A SHE plan and a fall protection plan are not the same document

The first point is terminology.

The Construction Regulations, 2014 use the term health and safety plan. “SHE plan”, “H&S plan” and sometimes “project safety plan” are commonly used industry terms, but the statutory requirement under Construction Regulation 7 is for a health and safety plan.

A health and safety plan is the contractor’s project-level system for managing the health and safety requirements applicable to its construction work. It must be based on the client’s documented health and safety specification and must remain applicable to the work as it develops.

A fall protection plan is narrower and more technically specific. Construction Regulation 10 requires it to deal with work carried out from a fall-risk position.

The documents therefore connect, but they are not interchangeable:

• the health and safety plan controls the contractor’s broader construction-health-and-safety arrangements;
• the Regulation 9 construction risk assessments form part of that plan;
• the fall protection plan deals specifically with fall-risk work;
• relevant fall-risk controls must also be reflected consistently in the risk assessment, work procedures and site implementation.

Construction Regulation 7 requires a principal contractor to provide the client with a suitable, sufficiently documented, coherent and site-specific health and safety plan. A contractor must similarly provide its plan to the principal contractor before performing construction work. Both plans must be reviewed and updated as the work progresses.

As at September 2026, this guide is based on the Construction Regulations, 2014. The Department published proposed replacement Construction Regulations in March 2025 for public comment; those were published as draft regulations, not as the replacement currently governing construction work. OHSE Resolved’s current Construction Safety File Readiness Check accordingly continues to use the 2014 Regulations as its legal basis.

When is a construction health and safety plan required?

Where the Construction Regulations apply and an organisation is acting as a principal contractor or contractor, Regulation 7 creates the relevant health and safety plan duties.

The important point is that the plan cannot be prepared independently of the client documentation.

Construction Regulation 5 requires the client to prepare a baseline risk assessment and a suitable, sufficiently documented and coherent site-specific health and safety specification based on that baseline assessment.

The principal contractor’s plan must answer that specification. A contractor’s plan must in turn address the relevant portions of the specification supplied through the principal contractor.

This creates a deliberate chain:

1. 01Client baseline risk assessment
2. 02Client H&S specification
3. 03Principal contractor H&S plan
4. 04Contractor H&S plan
5. 05Task risk assessments and safe work procedures
6. 06Implementation and records

A generic plan that happens to contain policies, appointment letters and registers does not satisfy this logic merely because the document is large.

When is a fall protection plan required?

Construction Regulation 10 is triggered by work from a fall-risk position.

There is no sensible compliance basis for treating “working at height” as beginning only when an arbitrary number such as two metres is reached. The question is whether the work exposes a person to a fall risk in the circumstances of the construction work.

That can include, depending on the task:

• roof work;
• work from scaffolding;
• work from ladders;
• open edges;
• floor openings;
• elevated platforms;
• structural steel;
• temporary works;
• excavations or openings into which a person may fall;
• access and egress arrangements creating a fall exposure.

Regulation 10 requires the contractor to designate a competent person to be responsible for preparation of the fall protection plan, and then requires the contractor to implement, amend and maintain that plan and ensure continued adherence to it.

A fall protection plan should therefore not be created simply because a tender checklist has a line marked “FPP”. It should begin with the real fall-risk positions on that site.

What must a construction health and safety plan contain?

The Construction Regulations do not provide a closed, numbered statutory table of contents for every health and safety plan.

That distinction matters.

Regulation 7 describes the plan in terms of its suitability, level of documentation, coherence, site specificity and relationship with the client’s specification. Regulation 9 then requires construction risk assessments forming part of the plan to include identified hazards, evaluation by a documented method, a documented control plan and applicable safe work procedures, a monitoring plan and a review plan.

A properly developed plan will ordinarily need to cover at least the following technical areas.

Project and scope definition

Identify:

• client;
• principal contractor;
• contractor;
• project and physical site;
• exact scope of construction work;
• planned duration and phases;
• interfaces with other contractors or operational activities;
• material restrictions or site-specific conditions.

The work described here must agree with the quotation, specification, risk assessment and method statements.

Response to the client’s health and safety specification

The plan should demonstrate how each applicable requirement in the client’s specification will be implemented.

For complex projects, a specification-response matrix is often the clearest way of doing this.

A plan that ignores the specification and simply reproduces the contractor’s standard procedures has missed the legal architecture of Regulation 7.

Management structure and statutory responsibilities

Set out the project management and supervision structure and identify appointments applicable to the project.

Depending on the work, these may include appointments or designations under Regulations 8, 9, 10 and the specialist construction regulations.

The plan should identify not merely a name and appointment number, but also the scope of control and reporting relationship.

Risk management methodology

The plan should explain:

• who performs the construction risk assessments;
• the documented risk-rating methodology;
• how baseline or project hazards are translated into task-level controls;
• when assessments are communicated;
• who may authorise changes;
• what triggers review.

Under Regulation 9, the contractor must have the construction risk assessments performed by a competent person appointed in writing. The assessment must be reviewed when design or construction changes alter the risk profile and when an incident occurs.

Safe work procedures and method controls

The plan should identify the safe work procedures required by the risk assessments.

For technically complex or higher-risk work, the safe work procedure may be supported by a detailed method statement setting out sequence, plant, competence, permits, hold points and task controls.

