Inspecting Occupational Safety and Health in the Construction Industry

Section 9: Instruments and methodology for inspection visits

9.1 Instruments for inspection visits
9.2 Methodology for the inspection of construction sites

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The main objective of any OSH inspection programme is to contribute to the reduction of occupational accidents and diseases. For this mission, the labour inspectorates make use of instruments to enforce the application of the existing OSH laws and regulations of the country by all those involved in the life cycle of construction projects.

The high number of OSH laws and regulations, general or specific to the construction sector, and the different times at which they were issued can make it more difficult to apply them and inspect their application in a systematic way.

However, more and more countries require the preparation of specific documents dealing with each construction project. By summarizing the legislation applicable to each case, identifying hazards/risks and setting out preventive measures, these documents facilitate both application and inspection.

These documents are usually called the Safety and Health Plan (SHP) and the Safety and Health File (SHF). Both aim to identify, evaluate and prevent hazards/risks, the former (SHP) during the execution phase and the latter (SHF) during the use/operation/maintenance phase.

The enforcement and preventive instruments are presented in subsection 9.1. They should be used by the labour inspectors during their inspection visits to the construction sites.

These inspection visits to the construction sites by the labour inspectorates follows usually a methodology established previously. Sometimes, they are prepared to cover specific issues (e.g. labour control, as per the existence of unrecorded national and/or foreign workers, compliance with medical surveillance), including combined inspections involving other local authorities with the authority given by law to inspect particular issues (e.g. control of the equipment used on construction sites).

In subsection 9.2, a methodology for general inspection of a construction site in a systematic and structured way is proposed, including an evaluation system giving information on the results of the inspection at a global level and at a detailed level. This methodology is based on checklists that should be adapted for each construction site.

9.1 Instruments for inspection visits

This subsection presents and briefly describes the main enforcement and preventive instruments for labour inspectors to use on inspection visits¹².

a) Enforcement instruments

Labour Inspectorates have to ensure the application of the OSH laws and regulations. For this, they may use one or more of the following enforcement instruments (Figure 40):

• verbal warning;
• written warning;
• fine / penalty;
• cessation of work;
• legal prosecution.

Figure 40 – Enforcement instruments

Complementary enforcement measures include publicizing (e.g. through the Web pages of the labour inspectorate) the enforcement instruments used during inspection visits to a construction enterprise or site. This example of complementary enforcement measure may only be used if the country’s law explicitly allows it.

However, there is no common practice on the application of these enforcement instruments. Whereas some countries favour the application of fines, others favour the warnings (verbal and/or written) or education and prevention, rather than just inspection and prosecution.

In 2004, the Senior Labour Inspectors Committee (SLIC, 2005) of the 15 countries of the European Union launched a campaign on 25 000 construction sites. About 50 000 instances of non compliance were detected. About 60% led to written warnings, and about 80% of them were used on construction sites with 20 workers or less (Figure 41). The application of fines and cessation of work were found to be the most effective enforcement instruments.

Figure 41 – Results of the inspection of 25000 construction sites in the EU (SLIC, 2005)

In view of the differences among countries (and sometimes, within the same country in different regions or by different inspectors) in the application of enforcement instruments, it is very important to harmonise the procedures for the application of each enforcement instrument taking into account the cultural and legal differences between countries.

For this purpose, the instances of non-compliance observed during an inspection visit should be classified into three main groups (Figure 42):

• Light;
• Severe;
• Very severe.

Figure 42 – Groups of non compliances

“Light non-compliances” include non fulfilment of the arrangements established by the OSH related laws or regulations and any reference document specifically applicable to the construction project under consideration (the safety and health plan, the safety and health file, the project specifications, etc.), which:

(i) do not cause direct and immediate risks to the safety and health of any person working on the construction site or the public; and

(ii) may be corrected soon (e.g. within one day).

Examples include the absence of a signature on administrative documents, an incomplete record of personal protective equipment, incomplete hazard/risk information to the workers and other administrative failures. In general terms and depending on each case, these non-compliances are associated with verbal and/or written warnings.

