What a health and safety file is

The Construction Regulations, 2014 define a health and safety file as “a file, or other record containing the information in writing required by these Regulations”. In plain terms it is one place, on site, where anyone entitled to ask can see how the work is being kept safe: who is appointed, what the risks are, how they are controlled, who is trained and fit, and what has been inspected.

Outside construction the Occupational Health and Safety Act, 1993 does not use the words “safety file”. Clients, landlords and principal contractors still ask for one, because it is the quickest way to check that a company they are letting onto their premises meets its duties under the Act. So the same name covers two things: a legally required construction file, and a contractor or company file that a client asks for before work starts.

When you need one

• You are the principal contractor on construction work. Regulation 7(1)(b) requires you to open and keep a health and safety file on site, with all the documentation the Act and the Regulations require, and to make it available on request to an inspector, the client, the client’s agent or a contractor.
• You are a contractor or subcontractor on a construction site. Regulation 7(2)(b) puts the same duty on every contractor. Each contractor keeps its own file for its own scope of work.
• You are doing work at a client’s premises. Maintenance, installation, cleaning, security and similar contractors are usually asked for a file, together with a section 37(2) agreement, before they are allowed on site.
• You are tendering or registering as a vendor. Many tenders and supplier portals ask for a file or an extract from one.

What goes in a construction safety file

The starting point is the client’s site-specific health and safety specification. The client must prepare it, along with a baseline risk assessment, under regulation 5(1). Your file is your answer to that specification, so its exact index comes from the client. These are the items almost every construction file contains.

• The client’s specification and your health and safety plan. The plan explains how you will meet the specification on this site, for this scope of work.
• Notification or permit. Proof that the work was notified to the provincial director on Annexure 2 (regulation 4), or the construction work permit applied for on Annexure 1 where the project is large enough to need one (regulation 3).
• Letter of good standing from the Compensation Fund or a licensed insurer, valid for the period of the work.
• Section 37(2) agreement between you and the client or principal contractor.
• Written appointments with proof of competence: the section 16(2) appointee, the construction manager and supervisors (regulation 8), the risk assessor (regulation 9), and task-specific appointments such as first aiders, scaffold, ladder and fall protection roles where they apply.
• Risk assessments for the actual tasks, done by a competent person before work starts, with the safe work procedures or method statements that follow from them.
• A fall protection plan wherever there is a risk of falling (regulation 10).
• Medical certificates of fitness on Annexure 3 for employees on site (regulation 7(1)(g)).
• Induction, training and competency records for everyone on site, including operators and visitors’ induction.
• Registers and inspection checklists for the equipment you actually use: ladders, tools, PPE issue, scaffolds, lifting equipment, first aid box and fire equipment.
• Incident procedures and records, including how incidents are reported and investigated.
• An emergency plan with site contacts and the nearest medical facility.
• Safety data sheets for hazardous chemicals brought to site.
• Subcontractor appointments and files, if you appoint anyone under you.

What goes in a file for a business or contractor

For work that is not construction, there is no single regulation that lists the contents. A sound file shows how you meet the general duties in the Act, scaled to your size and risks.

• Health and safety policy, signed by the chief executive officer.
• Legal appointments: the section 16(2) appointee where duties are assigned, and health and safety representatives where you have more than 20 employees (section 17), with committee minutes where a committee is required (section 19).
• First aid arrangements: a first aid box where more than five people work, and a trained first aider where there are more than 10 (General Safety Regulation 3).
• Risk assessments for your activities, and the procedures that come out of them.
• Training records, inductions and any licences or competency certificates.
• Registers for the equipment and PPE you use.
• Incident reporting procedure and records (section 24 and the General Administrative Regulations).
• Emergency plan and evacuation arrangements.
• Letter of good standing and, for work on someone else’s premises, the section 37(2) agreement.

Not sure your appointments would hold up? The free Legal Appointments Check and Contractor Safety Compliance Check cover the two areas clients query most.

Why safety files get rejected

• It is a generic template. The site name, scope and client are wrong or missing, and the risk assessments describe work you are not doing.
• It does not answer the client’s specification. The client checks the file against its own index. Anything it asked for that is missing comes back as a finding.
• Appointments are unsigned, or there is no proof of competence behind them.
• Documents have expired: the letter of good standing, medicals, first aid or operator certificates.
• Registers are blank. A file full of empty checklists tells the client that inspections are not happening.
• The file and the site do not match. The plan says one thing and the work on the ground shows another.

After the file is approved

Approval is the start. The file stays on site and is kept current as people, plant and tasks change. On construction work the client must make sure the principal contractor’s file is kept and maintained (regulation 5(1)(s)), and clients audit against it during the project. When the work is finished, the principal contractor hands the client a consolidated health and safety file (regulation 7(1)(e)).

A good file is one your supervisor actually uses: the risk assessment is the one discussed at the toolbox talk, and the registers are filled in on the day of the inspection.

Common questions

This guide is general information about South African occupational health and safety requirements as at September 2026. It is not legal advice, and it does not replace the client’s specification or the text of the Act and Regulations. Requirements depend on your site, scope and risks.