to the site and adequate welfare facilities are provided for workers.
 Ensuring that any design or specification work, including temporary works, is carried out in compliance with
the designer’s duties described within CDM 2015.
 Ensuring those carrying out the work have the right plant, tools, equipment, materials, PPE.

We also have obligations to cooperate and coordinate with other employers who share a workplace under Regulation
11 of the Management of Health and Safety at Work Regulations 1999.
Our ___________________________________ [job title] has responsibility for planning and coordinating our work on
site, including the work of sub-contractors.

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This individual is responsible for ensuring that the legal requirements described are complied with by implementing the
detailed arrangements which follow.

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Detailed arrangements

Competence assessment

We select sub-contractors based on technical competence, experience and suitability for the work to be done. In
particular our assessment process involves a review of past performance and requested information from the sub-
contractor including:

 Track record of experience in similar contracts.

 Membership of reputable trade bodies or approved contractor schemes.
 Legally required registrations (eg Gas Safe Register).
 Health and safety policies and practices.
 Recent health and safety performance (number of accidents etc).
 Qualifications, training and skills of their staff and manager.
 Health and safety information and training provided to workers.
 Example safety method statements and risk assessments for similar work, if available having consideration to
the size of the sub-contractor.
 Supervision arrangements.
 Arrangements for consulting with their workforce.
 References from previous clients if not previously used by our company.
 Current insurance certificates (employer’s and public liability, professional indemnity, as applicable).

Note that if your company uses an approved contractor list such as Construction Line, CHAS or Safe Contractor to
cover off generic issues, you should describe here how you use that and amend the list of items above which you
check in respect of individual projects.

If you have a specific form for undertaking these sub-contractor reviews, you may wish to include it as an appendix to
this policy. In any case it is recommended that you cross refer to it here.

We also review the HSE’s notices and prosecution database (www.hse.gov.uk/enforce/index.htm) to determine if the
potential sub-contractor has been subject to any formal legal sanction.

Any claim that a sub-contractor is a member of a trade or professional body or an approved contractor scheme is
verified directly with the body to ensure the membership is current and covers the work being offered.

If applicable, describe the approved list of sub-contractors which you maintain.

Essential information provided to sub-contractors

To enable sub-contractors to take account of all issues affecting health and safety within their quote/tender, we
provide essential health and safety information such as pre-construction information provided to us by the client in
good time. So far as it is applicable and relevant to the sub-contractors work on site we will provide details of:

 The work specification and timescales.

 Any restrictions on the time, location or duration in which the work is done.
 Access, parking and road traffic rules.
 Information about other people who could be present on the premises, or could be at risk in the vicinity
[including more vulnerable persons such as children, the elderly, the disabled and those with special
educational needs – amend as applicable].
 Restrictions which will apply to the storage of goods, materials, tools and equipment, skips, site huts and
storage containers.
 Rules regarding the storage of waste awaiting collection, and where applicable for removal of waste from site.
 For any design or specification work already undertaken, any information about risks which could not be
eliminated at the design stage.

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  Smoking restrictions.
 Rules about work on the electrical installation and the use of electrical equipment.
 Requirements for work on or close to any gas system.
 General rules about the need to maintain escape routes and access to fire equipment plus any specific rules
in relation to the project.
 Procedures in the event of an emergency or threat to health and safety.
 Rules requiring the use of personal protective equipment when required as a result of the hazards of the work
[and as required within designated hearing protection/head protection/safety footwear/hi viz areas – delete or
amend as applicable].
 Any particular hazards within the premises such as the presence of asbestos, fragile roofs, overhead or
underground services, confined spaces, reversing vehicles at loading bays etc, anticipated hazards from the
work activities undertaken or other contractors, machinery or hazardous substances (this information will
include copies of our own risk assessments and method statements where applicable).
 Restrictions on the introduction of certain high hazard equipment or processes except where agreed in
advance and subject to a permit to work, eg radioactive sources, cartridge tools, hot work, lifting equipment.
 Restrictions and rules about the use of hazardous substances or generation of noise.
 Rules about work at height including roof work, scaffolds, mobile elevating work platforms and suspended
access equipment when applicable.
 Restrictions on the use of our facilities eg toilets, washing facilities, restaurants and equipment eg forklift
trucks.
 Requirements for supervision and quality assurance.
 The provision of first aid facilities and personnel.
 Any specific qualifications required for particular parts of the job.
 Security clearance arrangements – delete if not applicable.
 Requirements to report all accidents and incidents to our representative immediately (and to client
representatives where required under the project rules).
 The contact details of our representative and requirements for communications.
 Arrangements for dealing with design changes and for reporting that planned methods of work cannot be
adhered to.
 Coronavirus guidelines which may be applicable.

Sub-contractors will not be permitted to appoint sub-contractors. Note that this is not a legal requirement but if you
allow sub-contractors to appoint sub-contractors it becomes extremely difficult to control standards. If you decide to
allow them to appoint sub-contractors describe the additional measures you implement in order to maintain control,
e.g. by providing your own full-time site supervisor.

Note that it is recommended that you have a standardised set of rules and information which you adapt to each
project covering the issues which apply to most contract work. Once you have this in place, cross refer to it in this
section. You may find with such a set of rules in place that you can reduce the list above to reflect only those items to
be covered on a project by project basis.

Once appointed, all sub-contractors will be asked to contribute to the construction phase plan and will be provided
with the current version of the plan prior to them starting work on the project and then periodically as it is updated
whilst the project progresses until they are no longer involved on site.