“Severe non-compliances” are all other situations of non fulfilment, for example:

• starting any construction operation without a monitoring and prevention plan (see 8.2);
• total or partial absence or inadequacy of any collective or personal protective equipment;
• absence of proof that any worker on site (randomly identified) is covered by a valid and up-to-date insurance against occupational accidents, or has no up-to-date record of medical surveillance;
• absence or inadequacy of any of the plans referred to in the safety and health plan for the construction site under consideration (e.g., emergency plan, collective or personal protective plans, etc.);
• inadequate habitability and hygiene conditions;
• presence on the construction site of any unrecorded contractor or subcontractor;
• absence of, inadequacy of or non compliance with the information training plan;
• non compliance with the time schedule of any person referred to in the flow chart of the construction site;
• absence or inadequacy of the written description of the functions each of them should perform, especially, in relation to OSH issues;
• non-investigation of any occupational accident or the absence of measures taken to stop the same type of accident happening again.

Depending on each case, these severe non-compliances are associated with written warnings and/or on-the-spot fines.

Whenever these severe non-compliances involve direct and immediate risk to the safety and health of any person working on the construction site or of the public, or the absence of the prevention measures may cause (or have already caused) a severe occupational accident, they should be considered as “very severe non-compliances”. These non-compliances are associated with the cessation of work or even the legal prosecution.

Any non-compliance (light, severe or very severe) recorded by the labour inspectors should be supported by the reference document whose stipulations were not fulfilled, otherwise it should be considered as just an opportunity for improvement. The reference documents (other than a law or regulation), or part of them, and evidences gathered of non compliance, should be kept by any means (e.g. photocopy, photography) and attached to the report on the inspection.

Table 12 illustrates a possible strategy for enforcement after observing con-compliance during an inspection. However, it should be adapted to the cultural and legal practices of each country.

Table 12: Possible use of the enforcement instruments in view of the non-compliances

Non-compliances	Light non-compliances					Severe and very severe non-compliances
	VW	WW	F	CW	LP	VW	WW	F	CW	LP
1. Not supported by a reference document	X					X
2. Not corrected within the time period fixed		X						X
3. Not implying direct and immediate risks, corrected during the inspection period and re-verified	X
4. Implying direct and immediate risks, although corrected during the inspection period and re-verified							X
5. Not implying direct and immediate risks, but to be corrected within a short period of time		X
6. Implying direct and immediate risks, but to be corrected within a short period of time								X	XX
7. Implying direct and immediate risks or the absence of the prevention measures may cause (or have already caused) a severe occupational accident on the site									X	XX
8. Incomplete administrative records, with no significant influence on OSH	X
9. Incomplete administrative records, but with significant influence on OSH		X					X	XX
10. Same or similar to a non-compliance recorded in any previous inspection visit to this site, but no accident was previously caused by the absence of the correction			X						X
11. Same or similar to a non-compliance recorded in any previous inspection visit to this site, but an accident has already been caused by the absence of the correction				X					X	XX
VW – Verbal Warning; WW – Written Warning; F – Fine; CW – Cessation of Work; LP – Legal Prosecution; “X” means a possible enforcement instrument to be applied; “XX” means a possible alternative to be applied for more severe non-compliances.

Whenever an inspection uncovers more than a certain number of “light non-compliances” (e.g. 10), of “severe non-compliances” (e.g. 5) or of “very severe non-compliances” (e.g. 1), a new inspection should be scheduled to follow up and to confirm that the non-compliances have been corrected. A full inspection may also be made then, especially if the number of “non-compliances” was more than double the number that calls for a follow up inspection.

Another important issue is whether the labour inspectors should make recommendations during the inspection visits. It is not usual and it is not a duty of the labour inspectors to do so, although some do make recommendations, usually verbally.

However, labour inspectors should make any recommendations in a pro-active way, when they are sure about the way to correct the non-compliance and there is only one way to do so according to a specified reference document. In these cases, and only in these, the recommendations should be given in writing, making them part of process, i.e., part of the enforcement instrument.

b) The Safety and Health Plan

The Safety and Health Plan (SHP) is the main hazard prevention document. It aims to identify and evaluate OSH hazards/risks and preventive measures on the construction site. It should be available before any work starts and it must include the measures to be taken by all those involved in the construction process, to whom it should be available, namely the supervisors, safety and health coordinators, contractors, subcontractors, self-employed persons and workers’ representatives.

