2.4 The CHS Manager vs CHS Officer vs CHS Agent & Professional Registration
Key Takeaways
Section 18(2) of the Project and Construction Management Professions Act bars practising in a registration category without being registered in it; contravention is an offence under Section 41(1).
GN 1181 of 2019 describes a CHSM as a competent person appointed by an employer to manage the planning and implementation of construction health and safety systems, with services in project stages 4 to 6.
CR 8(5) requires a contractor, after consulting the client, to appoint a full- or part-time construction health and safety officer, with no fixed headcount trigger; CR 8(6) requires SACPCMP registration.
Under the SACPCMP Rules for Registration effective 1 August 2025, CHSM applicants need an NQF 6 (240-credit) qualification or RPL plus at least five years' relevant experience.
SACPCMP examinations are online and proctored with a 60% pass mark; 35–59% allows a rewrite within six months, while 0–34% archives the application.
2.4 The CHS Manager vs CHS Officer vs CHS Agent & Professional Registration
Legislative Framework for Professional Registration
Construction health and safety practitioners are registered under the Project and Construction Management Professions Act, 2000 (Act 48 of 2000) by the South African Council for the Project and Construction Management Professions (SACPCMP). Section 18 of that Act lets the Council prescribe "specified categories" in addition to the professional and candidate categories. Section 18(2) provides that a person may not practise in a category unless registered in it, and contravention is an offence under Section 41(1). Section 26 provides for the identification of work reserved for each category.
The Construction Regulations then make registration a legal precondition for the two roles they name:
- Client's agent: must be registered with a statutory body approved by the Chief Inspector (CR 5(7)(b)).
- Construction health and safety officer: a contractor may not appoint one unless reasonably satisfied that the person is registered with such a body and has the necessary competencies and resources (CR 8(6)).
The Three SACPCMP Construction Health and Safety Categories
The Rules for Registration list the specified categories Professional Construction Health and Safety Agent (PrCHSA), Construction Health and Safety Manager (CHSM) and Construction Health and Safety Officer (CHSO), each with a matching candidate category (Can CHSA, Can CHSM, Can CHSO). Their "level descriptors" come from the scope of work gazetted by the Council for the Built Environment (Government Notice 1181 of 20 September 2019):
| Category | Level descriptor (GN 1181 of 2019) | Typical position |
|---|---|---|
| PrCHSA | A competent person who acts as a representative for a client in managing health and safety on a construction project | Client's agent under CR 5(5)–(7), from project initiation to close-out |
| CHSM | A competent person appointed by an employer to manage the planning and implementation of construction health and safety systems | Contractor's (or, on suitable projects, client's) health and safety manager |
| CHSO | A person appointed by an employer to assist site management with planning, implementing and managing construction health and safety systems | Site officer appointed under CR 8(5) |
The SAQA record for the CHSM designation adds that a CHSM must show detailed knowledge of construction health and safety requirements at managerial and operational levels, the ability to design, compile and implement or manage the health and safety requirements for a project, and the ability to mentor, coach and guide CHSOs.
The CHSM's Gazetted Scope of Services
GN 1181 lists CHSM services from project stage 4 onwards (the CHSM has no stage 1–3 services; those belong to the client's agent):
- Stage 4 – Tender documentation and procurement: attend tender clarification meetings; review the documentation programme; finalise the baseline risk assessment; identify precautions and develop health and safety plans from the specification; agree the format of the health and safety file; help with health and safety cost estimates and budgets; manage the health and safety documents issued to tendering contractors; facilitate evaluation of contractors' competencies and resources; and facilitate health and safety contract documentation.
- Stage 5 – Construction: attend site handover; facilitate the site-specific plan; ensure documents reach the authorities; manage assessment and approval of other contractors' plans; run health and safety meetings; ensure hazards are identified through coordinated inspections; manage communication structures; evaluate emergency response plans; monitor and report performance through compliance audits; evaluate contractor compliance; manage incident reporting and investigation; manage non-compliance and corrective and preventive action; review the management system; use trend analysis; manage changes to plans; and present technical reports to decision-makers.
- Stage 6 – Close-out: review and approve contractors' consolidated files; manage site safety during the defects liability period; and prepare the consolidated project health and safety file for the client.
The 2017 guideline note to CR 5 also allows a client to appoint a CHSA or a CHSM, depending on the scope and risk profile of the work, to represent it on health and safety matters.
The Construction Health and Safety Officer Appointment (CR 8(5)–(6))
A contractor must, after consulting the client and having considered the size of the project, the degree of danger and the accumulation of hazards or risks, appoint a full-time or part-time construction health and safety officer in writing. Where it is unclear whether an officer is needed, the inspector's decision is decisive. The regulation sets no headcount threshold: a small but high-risk job may justify a full-time officer, while a larger low-risk one may not. Many client specifications add their own ratios.
