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What Goes in a Health and Safety File in South Africa?
A health and safety file is the organised proof that you manage safety the way the law and your client expect. This guide covers when you need one, what goes in it for construction and for ordinary business premises, and why clients send files back.
Written byJean Duvenage
Reviewed byArthur PaddockOn this page
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
Is a safety file a legal requirement in South Africa?
For construction work, yes. The Construction Regulations, 2014 require the principal contractor and every contractor to open and keep a health and safety file on site. For other work the Act does not name a “file”, but the documents in it are how you show you meet your duties, and most clients make a file a condition of access.
Does every subcontractor need its own file?
On a construction site, yes. Regulation 7(2)(b) applies to each contractor. The principal contractor keeps the overall file and checks that each contractor’s plan and file are in place.
Can I use a template?
A template is a reasonable starting structure. It becomes a problem when it is handed in as it came. The specification, the scope, the risk assessments, the appointments and the registers all have to be about this site and this work.
Can the file be electronic?
The definition is “a file, or other record”, and many clients accept an electronic file. It still has to be available on site on request, so check what the client’s specification says before you leave the paper copy behind.
How long does a file take to put together?
It depends on the scope and on how much you already have: valid medicals, training certificates and a current letter of good standing are usually what holds things up. Tell us the site, the client and the start date and we will tell you what is realistic.
What should be included in a contractor’s safety file?
Think of it in the four groups our Construction Safety File Readiness Check uses. Plan and specification: the client’s or principal contractor’s health and safety specification and your health and safety plan answering it for the actual scope of work, with the section 37(2) agreement and a valid letter of good standing. Appointments and competence: signed construction appointments with proof of competence, hazard-specific induction records for everyone entering the site, and medical certificates of fitness on Annexure 3. Risk and work controls: task and site risk assessments that are current and specific to the work, method statements consistent with them, and a site-specific fall protection plan where there is a fall risk. Evidence and site file: equipment inspection, testing and operator certification records, subcontractor files, site inspection records with tracked actions, the emergency plan, incident procedure and safety data sheets. The client’s index decides the exact order and headings; the readiness check shows where a file is likely to be sent back.
Which document should be placed at the very beginning of a contractor’s safety file?
An index, so that anyone opening the file can find each item quickly. What follows the index depends on the kind of file. For a business or non-construction file, OHSE Resolved’s own index opens with the policy statements, starting with the health, safety and environmental policy signed by the chief executive officer, then the safety plan and meeting minutes, then the legal appointments. A construction file follows a separate construction index. A contractor’s file, though, is normally built to the index the principal contractor or client specifies in its health and safety specification, and that index takes precedence over any standard one.
Which document serves as the proof of compliance for safety activities?
The completed records, not the blank forms. Signed inspection registers, toolbox talk attendance lists, induction and training records, risk assessments signed by the assessor and the team doing the work, permits, and closed-out incident and non-conformance reports are what a client or inspector treats as proof that the controls in the plan are actually being applied. A file full of empty checklists tells the reader that inspections are not happening, and, as our risk assessment guide puts it, a control only counts if it can be checked on the floor. The readiness check puts it as one question: is the file a live record that changes with the project, or a once-off tender pack? Our Contractor Safety Compliance Check tests the same thing from the client’s side.
What must be included in the training and competency section of a safety file?
Proof that every person on site is competent for the work they do and fit to do it. That means hazard-specific site induction records for everyone who enters the site (not a generic company induction), certificates for role-specific training such as first aid, fire fighting, working at heights, scaffolding or forklift operation, operator licences and statutory certification, medical certificates of fitness (Annexure 3 on construction sites), and the competence evidence behind each legal appointment. Each item should be current, legible and tied to a named person on the site attendance list. Competence is always about the particular work: a certificate for a different task or machine does not count.
A contractor’s safety file is rejected by the client. What is the most likely reason?
Most often the file is generic: the health and safety plan is not based on the client’s specification and the actual scope, so the risk assessments describe work that is not being done and the site name or client is wrong. The next most common reasons are items missing from the client’s own index, appointments that are unsigned or not backed by proof of competence, expired documents (letter of good standing, medicals, operator or first aid certificates), and registers that have never been filled in. The section above, “Why safety files get rejected”, covers each of these, and the Construction Safety File Readiness Check flags them before the client does.
Work with OHSE ResolvedNeed a file that gets approved the first time?
We build health and safety files around your site, your scope and your client’s specification. See what is included, or send us the details.
AuthorJean DuvenageSAIOSH Registered Professional, Managing DirectorReviewed byArthur PaddockSenior Safety ConsultantThis 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.
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