Preparation of the SHP should start during the design process. It should be included in the tender process, where applicable, so that all bidders may budget for the measures when preparing their proposals. It is a dynamic document which should be updated, adapted and complemented after contract has been awarded and throughout the construction period.

Records of the measures taken should also be required. Having one SHP for the design phase and another for the construction phase, leads to static documents of dubious efficiency.

A SHP should be required for all construction projects independently of their size and complexity with some exceptions¹³, namely, for medium and large construction projects based on the conditions for a Prior Notice (see subsection 4.1) and/or where particular risks are involved (see subsection 7.1). However, the minimum contents (but not the structure) of the SHP should be included in the laws or regulations and vary according to the size, complexity and environment around each construction project; simplified versions of the SHP should be considered. Table 13 gives an example of the contents of a possible SHP for a medium/large construction project, which must, of course, be adapted to the characteristics of each construction project.

Table 13: Example of a possible structure and contents for the SHP

Promulgation (by the owner’s representative)

1. Introduction

1.1 Scope and application (construction project under consideration and any boundaries)

1.2 Identification of main and general hazards and prevention measures

1.3 Objectives and action plan

1.4 List of legislation and standards applicable to the construction project under consideration

2. Organizational and general procedures

2.1 Distribution of the SHP

2.2 Delivery of the SHP at the start of the works and at the end (reception of the project)

2.3 Changes to the SHP

2.4 Adapting and complementing the SHP

2.5 Technical archive for records

2.6 Control of signatures and rubrics

3. Procedures related to general, social and training policy

3.1 Functional chart and definition of roles

3.2 Prior notice and its updates

3.3 Safety and health policy

3.4 Timetable (Working hours)

3.5 Insurance against accidents at work

3.6 Personal protective plan (identification of workers, PPE)

3.7 Information and training plan

3.8 Health plan

3.9 Visitors’ plan

4. Planning and management procedures

4.1 General characteristics of the construction site

4.2 Construction phases

4.3 Existing local conditionings

4.4 Planning of the works (general analysis and list of relevant works to be performed)

4.5 Planning of labour resources

4.6 Control of construction equipment (updated revisions, noise, dust or fumes emissions, etc.)

4.7 Control of materials and equipment involving specific hazards

4.8 Works involving particular hazards

4.9 Control of subcontractors and successive chain of subcontracting

4.10 Emergency plan, including evacuation

5. Work instructions and hazard prevention

5.1 Construction processes and methods (relevant construction elements)

5.2 Collective protective plan

5.3 Monitoring and prevention plan

5.4 Construction site design and layout (including access and internal circulation and signalisation)

5.5 Temporary signalisation plan (public area, in special in road construction)

5.6 Scaffolding plan for assembly, use and dismantling

5.7 Excavation prevention plan

5.8 … (other specific prevention plans according to the construction project)

6. Follow up and assessment procedures

6.1 Monitoring

6.2 Record of non-conformities and corrective and preventive actions

6.3 Record of accidents and indices, including accident investigation records

6.4 OSH committee for the construction site

6.5 Auditing (internal and external)

6.6 Notifications and reports of the authorities related to the construction site

Annexes

Annex 1 – List and models to be used

Annex 2 – Extracts of the most relevant legislation and standards applicable

Annex 3 - List of relevant works to be performed in the construction site

Annex ? – (to be created during the construction phase as needed)

Figure 43 shows a possible simplification for this SHP for very small construction projects. It is based on a simple form that includes the main information on the construction project and on annexes that should be attached to it (namely, the forms referred to in section 8 of this document).

Figure 43 – Form for a safety and health plan for very small construction projects

c) The Safety and Health File

The Safety and Health File (SHF) is the main hazard prevention document after the conclusion of the works, i.e., during the use/operation/maintenance phase. It should contain all OSH information relevant to any subsequent works especially hazards involved when performing anymaintenance work.

It is a long-term document which should be kept up to date throughout the project. It should be mandatory for all construction projects for which a safety and health plan is also required.

Like the SHP, the SHF is also a dynamic document whose minimum contents should also be included in the laws and/or regulations and vary according to the size and complexity of each construction project, so that simplified versions of the SHF should be considered.