Regulated construction activities

Applicable specialist requirements must be built into the plan rather than left as disconnected documents.

Examples may include:

• fall protection;
• structures;
• temporary works;
• excavation;
• demolition;
• tunnelling;
• scaffolding;
• suspended platforms;
• material hoists;
• explosive-actuated fastening devices;
• construction vehicles and mobile plant;
• electrical installations and machinery.

Only the regulations applicable to the actual scope should be included.

Competence, induction and training

Identify:

• competence requirements for appointed persons;
• task-specific training;
• site induction;
• toolbox or pre-task communication;
• licences or competency certificates where required;
• refresher arrangements;
• verification before assignment to work.

Occupational health and medical fitness

Construction Regulation 7 includes specific medical-certificate requirements for contractor employees.

The plan should connect the employee, the work they perform, the relevant medical fitness and any occupational-health restrictions rather than keeping medical certificates as unrelated paperwork.

Emergency arrangements

The emergency plan should reflect credible site scenarios.

Depending on the scope these may include:

• fire;
• serious injury;
• fall arrest and suspended-person rescue;
• chemical release;
• excavation collapse;
• electrical incident;
• plant collision;
• severe weather.

Emergency arrangements must align with the risks identified elsewhere in the plan.

Monitoring, inspection, audit and review

A health and safety plan is not complete because it has been approved once.

It should explain how implementation will be checked through:

• inspections;
• registers;
• supervisor verification;
• statutory inspections;
• contractor audits;
• corrective actions;
• risk-assessment review;
• plan revision.

That is also why the plan and safety file should remain controlled, live documents throughout construction.

What must a fall protection plan contain?

Construction Regulation 10(2) is much more prescriptive than Regulation 7.

A compliant fall protection plan must include the following five core elements.

01Risk assessment of all work from a fall-risk position

The plan must include a risk assessment covering all work carried out from a fall-risk position, together with the procedures and methods used to address the risks identified per location.

“Per location” is important. A roof edge, ladder access point, fragile roof, loading platform and scaffold do not necessarily present the same fall scenario.

02Medical-fitness process

The plan must address the processes used to evaluate employees’ medical fitness for work from a fall-risk position and the associated records.

This should connect to the actual employees authorised to perform the work.

03Training programme and records

The plan must contain the programme for training employees who work from fall-risk positions and the corresponding records.

Training evidence without task competence or site-specific communication is not sufficient by itself.

04Inspection, testing and maintenance of fall-protection equipment

The plan must specify how fall-protection equipment will be inspected, tested and maintained.

That requires equipment identification and traceability, not simply a statement that harnesses will be “checked before use”.

05A rescue plan

The fall protection plan must contain a rescue plan detailing the:

• procedure;
• personnel;
• suitable equipment

required to rescue a person following a fall incident, with the arrangement capable of being implemented immediately following the incident.

Calling an ambulance is not, by itself, a suspended-worker rescue plan.

If a person is hanging in a fall-arrest system, the site needs a workable method of reaching, releasing, lowering or otherwise recovering that person without exposing rescuers to an uncontrolled secondary fall.

Regulation 10 also requires fall-arrest equipment to be used only where it is not reasonably practicable to use fall-prevention equipment. Equipment must be suitable, strong enough for its purpose and securely attached to a structure or plant capable of carrying the relevant load.

Who may compile or sign these plans?

This is frequently oversimplified.

Health and safety plan

Regulation 7 places responsibility on the principal contractor and contractor to provide and demonstrate their respective health and safety plans.

It does not create a single statutory job title called “SHE plan compiler”.

The client discusses, negotiates and ultimately approves the principal contractor’s plan. The principal contractor performs the corresponding approval function for its contractors’ plans.

Individual technical components may, however, require legally competent persons.

Most importantly, Regulation 9 requires the construction risk assessment to be performed by a competent person appointed in writing.

Fall protection plan

Regulation 10 expressly requires the contractor to designate a competent person responsible for preparation of the fall protection plan.

That person should hold specific Fall Protection Plan Developer training, together with the relevant knowledge, experience and, where applicable, qualifications for the fall-protection work on the project.

Competence is not created by putting someone’s name on an appointment letter. It must be defensible against the regulatory competence standard and the nature and complexity of the work.

A signed template does not cure a competence deficiency.

Why construction plans are rejected

The most common problem is not formatting. It is failure to demonstrate that the documents belong to the project being assessed.

Typical deficiencies include:

• the plan does not answer the client’s H&S specification;
• another client’s name or previous project details remain in the document;
• risk assessments do not match the scope;
• method statements describe a different sequence from the actual work;
• a fall-risk task exists but no Regulation 10 plan has been developed;
• the fall protection plan has no credible rescue arrangements;
• anchor or attachment arrangements are not defined;
• employees named for fall-risk work cannot be linked to medical fitness and training;
• statutory appointees cannot demonstrate competence;
• revisions to design or work sequence have not triggered risk-assessment and plan review;
• the plan exists in the file but cannot be shown to operate on site.

A technically strong safety file is therefore an evidence system: the plan, assessments, appointments, training, inspections and implementation must agree with each other.

Frequently asked questions

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AuthorJean DuvenageManaging Director Reviewed byArthur PaddockSenior Safety Consultant