The International Language of Safety
“Health and Safety’: Is it truly an international language?”
During a recent design team meeting in which SFD was liaising with the Client, Principal Contractor (PC) and end Client, it quickly became apparent that the foreign end Client was unaware of the comparatively ‘higher’ standards of health and safety legislation compliance required when operating in Great Britain (GB) and the specific duties CDM 2015 places on a construction project. The end Client became increasingly concerned of the steps that needed to be taken to enable its non-GB contractors to carry out early access fit-out works during the construction phase of the main works under the control of a PC i.e. it was clear that the end Client had not allowed sufficient project resources to meet these requirements, including:
- applicable CDM 2015 Regulations, such as:
- Regulation 9 Duties of Designers
- Regulation 10 Designs prepared or modified outside Great Britain
- Regulation 15 concerning duties of Contractors;
- checks on the skills, knowledge and experience on non-GB Contractors and how difficulties may be overcome;
- the collation and sharing of pre-construction information between all relevant parties;
- understanding the PC’s health and safety management arrangements set out within the Construction Phase Plan, including the PC’s risk assessment and method statement production and approval procedure;
- provision of information for the Health and Safety File;
- phasing of the proposed works with the main works; and
- arrangements affecting the delivery and storage of the end Client’s materials, plant and equipment.
The PC and SFD, as Client CDM Advisor, began to set out the level of planning that would be required by the end Client in order to meet its intended delivery programme, whilst highlighting the range of options that were available about how this could be best achieved.
Factors that non-GB organisations should consider when planning construction projects in GB include:
- understanding that the same health and safety law applies to overseas workers as to the GB workforce, and, everyone at work, including employers and workers, have responsibilities under it;
- understanding the requirements of all applicable legislation relating to the proposed design/construction work;
- understanding any differences in language when describing technical terms, processes, plant, contractual arrangements, etc. or when complying with emergency arrangements, site rules, health and safety signage, etc.;
- considering the needs of workers who may not speak English well, if at all, and the level of support that may be required, including translation services (particularly with technical terms), nonverbal communication, using a ‘buddy system’ (i.e. putting experienced workers with new or inexperienced migrant workers who speak the same language to help smooth the transition when they commence work), providing English for Speakers of Other Languages (ESOL) courses for workers who need to improve their English, etc.;
- understanding whether vocational accreditations/qualifications of non-GB organisations/workers are compatible with those in GB;
- understanding any project-specific requirements that may be imposed by a Client, Principal Designer, Principal Contractor, etc.; and
- understanding the arrangements and responsibilities for providing information, instruction, training and supervision on site.