Building your own safety file seems straightforward. You download a few templates, add your company name, print it out, and put it in a folder. The problem is that this approach fails Department of Labour inspections more often than contractors expect — and the consequences of a failed inspection are serious.
This article explains the most common failures in self-assembled safety files and what a compliant plan actually requires.
What the regulations actually require
The Construction Regulations 2014, issued under the OHS Act 85 of 1993, require that a health and safety plan be prepared before construction work commences. Regulation 5 specifies that the plan must be:
- Specific to the site and scope of work
- Approved by the client
- Kept on site at all times
- Updated as conditions change
The word "specific" does the most work in that list. A generic template is not site-specific. An inspector from the Department of Labour can identify a generic document in seconds — it will reference hazards irrelevant to the actual site, omit hazards that are present, and contain placeholder text that was never filled in.
The most common DIY failures
1. Missing documents
A complete construction safety file contains 314 documents across eight categories: policies, procedures, risk assessments, inspection registers, safety plans, legal appointments, construction documents, and toolbox talk records.
Most contractors who build their own files assemble far fewer. The legal appointments section alone requires 63 signed appointment letters. Missing even one — a Health and Safety Representative Appointment, a First Aider Appointment, an Incident Investigator Appointment — creates a non-compliance finding.
2. Unsigned or incorrectly signed documents
Policies must be signed by a responsible person at the appropriate level of authority. Appointment letters must be signed by both the appointing person and the appointee. Risk assessments must be signed by a competent risk assessor.
Self-assembled files frequently contain unsigned documents, or documents signed by the wrong person. An unsigned health and safety policy is not a valid health and safety policy.
3. Generic risk assessments
Risk assessments are perhaps the most frequently cited deficiency in site inspections. A risk assessment must identify the specific hazards present at this site for this scope of work. A generic document that lists every possible hazard in a table is not a site-specific risk assessment.
Under the Construction Regulations, the risk assessor must be a competent person — someone with relevant training, qualification, or experience. A risk assessment signed by an unqualified person is invalid regardless of its content.
4. Out-of-date inspection registers
Inspection registers must be completed at the required intervals. A scaffolding inspection register that was filled in once and never updated demonstrates that inspections are not being conducted. An inspector will notice this immediately.
5. Wrong documents for the scope of work
A safety file for an excavation project requires an Excavation Safety Plan. A project where workers could fall 2 metres or more requires a Fall Protection Plan. A file assembled from a generic template may include neither — or may include both even for a project where neither applies.
Why "close enough" is not compliant
The Department of Labour enforces the OHS Act and Construction Regulations strictly. An inspector who identifies a non-compliant safety file can:
- Issue a prohibition notice stopping all work on site
- Issue a contravention notice requiring immediate remedy
- Refer the matter for prosecution
The penalty for non-compliance under the OHS Act can reach R100,000 or one year's imprisonment per contravention. More practically, a stopped site costs money every day it is not productive.
A safety file that cost R50 in printing but fails inspection is not a saving — it is a liability.
What a compliant file requires
A compliant safety file requires:
- All required documents — all 314 of them — to be present
- Every document to be site-specific — populated with the site address, scope of work, contractor details, and project dates
- All signatures to be in place from the correct persons
- The file to be kept on site and updated as conditions change
Producing this from scratch, without a structured system, typically takes a professional safety consultant two to three days. At consulting rates, that costs between R2,000 and R5,000 per file.
A practical alternative
MySafetyFile generates all 314 required documents automatically. You enter your project details — site address, contractor name, scope of work, and project dates — and the system populates every document with that information.
The process takes 8 minutes. The file costs R500. Each document carries a unique identification code for verification purposes.
A compliant file is not something you should have to build manually. Register free and generate your first file today.