Table 14 illustrates a possible SHF for a medium/large building project. The contents must of course be adapted to the characteristics of each construction project. There will certainly be significant differences for different types of projects (buildings, roads, bridges, etc.).

During the use/operation/maintenance phase, any significant rehabilitation or modification to the existing construction project mean that new safety and health plan should be drawn up, where required, and the safety and health file should be updated accordingly.

Table 14: Example of structure and contents for the SHF for a building

Promulgation (by the owner’s representative)

1. Introduction

1.1 Scope and application (construction project under consideration)

1.2 Identification of main and general hazards and prevention measures

1.3 Details related to the construction process (dates of starting and ending, costs involved, etc.)

1.4 List of legislation and standards applicable to the construction project during the maintenance phase

1.5 Regulation for the use of the project, including insurances needed (as for fire insurance)

2. Organizational and general procedures

2.1 Distribution of the SHF at the end to the responsible of the project during the maintenance phase

2.2 Changes to the SHF and adapting and complementing the SHF

2.3 Organization of the technical archive of all documents related to the SHF

3. Project characteristics

3.1 Technical data (construction areas, number of floors below and over the entrance floor, etc.)

3.2 Brief description of the project (relevant structural aspects, type of external walls, type of cover, etc.)

3.3 Project “As built”

3.4 Details on the connection of internal to external infrastructures (water, sewage, electricity, etc.)

3.5 List of hazardous materials used in the project and prevention measures (asbestos, etc.)

3.6 Relevant quality records (assurance certificates of materials and equipment, results of tests, etc.)

3.7 Relevant OSH records (accidents and indexes during the construction phase)

4. Hazard prevention plans

4.1 Signalization plan (interior and exterior)

4.2 Information and training plan of all those involved in the maintenance phase

4.3 Security plan

4.4 Fire safety plan

4.5 Emergency plan, including evacuation

4.6 Deconstruction and/or Demolition plan (relevant aspects to take into account)

4.7 … (other specific prevention plans according to the construction project)

5. Maintenance procedures

5.1 Interior maintenance (cleaning, painting, etc.)

5.2 External maintenance (cleaning, painting, waterproof, etc.)

5.3 Cover maintenance (substitution of elements, waterproof, etc)

5.4 Maintenance of electrical installations (lights, electrical equipment, etc.)

5.5 Maintenance of mechanical installations (air conditioning, ventilation, heat, water, sewage, etc.)

5.6 Maintenance of elevators and similar equipment

5.7 … (other specific prevention procedures according to the construction project)

6. Monitoring

6.1 Periodic inspections (based on checklists)

6.2 Record of non-conformities and corrective and preventive actions

6.3 Record of accidents including accident investigation, during the maintenance phase

Annexes

Annex 1 – List and models to be used (namely checklists)

Annex 2 – Extracts of the most relevant legislation and standards applicable

Annex ? – (to be created during the construction or pos-construction phase as needed)

9.2 Methodology for the inspection of construction sites

Inspection visits to construction sites by labour inspectors should take a proactive approach and use a systematic process like the one proposed below.

This proactive approach places responsibility for the OSH measures mainly (but not only) on those in the “front line” of responsibility, i.e. those who have the authority and means to decide on the level of safety and health on the construction site (namely, the owner’s and constructor’s representatives rather than the safety experts).

In contrast to the audits, inspection visits by labour inspectors are not announced, but some information about the construction site to be inspected is needed, as a minimum, the Prior Notice (referred to in subsection 4.1) and the Safety and Health Plan (referred to in subsection 9.1), and preferably also the Safety and Health File (also referred to in subsection 9.1).

These documents should list the main characteristics of the construction site, the hazards/risks and the corresponding preventive measures whose effective implementation is to be verified.

In view of this, the OSH law or regulations should make their presentation compulsory whenever the labour inspectorate requires it. While the Prior Notice should be sent to the authorities (e.g. labour inspectorates) for the construction projects with the conditions described in subsection 4.1, the Safety and Health Plan (SHP) and the Safety and Health File (SHF) should only be sent to the authorities when this is explicitly required.

The authorities may require these documents from any of those involved in the construction process, but preferably the owner/client. Requiring a SHP and a SHF means that the labour inspectorate should analyse it and decide whether or not an inspection should be performed. In view of this, requiring these documents for all construction projects is not at all recommended.