Becoming Registered as a CHSM
Under the SACPCMP Rules for Registration (version 3, effective 1 August 2025):
- Qualification and experience: an NQF level 6 qualification of 240 credits on the Council's recognition list (or an RPL certificate), plus at least five years of relevant practical experience. Candidate CHSMs (Can CHSM) need the qualification but no experience, and log their experience in a mentored logbook.
- Application: apply on the online construction health and safety portal (myCHS), watch the mandatory application video, and submit certified documents, a CV and an eligibility assessment report: a 3 000-word report on successes and challenges across ten knowledge areas (planning, implementation and management; procurement; cost; hazard identification; risk; accident or incident investigation; legislation and regulations; health, hygiene and environment; communication; emergency preparedness).
- Eligibility assessment: two assessors must both recommend progression; if they disagree, a third assessor decides.
- Competency assessment: a professional interview or examination. Examinations are online and virtually proctored; points and time are set in advance for each paper, and the Council does not publish a standard question count. The pass mark is 60%. A candidate scoring 35–59% may rewrite within six months after paying the re-examination fee; 0–34% means the application is archived and a fresh application is needed.
Code of Conduct, CPD and Discipline
Registered persons must comply with the Council's Code of Conduct: putting the health and safety of workers and the public first, working only within their competence, avoiding conflicts of interest, and refusing to sign off unsafe plans or falsified records under commercial pressure. To keep registration they must comply with the SACPCMP CPD Policy and pay the annual fee; failure leads to deregistration. The SAQA record for the designation summarises the CPD framework (Board Notice 75 of 2012) as a five-year cycle of 52 points: Category A (core and non-core knowledge) 60%, Category B (mentorship and development) 20% and Category C (ongoing practice) 20%. Check the current policy before relying on point values. Complaints of improper conduct are investigated under the Act and may lead to a disciplinary hearing, with sanctions up to removal from the register.
SACPCMP Categories Comparison Matrix
| Attribute | PrCHSA | CHSM | CHSO |
|---|---|---|---|
| Statutory hook | CR 5(5)–(7) client's agent | Employer's H&S manager; may represent client per 2017 guideline note | CR 8(5)–(6) contractor's officer |
| Project stages (GN 1181) | Stages 1 to 6 | Stages 4 to 6 | Construction stage |
| Key functions | Specification, design-risk review, plan approval, client audits, stop-work | Plans, contractor evaluation, audits, incident management, trend analysis, close-out file | Site inspections, registers, induction, minor investigations, support to supervisors |
| Typical employer | Client or consultancy | Principal contractor, contractor or client | Contractor |
A Grade 8 Principal Contractor is executing a R300 million hospital contract involving three multi-story blocks, tower cranes, deep basement excavations, and 350 workers. The contractor's executive team must establish safety leadership appointments. What is the legally correct relationship between the Construction Health and Safety Manager (CHSM) and the Construction Health and Safety Officer (CHSO)?
The contractor may assign all CHSM and CHSO responsibilities to the client's Pr.CHSA agent to eliminate overhead costs.
The contractor only needs to appoint one part-time CHSO who visits the site on Friday afternoons to sign the safety registers.
The corporate CHSM manages the systems and major risks, while full-time CHSOs appointed under CR 8(5) support daily site work.
A registered CHSO may oversee all corporate multi-project risk policies while an unregistered safety intern acts as the sole site safety officer.
A registered Construction Health and Safety Manager (CHSM) employed by a major civils firm is pressured by the Contracts Director to sign an internal approval for a deep trench excavation method statement that deliberately omits required soil shoring to meet a tight deadline. How must the CHSM act under the SACPCMP Code of Conduct?
The CHSM should sign the document with a confidential note to the file stating they were under duress.
Leak the company's bidding files to the press without escalating internally.
Refuse to sign the unsafe method statement and insist on adequate shoring to the required standard.
The CHSM must sign the method statement because the Contracts Director holds a superior Section 16(2) appointment and bears all legal liability.
A municipality acting as a Client embarks on a R120 million highway expansion project. To save consulting fees, the municipal project manager appoints an unregistered freelance safety consultant to act as the 'Client Health and Safety Agent' under CR 5(5). When the permit application is submitted to the Department of Employment and Labour, how will the Provincial Director respond?
The Department will issue the permit immediately because municipal infrastructure projects are exempt from the agent requirement.
Refused: CR 3(5) requires proof of a CR 5(5) agent registered with the SACPCMP (CR 5(7)(b)).
Approved if the municipal project manager co-signs.
The Department will grant a provisional permit while the consultant writes the SACPCMP examinations.
Sections you finish are checked off in the contents.