SSSP’s – tick box exercise or real risk management?
SSSP’s – tick box exercise or real risk management?
Do Site Specific Safety Plans (SSSP) add any value to managing risk on a construction site or are they merely a tick box exercise?
Working with both Main Contractors and Subcontractors alike, it is sadly my observation that it is a tick box exercise at best and a waste of time at worst. It seems to do zero for actual risk management on a construction site.
Let’s take a step back and create some context.
Site Safe was formed in 1999 and became the central pivot in construction safety management in NZ. The SSSP was one tool of many that was introduced and with wider industry support, became the ‘go to’ for evidenced based risk management.
It provided a systemised and standardised approach. It also provided efficiencies as Main Contractors could now receive the same formatted risk management documentation making pre-qualifications substantially easier.
Since 1999, we have had a myriad of changes including the disappearance of the ACC accreditation progamme (WSMP); the introduction of the HSAW Act; far too many new pre-qualification schemes; Tōtika; new HSNO regulations; an incredibly large number of Health & Safety Apps; a decent number of prosecutions giving us a better understanding of what we are meant to do (or not); to name a few.
In all of this, the SSSP hasn’t changed that much.
So, what is a SSSP and its intended purpose?
Site Safe tells us it “forms a critical part of the agreement between parties and outlines how health and safety will be managed on a job. A SSSP is developed by subcontractors and main contractors to make sure that all relevant site information is available and regularly updated and that health and safety is habitually and consistently monitored.”
Ok, so we have words like agreement, regularly updated, monitored. I read into this that it should be a ‘living’ document. But how can it be a living document when it is not actually designed to be a living document?
In Site Safe’s current formats (all 3 versions), there is not a lot in there that encourages me to review my SSSP. There is no link to reviewing when the job changes (i.e. from doing foundations to erecting steel) nor does it encourage me to review competencies, the risk register or anything.
I digress. The term agreement is very important. A SSSP is indeed an agreement, a contract between the Main Contractor and the Subcontractor. It is also an agreement between the Subcontractor and their Site Manager. If you disagree, I encourage you to go and talk to Worksafe NZ. As such, all parties should sign this agreement. Unfortunately, trying to get a Tier 1 Contractor to sign a Subbie SSSP is nigh impossible.
I am not sure how Sitewise, Impac, Qualify365, Pegasus, SHE, and all the other prequal platforms deal with this as the audit requirements are for SSSP’s to be signed by all parties. Good luck!
Why the reluctance? Ironically, the Tier 1 Contractor still typically allows the Subbie to do the work, so sign-off is implied.
I have been challenged by Tier 1 Contractors that a SSSP is a legal requirement. I have been challenged by Tier 1 Contractors that we must have manual copies of all the templates in the SSSP regardless that we use a Health & Safety App that has all these templates.
When I get presented with these challenges, I tend to be forthright whilst remaining polite (in most instances).
First and foremost, SSSP’s have no legal grounding. They are a tool to allow us to manage risk – nothing more nothing less. Secondly, given there is no legal grounding for them there is no prescribed content to a SSSP.
What are the solutions I hear you ask?
Stop. Think. Why are we doing a SSSP? How can we turn this document into an actual ‘living’ document that allows us to manage risk?
We may want to consider who has what control and influence. We have had Engineering / Project Management firms influence a job by driving changes to a SSSP and work methodologies but claim they have no control and influence. If that is indeed the case, go away. You have no right to demand anything. So let’s introduce a Safety Charter that sets out all parties and their control and influence.
We may want to change the layout of a SSSP and be a lot clearer on the various stages of the job. There is little point doing a SSSP for roofing when the actual framing isn’t up yet as we have zero knowledge of the risks at that time. At the same time, we can remove all the templates, they serve no purpose.
We should remove any templated Task Analysis and Rescue Plans. How can they be site specific if they are a prepopulated template?
Perhaps most of all, we should be doing training on the purpose and use of a SSSP. The impact of the 3 C’s (consult, co-ordinate, co-operate) and that there is no D – Dictate. This training should perhaps start with the Tier 1 companies and Project Management firms.
SSSP’s do have there place and are really useful when used as a working ‘live’ document.
My SSSP Pros and Cons
Pros
Encourages some risk management to be done
Cons (in no particular order)
Often done from office with no link to site risks i.e. powerlines, traffic management, specific site risks depending on where the job is at, etc
Copy & paste exercise
Lists TA’s or SWMS or both that are templated and not tailored to the actual work being done at the time it is being done
Is not a live document – just sits in the office
Rarely signed off by the Main Contractor (or subbie for that matter) and does not get treated like a contract
Treated in the most part as a tick box exercise
Does not align to the HSAW Act and specifically Sec 34 dealing with overlapping duties. How are the 3 C’s of Consult, Co-ordinate and Co-operate applied?
Main Contractors and Project Management / Engineering firms often apply the ‘D’ of Dictate not the 3 C’s.
Doesn’t typically allow for linking Apps that are used for Prestarts, TA’s, Step Back Cards, Toolbox Meetings, Safety Inspections, Equipment Inspectinos, etc