The selection of the SHP and SHF to be required may be based on the planning of the OSH inspection programme referred to in subsection 5.1, i.e. these documents should be required for the “high-risk” construction sites to be inspected during a period (e.g. 3 months).

Based on these documents (SHP and SHF), the labour inspectors may prepare the inspection of each of the construction sites following the process set out in a), below. It is based on checklists and on the evaluation method set out in b), below.

a) Inspection process

A coordinator of the inspection should be appointed, who should prepare and conduct all activities before, during and after the inspection process. This process should include the following three main steps in a systematic way (Figure 44):

• preparation of the inspection;
• performing the inspection;
• reporting on the inspection.

Figure 44 – Main steps of the inspection process of a construction site

The preparation of the inspection includes the compilation and analysis of all the relevant information related to the construction site (namely, the Prior Notice, the Safety and Health Plan, the Safety and Health File), the Inspection Plan and the checklists to be used as a reference.

The Inspection Plan (IP) is an internal document of the labour inspectorate that should be flexible to accommodate any changes during the inspection process. It should include the following information (see annexe a) for an example):

• objectives of the inspection, which include the analysis of the implementation of the safety and health measures on the construction site, using a random sample;
• reference documents (e.g. laws and regulations, prior notice, safety and health plan, safety and health file, project design and specifications);
• scope of the inspection, including the parts or activities of the construction site to inspect;
• dates and places of the inspection;
• estimated timetable and duration of the inspection activities, including meetings;
• description of the functions/responsibilities of each member of the inspection team (coordinator, inspectors, assistants, technical experts, observers);
• identification of the main people responsible for the construction site (namely, owner’s representative, constructor’s representative, OSH experts);
• language to be used during the inspection (usually, the country’s official language; the employers may need interpreters if they employ foreign workers);
• topics of the inspection report and estimated date for sending it to the owner’s representative and/or to the constructor’s representative (independently of this report, the labour inspectors may immediately apply any of the enforcement instruments referred to in subsection 9.1, especially the most severe ones);
• logistics issues (special transport for lengthy construction sites, e.g. roads, pipelines, and means needed to gather evidence like cameras, photocopiers, etc.);
• confidentiality (all documents gathered should be confidential, but the labour inspectorate may use them for legal prosecution, if need be);
• follow up action (e.g. follow up inspections, as per subsection 9.1).

Checklists should be prepared before the inspection. They should take into account the type of construction project and what is to be inspected.

The process of performing the inspection, i.e. the on-site activities, should be conducted according to the Inspection Plan. There should be an opening meeting, followed by on-site observations (gathering evidence) and finally a closing meeting. Records of attendance at all formal meetings during the inspection should be kept, especially for the opening and closing meetings.

The opening meeting may be formal or non formal. In very small construction projects, this meeting may involve only the identification of the labour inspector and the person responsible for the construction site (e.g. foreman). On the other cases, however, the opening meeting should be formal and should involve the main persons responsible for the construction site (owner’s and constructor’s representatives, OSH experts, but also the workers’ representatives).

At a formal opening meeting, the coordinator of the inspection should summarise the way the inspection will be conducted, in line with the Inspection Plan, including¹⁴:

• introducing the inspection team and the main functions of each of its members, including the reasons for the inspection and the need to use the office during it;
• requirement the presence of the person in charge of the construction site according to the Inspection Plan; those not usually present on the construction site (e.g. the owner’s representative) should be required at least for an interview and to attend the closing meeting;
• brief presentation of the objectives, scope and reference documents of the inspection;
• information on the Inspection Plan, introducing any changes needed;
• Information about the method and procedures that will be used for the inspection, pointing out that the inspection uses a random sample and so refers only to the activities observed; it should not be inferred that activities not observed comply with the reference documents;
• confirmation of the working language during the inspection; any foreign workers who do not speak the national language should be accompanied by someone working on the site who does;
• requiring the availability of any special resources needed for the inspection (e.g. special transport needed to inspect some parts of the construction site, access to photocopies of the documents and, if not available, the originals may be taken by the labour inspector during a short period not exceeding two working days, leaving a receipt of these documents;
• requiring safety and emergency procedures to be followed by the inspection team;
• information on conditions for ending the inspection (e.g. changes in weather);
• Confidentiality issues (all documents shall be available, except those that are protected by law as professional secret and a proof is presented).
• The on-site observations aim to gather the information that will confirm whether preventive measures are being taken as per the reference documents mentioned above. This information may be gathered in three ways:
• observation of the work being done;
• analysis of the documents recording the action taken;
• interviewing the person in charge of the construction site and the workers’ representatives.