Receiving information from sub-contractors

Once the sub-contractor is selected, detailed work plans are discussed and the sub-contractor’s risk assessment and
method statement are reviewed. The level of detail of the paperwork expected is proportionate to the complexity of
the work to be undertaken and the risk involved.

If our own employees are working alongside the sub-contractor on site we review our own risk assessments, taking
into account the risk management information which the sub-contractor has provided.

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Authorisation/permits

Where a project has another company appointed as the principal contractor we will provide details to them of any
sub-contractors we have appointed.

We will ensure that no one under our control including any sub-contractor’s employees is authorized to start work on
site until we are satisfied that: (1) the client is aware of the duties owed by them under CDM; (2) there are adequate
security and work segregation arrangements; and (3) there are adequate welfare facilities available for workers.

Sub-contractors representatives are normally required to sign in on arrival and out on leaving and where this is the
case a site register will be provided. If the client or principal contractor requires specific signing in and authorization
procedures to be followed, these requirements will be passed on to the sub-contractor and adherence will be
monitored. The sub-contractor must ensure that each worker is briefed on essential health and safety requirements
and is required to sign that they understand our health and safety rules for the project.

For particularly hazardous work, a permit to work may be required, e.g. for hot work, work in confined spaces,
electrical work etc. Where such hazardous work is likely to take place we will ensure that suitable permits to work are
issued in coordination with the client or principal contractor where those organisations have their own permit to work
procedures. Sub-contractor’s representatives are required to keep a copy of their permit at the place of work which
may be inspected by our representative.

Note that pads of duplicate permit to work forms are available from commercial suppliers. There are also example
permit to work forms on the Barbour service.

Contracts

In the conditions of contract we stipulate that the sub-contractor and all of their employees must:

 Adhere to any safety rules which we have issued.

 Comply with their own method statements or where this is not practicable for any reason, to agree changes
with our representative in advance.
 Comply with all health and safety laws applicable to the work undertaken.
 Comply with the designers’ duties specified within CDM 2015 in relation to any design or specification work
undertaken by the sub-contractor.

The contract also stipulates that our representatives may stop the work at any time if the work is unsafe and that
sanctions may be applied including, if necessary, removal of the sub-contractor’s worker and equipment from the site,
without pay for any work not yet completed.

Briefing

As described within the Authorisation/Permits section above, on arrival at the site, sub-contractor’s representatives are
to be briefed in relation to the following minimum content. This will be added to as appropriate according the project
needs:
 Parking and signing in/out arrangements.
 Any hazards that the workers may create for other building users/the general public.
 Any hazards arising from other activities on site.
 A reminder of the locations of any known asbestos containing materials, rules for working in those areas and
that work must stop immediately if suspect materials are identified or disturbed.
 Agreed safe working methods and the importance of not doing any work which has not been previously
agreed.
 Toilet location and any other welfare facilities for their use.

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  Specific activities requiring a permit to work and how this will be issued and by whom, before the contractor
commences work.
 The fire procedure and smoking rules.
 The need to report any accidents or hazards.
 Arrangements for waste storage and removal.
 Arrangements in place to prevent the spread of Coronavirus.

The briefing will be carried out either by our representative or by a manager/supervisor appointed by the sub-
contractor. In the latter case the content of the briefing, method of briefing, record keeping arrangements will be
agreed in advance.

Supervision

We will ensure that those managing and supervising the work have the right combination of skills, knowledge, training
and experience and that there is an adequate number of supervisors. The supervision provided will need to reflect the
level of risk associated with the work/project.

We will assess the degree of supervision needed, taking account of the skills, knowledge, training, experience and
likely behaviour of the workers.

Monitoring

All work by sub-contractors is monitored periodically to:

 Review progress.
 Check quality of workmanship.
 Check that the workers on site are those expected and who have signed in.
 Identify any problems or unanticipated risks at an early stage.
 Check that work is restricted to the areas anticipated and not creating additional risks by spreading beyond
the agreed area or involving unauthorised work.
 Check that method statements are being followed, that the sub-contractor’s employees are complying with site
rules and that they are generally working in a safe manner.
 Ensure that workers continue to have access to welfare facilities.
 Ensure that any design or specification work undertaken by the sub-contractor meets the requirements of
CDM 2015.

The degree of monitoring depends on the type of work involved. Where monitoring detects poor standards, this is
addressed with the sub-contracting company concerned and, if necessary, monitoring frequency is then increased.
Where appropriate, work is stopped whilst a solution is found.

On an ongoing basis we provide the sub-contractor with: (1) new information on risks to health and safety which have
been identified, e.g. by our own risk assessments, by other parties on the site, through incidents etc; (2) information
about new site safety rules or information supplied by the client or principal contractor; (3) information about design
changes provided by any designer.

Contract review

On completion of works our ______________________________ [job title] ensures that we receive required
certification, operating and maintenance instructions, product guarantees and other necessary health and safety
information and that these are passed to the client or the client’s representative as appropriate.

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He/she also evaluates satisfaction with the subcontractor’s work including quality, compliance and effectiveness of
communications. This information is logged for future reference in order that we can determine whether to use the
sub-contractor for future projects. This review process takes place on completion of the work or, in the case of
contracts for regular work, takes place at least every ______________________ [eg six months].

Where the review indicates that the sub-contractor’s standards are below those required, we would normally
________________________ [describe action taken to avoid using the contractor for future work eg remove them
from our approved list of sub-contractors].

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