The hazards that actually kill people on South African sites are falls, collapsing excavations and unprotected edges, and the law targets each one directly. The headline rule: any work where someone could fall 2 metres or more needs a written Fall Protection Plan under Construction Regulation 10, before the work starts. Here is what that plan must contain, plus the scaffold, excavation, noise and PPE rules every contractor should know.
Working at height: the Fall Protection Plan
Falls are the single biggest killer on SA construction sites, accounting for roughly 25 to 30 percent of construction fatalities annually according to DEL data. Construction Regulation 10 (CR 10) requires a Fall Protection Plan (FPP), developed by a competent person, before any work where a person could fall 2 metres or more.
The FPP must include:
- A risk assessment of all work-at-height activities.
- Identification of fall hazards: edges, openings, fragile roofs, scaffolds, ladders.
- The hierarchy of controls: fall prevention first (guardrails, barriers, covers), then fall restraint, then fall arrest (harnesses, lanyards, lifelines).
- A rescue plan for a suspended worker. Suspension trauma can be fatal within minutes, so "phone the fire brigade" is not a rescue plan.
- Emergency procedures and training requirements.
Workers must be trained on the FPP before starting, and the plan must be reviewed when conditions change. Edge protection minimums: guardrails at least 900 mm high with a mid-rail and toe board. Fall-arrest kit must comply with the SANS equipment standards (SANS 50361 harnesses, SANS 50355 energy absorbers, SANS 50360 retractable fall arresters) and be formally inspected by a competent person at least every 3 months.
Scaffolding
Scaffolding is governed by Construction Regulation 16 and SANS 10085, with SANS 10085:2024 the latest edition. The core rules:
- Only trained, certified competent workers may erect, alter or dismantle scaffolding.
- Scaffolds must be designed to structural class and checked against wind and access loads.
- Daily visual inspection before use; formal inspection weekly and after adverse weather.
- Working platforms must display maximum load ratings.
- Guardrails, toe boards and fall arrest are non-negotiable, and nobody climbs the cross-braces: ladder or stair access only.
If a storm knocks a fitting loose, the formal inspection happens before anyone goes back up. That is the rule, and it is also the cheapest insurance you will ever have.
Excavations and shoring
Construction Regulation 11 covers excavations:
- A competent person must design and supervise any shoring or support.
- Nobody works in an excavation at risk of collapse unless it is supported, properly battered back, or demonstrably stable.
- Barriers at least 1 metre from the edge must keep people and vehicles out.
- After rain, blasting or any seismic event, a competent person must inspect before workers re-enter.
Trench collapses are sudden and usually fatal. A cubic metre of soil weighs more than a bakkie, and it does not give second chances.
Noise: the rules are changing
Noise on site is regulated too, and the regime is mid-transition. The Noise Exposure Regulations 2024 replace the 2003 noise-induced hearing loss regulations, with the old regulations staying in force until 6 September 2026. The 85 dBA exposure limit stays. What is new is a lower 82 dBA action level that applies only to combined exposure, meaning noise together with ototoxic chemicals and/or vibration, plus impulse noise levels of 135 dBC (action) and 137 dBC (limit). If your crew runs cut-off saws or breakers all day, plan for hearing protection zones and audiometry now rather than after the transition date.
PPE: both directions
Section 8 of the OHS Act puts the duty on employers to provide personal protective equipment, and the principal contractor must ensure all workers on site wear it. Section 14 puts a duty on the worker to actually use what is provided; refusing to is an offence. Minimum site PPE: hard hat, high-visibility vest, safety boots, plus task-specific kit such as eye protection, gloves, respiratory protection and a harness for height work.
The registered health and safety agent
For large projects that need a construction work permit, the client must appoint a construction health and safety agent registered with the SACPCMP. The agent oversees safety on the client's behalf from design stage to completion, reviews the specification, and audits the PC's plan. Proof of the appointment goes in with the permit application.
Worked example: the roofing subbie
A roofing subcontractor re-roofs a two-storey house with a 6 metre ridge. Before starting they must: develop a site-specific FPP, erect scaffolding to SANS 10085:2024, inspect it daily, ensure harnesses near unprotected edges, brief the team on the rescue procedure, and keep an equipment inspection register. None of this is optional, and all of it fits on a few pages for a job this size.
Common mistakes
- No FPP because "it is only a single storey". The trigger is a potential 2 metre fall, not the number of storeys.
- A rescue plan that says "call emergency services". A suspended worker needs to be down in minutes.
- Skipping the post-storm scaffold inspection because the programme is tight.
- Harnesses clipped to nothing, or to a gutter bracket. Anchor points are part of the FPP.
- Buying PPE but not enforcing it. The PC's duty is wear-it-on-site, not have-it-in-the-bakkie.
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