The objective is to get evidence to support the inspection findings. Means include: (i) analysis and photocopying of relevant documents; (ii) observation and photographing or filming of relevant on-site activities and workplaces; (iii) verification of support equipment being used; and (iv) notes taken in interviews with workers involved in the on-site activities.

The closing meeting may be formal or non formal. In very small construction projects, this may involve only the communication of any non-compliance and recommendation (this may be done during the on-site activities), including the notification of any enforcement instrument.

In large construction projects, the closing meeting should be formal and involve the people who attended the opening meeting, at which:

• the main conclusions (and any recommendation) should be presented;
• enforcement instruments should be applied if any non-compliance has been observed (confirming any verbal order made during the inspection); and
• any subsequent action should be stipulated, including the period of time for those responsible for the construction site to take any corrective or preventive action.
• Finally, an inspection report should be drawn up in the following days (preferably, within one week) by, or under the responsibility of, the coordinator of the inspection. This report should include (but not be limited to) the following items:
• introduction;
• objectives and scope of the inspection (confirming those referred to in the Inspection Plan);
• identification of the construction site inspected (name, address, processes inspected, etc.),
• actions performed (actual dates, places visited, meetings, etc.),
• reference documents used in the inspection, highlighting those used most;
• inspection checklists and findings;
• conclusions and any recommendations.

All the information gathered during the inspection should be attached to the report, together with the Inspection Plan, the enforcement instruments issued during the inspection and any other relevant information.

b) Checklists and evaluation method

An inspection is a dynamic process. Consequently, the inspection evaluation should use, but not be limited to, a preliminary checklist in the form of a questionnaire. This preliminary checklist should be prepared by the labour inspectors based on a “template checklist” provided by the labour inspectorates, including the relative weighting of each item as a way to ensure uniformity among inspections. This “template checklist” should be periodically updated to be enriched along the time and used as an internal “standard”. However, the labour inspectors should be able to add items and/or adapt them to the specific features of each case while preparing the inspection and also during it.

An example of a “template checklist” for the inspection of construction sites is given in annexe b). It may be used in two levels (the process hereafter described is similar to that presented on subsection 4.2 - Method for selecting construction sites to be inspected):

• evaluation based on the summary checklist (1st level);
• evaluation based on the detailed checklist (2nd level).

The evaluation method based on the summary checklist (1st level) is simpler to use and analyse, as the number of items is small. It can be, however, more difficult to make a good assessment of each item in view of their broad scope.

To reduce subjectivity on the assessment, each item should be expanded into groups of sub-items. This means that a detailed checklist (2nd level) should be used instead. The results of the evaluations of each 2nd level group of sub-items should then be transferred to the corresponding 1st level item, i.e., to the summary checklist.

In both cases (1st and 2nd level evaluations), each item and sub-item should be weighted (Wi and Wk) between 1 and 5 (with 1 meaning “least important” and 5 “most important” in terms of the potential risks involved), where Wi and Wk represent the weight of the item i from 1 to n (number of items considered) or of the sub-item k from 1 to m (number of sub-items considered). These weightings should be decided by the labour inspectorate following the procedure referred to in subsection 4.4 (where the items and sub-items correspond to the criteria and sub-criteria) and included in the template checklist mentioned above.

For each construction site, the data for each of these items should be analysed and an assessment made in terms of the potential risks involved. Two approaches may be used:

• assessment based on just “conform/comply” and “no conform/no comply”; or
• detailed assessment based on a rating system.

The first approach is simpler and may be used for external presentation. However, the second approach is recommended for internal use, as it gives information on the level of conformance/compliance of each item against the respective reference document, and it may be “transposed” into the first approach.

