Working at Heights and Scaffolding in Mthatha: What Contractors Must Prove on Site

The contractor must designate a competent person to prepare a fall protection plan, then implement, amend, maintain and enforce it. The plan must include a risk assessment for every work location at a fall risk, medical fitness evaluations with records, a training programme with records, an equipment inspection and maintenance procedure, and a rescue plan.

That list is why one regulation justifies several courses and a medical at the same time. The plan is not a document that sits in a file. It is the reason the employer has to train the right people, medically assess them, inspect the equipment, and prove all of it with records.

The construction manager must hold the most recently updated version of the plan. An out of date plan with no records behind it is the kind of finding that stops work, and it is also the finding most likely to come up when a main contractor audits a subcontractor.

A fall protection plan must contain a risk assessment of every fall risk position with a method per location, medical fitness evaluations with records, a training programme with records, an equipment inspection and maintenance procedure, and a rescue plan. Each element is a separate deliverable the contractor must be able to produce on demand.

The regulations draw a firm line here. Fall arrest is permitted only where fall prevention is not reasonably practicable, so the employer has to show why prevention was ruled out before reaching for a harness. The default answer to a fall risk is to remove the risk, not to catch the person.

All unprotected openings in floors, edges, slabs, hatchways and stairways must be adequately guarded, fenced or barricaded. Where work near an edge cannot be guarded, that is where a fall arrest system and a trained, medically fit user come in.

Work at heights training covers the equipment and the method, but its real value is the discipline behind the choice. Contractors who train teams in fall protection planning as well as working at heights tend to argue about prevention first, which is the way the regulation is written.

Regulation 16 requires the contractor to appoint a competent person in writing to supervise all scaffolding work, and to make sure all scaffold erectors, team leaders and inspectors are competent. Access scaffolding must be inspected and maintained, and it must comply with SANS 10085.

The regulation names three distinct roles: erector, inspector and supervisor. They are not interchangeable. An erector builds the scaffold, an inspector checks and signs it off, and a supervisor controls the work and the persons doing it. A site that treats them as one blanket competency is exposed.

RSTL Centre runs Scaffolding Erector and Scaffolding Inspector as separate one day courses at R700 each, so a contractor can put the right people through the right course rather than sending everyone on the same class. The written appointment of the supervisor is a site decision the employer makes and keeps on file.

The N2 Wild Coast Road is a roughly R20 billion, 110km project in the region, with Package Four led by the WBHO-Edwin Construction Joint Venture and Package Five by the WBHO-H&I Joint Venture. Work of that scale means local subcontractors on site, and subcontractors carry the same fall protection duties as the main contractor.

SANRAL ran a contractor development programme session in Mthatha for local contractors, which is a signal that local firms are being brought onto that work. Any firm that moves from smaller jobs to a project of that size needs its fall protection plan and its training records in order before it starts, not after an audit.

The district water and sanitation programme adds the same pressure closer to town. With about 122 projects running and civil tender documents requiring a quarterly training needs analysis, contractors have to show a training plan that is refreshed through the contract, and heights and scaffolding training sit in that plan.