February 13, 2025
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A Principal Contractor will need to appoint contractors and workers from different trades and at various stages of the construction process. It is their responsibility to ensure that all contractors and workers on the site have the necessary skills, knowledge, training and experience for the work they are carrying out.
Some contractors/workers will be very experienced in the job they do while others will be new to the profession. Additional information, instruction, training and supervision will be needed to support those who are still developing their experience to become self-sufficient in safe and healthy construction practices.
When a Principal Contractor employs or controls people doing work for them, under the CDM15 Regulations, they must make sure that:
they have the necessary skills, knowledge, training and experience to do the job safely and without putting their own or others’ health and safety at risk;
they are supervised and given clear instructions;
they have the right tools, equipment, plant, materials and protective clothing;
they and their representatives are made aware of health and safety issues;
arrangements for employees’ health surveillance are made where required.
Who is classed as an employee?
If a person working under the control and direction of a Principal Contractor is treated as self-employed for tax and national insurance purposes, they are still classed as an employee for health and safety purposes. Whether they are employed or self-employed, action needs to be taken to protect all people under their control.
It is common practice for Principal Contractors to appoint contractors, subcontractors and different trades to work on a construction project. When this is done it is essential that they:
check their health and safety capabilities;
give them the health and safety information they need for the work;
talk about the work with them before they start;
ensure that everything is provided and agreed before they start (for example safe scaffolds, plant and access to welfare facilities);
monitor their performance and remedy any shortcomings.
How is a contractor’s competence determined?
It is important that Principal Contractors make specific enquires about the basic health and safety capabilities of anyone that they are going to employ on a job.
Smaller Projects
On a smaller project, it would be appropriate to ask for evidence from any potential contractor that they are capable of carrying out the work. This could be done by simply asking if they have done this type of work before, requiring references from previous construction work, checking qualifications or training records or by asking them how they plan to carry out the work safely without risk to the health and safety of themselves or others.
Larger Projects
On more complicated or higher risk projects, it is necessary to make more in-depth enquiries. These enquiries can be achieved by using a Construction Pre-Qualification Questionnaire (PQQ), more commonly referred to as PAS 91. It comprises of a set of health and safety questions that can be asked as part of the pre-qualification process for construction projects to assess the construction supply chain.
Accurately accessing the competence of any potential contractor is essential. However, it is preferable to only make enquiries for information that will address the anticipated risks and capability of the supplier. If the pre-qualification questions are excessive or duplicated, it can take the attention away from the practical management of risks.
Once the competency of the contractor has been established, appropriate management and supervision throughout the project must be decided and agreed.
Those managing and supervising the work must have the right mix of skills, knowledge, training and experience. There must be an adequate number of supervisors to reflect the size of the project and workforce. The appointed supervisor working on the site will not only need to be familiar with the type of work planned but will also have to provide the level of supervision required to reflect the level of risk associated with the work. The degree of supervision required will be determined by the level of supervision provided by the contractors themselves. Other additional factors to be aware of is the skill level, knowledge, training and experience of the contractor.
Consultation with all levels of the workforce is crucial to successfully manage health and safety on site. Key information on health and safety risks, including relevant parts of the construction phase plan, need to be shared with contractors. These vital pieces of information should be communicated to workers through induction and worker engagement. The process should be two-way, giving both parties, (or their safety representatives) an opportunity to contribute to decision making.
Engaging Contractors
On a busy construction site, there may be multiple contractors working in close proximity to each other. The Principal Contractor has a responsibility to ensure safe working, co-ordination and co-operation between contractors; this communication is essential to ensure that all contractors and workers on the project are aware of:
What has to be done and what is expected of them
When it will be done
How it will be done safely and without risk to anyone’s
Effective coordination will help reduce any possible risks that could occur by contractors working in close proximity on site. It enables different trades to access shared facilities, e.g. scaffolding, without compromising the safety on site.
This coordination of work can be addressed at site meetings when representatives of all contractors are present, and co-operation should be discussed when a new activity or construction phase begins.
Engaging workers
Health and Safety can be managed in a practical way when collaboration with workers is undertaken; this partnership is important because it:
Helps with the identification of workplace risks
Makes sure health and safety controls are practical
Increases the level of commitment to working in safe and healthy environment.
Workplaces, where the workers are all involved in helping to make decisions about health and safety, tend to have less incidents. Workers must be consulted, in good time, on health and safety matters and it doesn’t matter whether the workplace is unionised or not. In workplaces where a trade union is recognised, this will be carried out through trade union health and safety representatives. In non-unionised workplaces, consultation can either be direct or through other elected representatives. Consultation involves employers not only providing the relevant information to workers but also listening to them and taking into account what they say before making decisions that affect their health and safety.
Issues that workers should be consulted on include:
Risks arising from their work
Risks from others or the environment they are working in
Proposals to manage and/or control these risks
The best ways of providing information and training
Effective communication and consultation at all levels will help to improve the overall health and safety of everyone working in construction.
Edward Pavilion,
Liverpool, Merseyside, L3 4AF