Where a detailed assessment based on a rating system is to be followed (second approach), the assessment of each item should be rated out (Ai) between 0 (zero) and 5 (five), where Ai represents the assessment of the item i. Intermediate values may also be used by checking two consecutive Ai (e.g. checking the boxes 3 and 4 means an assessment of 3,5. The two approaches are equivalent where Ai is 0 or 5, respectively, for “no conform/no comply” and “conform/comply”.

Items rated less than 3 mean a “non-conformity/non-conformance” or “non-compliance”, with 0 meaning an “absolutely no”, “absolute non-conformity/non-conformance” or “absolute non-compliance”, and 1 and 2 meaning a “partial non-conformity/non-conformance” or “non-compliance” requiring a corrective and/or preventive action to be taken.

Items rated from 3 through 5 mean “conformity/conformance” or “compliance”, with 5 meaning an “absolutely yes”, “full conformity/conformance” or “full compliance”, and 3 or 4 mean a “partial conformity/conformance” or “partial compliance” and an opportunity for the labour inspectors to recommend improvements to those involved on the construction site (as part of a proactive approach). Figure 45 summarises this rating system to facilitate the task of those who have to apply it.

Figure 45 – The proposed rating system

The weighted evaluation of each item (Ei) and the evaluation of the construction site (E) in terms of a percentage (total weighted points obtained divided by the maximum possible points), are given by the following expressions, where “n” is the number of items:

The weighted evaluation of each second level item is obtained by the expression (3) below, and the weighted evaluation of each group of sub-items to be transferred to the corresponding first level item, is obtained by the expression (4), where “m” is the number of sub-items of each group. These expressions are similar to those presented above, but using the letter “k” instead of “i” to mean the items of the second level, i.e. while Wi means the weight of item “i” at the first level (summary checklist), Wk means the weight of item “k” of the second level (detailed checklist).

On the other hand, as the model treats partial “non-conformity/conformance” and partial “non-compliance” (assessments other than 0 or 5) differently, we must explain the difference between these two concepts.

Whereas “non-conformity/conformance” is a failure to meet a requirement of, for example, a management system implemented on a voluntary basis (e.g. ILO-OSH 2001 or any other reference document), “non-compliance” is a failure to meet a requirement of a law or compulsory regulation (compulsory at the local or national level).

A national, regional or international standard is by nature non-compulsory. However, if a law makes a standard compulsory, than a failure to meet this standard is “non compliance”.

Moreover, although non-compliance is often just a matter of “comply/no comply”, there are many situations in the construction industry where intermediate values should be considered.

For example, in many countries the regulations lay down technical characteristics for temporary edge guardrail systems (height, top and intermediate guard-rails, toebords, resistance, etc.) but on some construction sites there are guardrails that do not meet all these requirements (e.g. toebords are missing). One can deem this partial non-compliance with the regulations, scoring it from 1 to 4 depending on the risks (e.g. those caused by the absence of toebords).

In view of this, where the reference document for the item under consideration is a law or a regulation and a partial assessment Ai is checked (other than 0 or 5), then the model considers half of the weighted evaluation (Ei). This works as a penalisation of the system due to non compliance with a law or regulation.

Table 15 shows an example of a “summary checklist” (1st level) for the evaluation of a construction site.

Nr.	Checklist	Ref. DOCs1		Wi (2) (1 - 5)	Assessment - Ai (3)								Weighted Evaluation Ei (4)	INFO Nr.(5)
					External		Internal
			Law		C	NC	0	1	2	3	4	5
1	Site organizational flowchart and human resources									X
2	Safety and health coordination during the design phase (SHC-D)
3	Safety and health coordination during the construction phase (SHC-C)
4	Control of Prior Notice (PN)
5	Control of the Safety and Health Plan (SHP)
6	Control of the Safety and Health File (SHF)
7	Planning and control of operations (bar chart)
8	Site layout and facilities (including the construction workplaces)
9	Control of site workers
10	Control of site subcontractors
11	Control of site machinery and accessories
12	Work related accidents and diseases on the site, including investigations
13	Emergency plan
14	Audits, technical visits and official inspections performed on the site
15	Site environmental control
16	Monitoring and Prevention Plans (MPP)
17	Records of non-conformities (NC) and corrective/preventive actions
18	Control of excavations
19	Control of trench lining systems
20	Control of working scaffolds
21	Control of temporary edge guardrails systems
22	Control of safety nets
23	Control of falsework
24	Free
25
Totals ->														--
					Site Evaluation (E %):

Table 16 shows the detailed checklist (2nd level) for item 20 (control of working scaffolds) of the above checklist. These are also included in . This checklist is based on the European Union standards EN 12810 and EN 12811. The first position on this checklist is used to write the place where the working scaffold under checking is on the construction site, together with the base material used and whether it is prefabricated or not.

