13.2 Health and Safety Communication, Consultation, Meetings & Reporting

1. Communication as a Core Knowledge Area

Health and Safety Communication Management is a SACPCMP core knowledge area, and communication, stakeholder management and team building appear throughout the SACPCMP's project and construction management areas. Most serious incidents involve a communication failure: a design hazard not passed on, a change not explained, an instruction not understood, or a warning not heard. The CHSM designs communication channels so that the right information reaches the right people in a form they understand.

2. Statutory Channels in the OHS Act

The Act builds communication and consultation into the workplace:

• Section 7: the chief inspector may direct employers to prepare a written health and safety policy, and the employer must then display it prominently.
• Section 8(2)(e) and (j): employers must provide necessary information, instructions, training and supervision, and must inform employees of the scope of their authority under section 37(1)(b).
• Section 13: employers must inform employees of the hazards of their work, the precautions to be taken, and must inform health and safety representatives of inspections, investigations and formal inquiries.
• Section 17: an employer with more than 20 employees at a workplace must designate health and safety representatives in writing after consultation, at least one for every 50 employees (one for every 100 in shops and offices).
• Section 18: representatives may review the effectiveness of health and safety measures, identify hazards, examine the causes of incidents with the employer, investigate complaints, make representations to the employer and inspectors, and take part in consultations and inspections.
• Sections 19 and 20: where two or more representatives are designated, the employer must establish a health and safety committee and consult it at every meeting. The committee must meet at least once every three months; an inspector may direct a meeting, including where more than 10% of employees request one. Under section 20 the committee may make recommendations to the employer and inspectors, must discuss incidents in which a person was injured, became ill or died and may report on them to an inspector, and must keep records of its recommendations and reports.

3. Information Duties in the Construction Regulations

The Construction Regulations create a chain of information from the client through the designer to the last subcontractor:

• The client gives the health and safety specification to the designer (CR 5(1)(c)) and includes it in the tender documents (CR 5(1)(f)).
• The designer informs the client in writing of known or anticipated dangers relating to construction work and makes the relevant information available, and must take the specification into account (CR 6).
• The principal contractor gives tendering contractors the relevant sections of the specification (CR 7(1)(c)(i)) and makes information and resources available when the design or construction changes (CR 7(1)(c)(ix)); the client has a similar duty to the principal contractor (CR 5(1)(r)).
• The client must make the principal contractor's health and safety plan available on request to an employee, inspector or contractor (CR 5(1)(m)).
• Under CR 9(3), every contractor must ensure that employees under their control are informed, instructed and trained by a competent person on hazards and related work procedures before work starts and at intervals the risk assessment determines; under CR 9(4) the principal contractor must inform contractors of hazards in the risk assessment before work starts; and under CR 9(5) contractors must consult the health and safety committee, or representatives chosen by the employees, on the risk assessments.
• Induction before site entry (CR 7(5)) and visitor induction (CR 7(6)) are the first communication every person receives.

4. Site Communication Tools

• Induction: site-specific, in understandable languages, with comprehension checks.
• Daily safety task instructions (DSTIs) and toolbox talks: short briefings at the work face on today's task, hazards, controls and changes; workers sign after the discussion, not before.
• Pre-task risk assessments and permits: the permit is a communication tool between the issuer, the work team and the area owner.
• Notice boards: the site's health and safety policy, emergency numbers, names of representatives, first aiders and appointed persons, the construction work permit number and safety alerts.
• Signage: standard symbolic safety signs at hazards and exclusion zones.
• Safety alerts and lessons learned: brief notices after incidents or near misses, shared across contractors and projects.
• Radios and alarms: clear channels for plant, cranes and emergencies.

5. Effective Health and Safety Meetings

Typical meetings on a construction project include the monthly client or agent audit close-out, the principal contractor's health and safety committee, weekly contractor co-ordination meetings, and daily start-of-shift briefings. Good meetings have:

• a fixed agenda: previous actions, incidents and investigations, inspection and audit findings, upcoming high-risk work, representatives' concerns, and statistics;
• the right people: decision-makers who can allocate resources, health and safety representatives, and contractors whose work is on the agenda;
• minutes with action items: each action has an owner and a due date and is reviewed at the next meeting;
• records kept in the health and safety file, because section 20 requires the committee to keep records of its recommendations and reports, and inspectors and auditors will ask for them.

6. Monthly Reporting

The CHSM's monthly report to the client and management summarises hours worked, incidents, leading and lagging indicators (Section 12.2), audit results, open NCRs, significant changes, and planned high-risk activities. It should lead to decisions. The client's agent uses it, together with the 30-day audit under CR 5(1)(o), to confirm that the plan is being implemented.

7. Communicating with a Diverse Workforce

South Africa has twelve official languages, and site workforces include migrant workers and people with limited literacy. Good practice includes interpreters or bilingual facilitators, pictures and demonstrations, short messages repeated at the work face, and checking understanding by asking workers to explain or show the control. Written communication must be plain and short. Communication must also run upwards: workers and representatives must be able to raise concerns without fear, which section 26 of the OHS Act protects.

8. External Stakeholders

Construction affects neighbours, road users, schools and businesses. The CHSM contributes to:

• public safety notices, hoardings and traffic accommodation;
• advance notice to neighbours of blasting, crane lifts over boundaries, road closures and noisy work;
• liaison with municipal services, utility owners and emergency services; and
• media and community communication after a serious incident, handled by designated spokespeople.

9. Recording Communication

If it is not recorded, it is hard to prove. Keep induction records (CR 7(7)), toolbox and DSTI attendance with the topic, minutes, safety alerts issued and acknowledged, and correspondence on design hazards and changes. These records show inspectors and auditors that information actually reached the people at risk.