DEFINITION of ‘Window Dressing’
A strategy used by mutual fund and portfolio managers near the year or quarter end to improve the appearance of the portfolio/fund performance before presenting it to clients or shareholders. To window dress, the fund manager will sell stocks with large losses and purchase high flying stocks near the end of the quarter. These securities are then reported as part of the fund’s holdings.

What has this got to do with the registration of CHS practitioners, well as the number of successfully registered person’s staggers to gain momentum and provide the construction industry with the numbers required to sustain the industry, the danger of misuse of this status manifests itself? So as the fund managers prop their portfolios to improve the appearance of their fund’s performance will the title, Registered CHS (#) result in the individual propping up their actual ability to perform and add value to a project?

Project Specific Health and Safety controls
The Construction Regulations’ objective is to enforce clients and contractors to develop project specific Health and Safety specifications and plans. Taking the relevant project’s specific exposures into account when the Health and Safety specifications are drafted. Such factors may include:

  • The scope of the work, what is being constructed?
  • Location of the site and elements specific to the location, such as municipal by-laws, weather factors, geographical and community factors;
  • Geo-technical reports containing findings regarding soil conditions, and other issues that may affect health and safety of persons on the project;
  • Baseline risk assessments grounded on the scope of work e.g. is this a high-rise building in a built-up area, or a Greenfields site?; and
  • Controls specific to the client’s requirements e.g. two-day induction periods, colour of overalls, and entrance to existing premises.

The regulation requires the client to appoint a principal contractor with the “necessary resources and skills” and likewise the Principal contractor must appoint contractors under the same conditions. This follows with the requirement that all stakeholders are expected to appoint “competent persons” into positions of responsibility on the project. Taking it a step further the legislator specifies that Construction Health and Safety (CHS) persons must be registered with a statutory body approved by the Chief Inspector.
The intention of the legislator to ensure construction projects are manned by appropriate contractors with suitably experienced, knowledgeable, qualified person “in respect of the work or task to be performed”
Registration of CHS specialists
To explain, Construction Regulation 5(7) requires that a client appointed construction health and safety agent appointed to act on behalf of the client must be registered with a statutory body approved by the Chief inspector. The same obligation is stated in Construction Regulation 8(6) for the construction health and safety officer appointed to assist the contractor.

The body so declared in a “Notice of Approval” published in GNR.85 of 7 February 2014 is the South African Council for the Project and Construction Management Professions (SACPCMP).
Three registration categories are listed namely;
• Construction Health and Safety Agent (Pr. CHSA)
• Construction Health and Safety Manager (CHSM)
• Construction Health and Safety Officer (CHSO)

Sound principles were followed in developing both the criteria and processes for registration. All three categories submitting a registration pack for assessment on successful negotiation of this stage, a written examination for the CHSO and CHSM categories and a professional interview for the Professional category of CHSA.

Competent Ethical Behaviour
At this time there are no formal guidelines for tariff of rates for any of the categories. The CHSO and CHSM categories would invariably be full time employees so market related salary scales would prevail. It is in the Pr. CHSA category with the low success rate of applications which will create a shortage on supply and following the potential for exploitation.
The intention of this registration process is to professionalise the CHS vocation, an opportunity to uplift our skills and image within the construction industry. Should individuals exploit this situation for short term financial gains it will further rupture our already tarnished image.

Registration alone cannot guarantee individual professional behaviour and pointing fingers at professional registration process will not resolve identified failings. What must be addressed is that individuals register and when successful bind themselves to a professional code of conduct. If they choose to flaunt the code and act unethically and unprofessionally then the custodians of these values, the registered professionals have a duty to report these flagrant behaviours.

Doug Michell

CHS Specialist