The second position is to be used for the classification of the scaffold according to the mentioned EN standards (service load class, drop test, width class, etc.). This is briefly described to in subsection 8.2. The following positions are then used to check evidence gathered during the inspection.

Table 16: Detailed checklist of the evaluation of a working scaffold (second level)

Nr.

Checklist

Ref. DOCs1

Wi (2) (1 - 5)

Assessment - Ai (3)

Weighted Evaluation Ei (4)

INFO Nr.(5)

External

Internal

Law

C

NC

0

1

2

3

4

5

20

Control of working scaffolds

--

--

--

--

--

--

--

--

Place of the scaffold and type (façade, tour, etc.); Base material (steel, aluminium, wood, other); Prefabricated (only for h5,5 m) or non-prefabricated (any h):

North façade; steel; prefabricated (h=18 m)

Classification/Designation: Service load class (1-6); Without or with drop test (N, D); Width class (W06-W24); Headroom class (H1, H2); Without or with cladding (A, B); Vertical access with ladder, stairs or both (LA, ST, LS)

EN 12810; EN 12811

Scaffold EN 12810 – 4D – SW09/250 – H2 – B - LA

a)

If prefabricated scaffold, clearness of the identification of the scaffold system and all its components, including manufacturer, year of manufacture or traceability code

EN 12810

b)

If non-prefabricated scaffold, verification of the responsibility document of the designer of the scaffold and his official qualification for the design, as well as the verification of the inspection documents of the components of the scaffold and/or their marking

EN 12811

c)

Availability of the Product Manual in the country language, including the instructions for erection, use, modification and dismantling

EN 12810; EN 12811

d)

Analysis of the test and assessment report of the scaffold made before use, performed by a different person from the designer, including the verification and record of the anchorages and foundations of the scaffold according to the loads of the design

EN 12810; EN 12811

e)

General assessment of the scaffold on site before the first use, including the side protection which should have a principal (h=1 m) and intermediate guardrail (h/2) and toeboard (=0,15 m)

EN 12810; EN 12811

f)

General assessment of the scaffold every 3 months and after any interruption on the use of the scaffold for more than one month

g)

General assessment of the scaffold after any changing of its previous position on site and after any changing of the conditions of use (e.g. different loads

h)

General assessment of the scaffold after any accident or incident due to malfunction of the scaffold or following adverse atmospheric conditions

i)

j)

k)

In these checklists (first and second level), “Nr.” means a reference number of the checklist and “Ref. DOCs” means the reference documents, which may be an article, requirement, item or clause of a law, regulation, standard, specification, or any other applicable document (mandatory to the case under consideration) against which the evaluation of the item is to be checked for conformity/conformance or compliance. Where a “X” is recorded in the “Law” column, it means that the reference document for the respective item is a law or a compulsory regulation and so the weighted evaluation of this item will consider the penalisation mentioned above.

The column labelled “INFO” may be used to record a reference number (e.g. sequential number) referring to a document that supports the evaluation (e.g., evidences gathered, notes, comments). Where an “X” is recorded in this column, it means that information or a statement of a fact had just been received but no evaluation or confirmation had been made, and so it will not be included in the evaluation.

Each construction site may have a significant number of items to check and so many others are to be added to the “template checklist” mentioned above (as part of the dynamic process), depending on the type of construction project and its characteristics (e.g. complexity).

Moreover, the user of this checklist may have to be an expert on the construction process with a knowledge of the laws, regulations and standards specific to the construction activity.

_________________________________________

¹²A detailed description of the preventive instruments (SHP and SHF) is beyond the scope of this document, as both are highly dependent on the type of construction project and on the specific legislation of each country.

¹³Some countries of the European Union do not require a SHP for small jobs inside a private home.

¹⁴Depending on the size and complexity of each construction project, simplifications should be considered.

 

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