Subcontractor Health and Safety in the South African Construction Industry
Monday, 06 July 2026
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Posted by: Ernest Roper
 The South African Construction Industry for both construction and civil projects, rely on subcontractors for specialised services and labour. This is especially true for projects such as the construction of roads, pipelines, wind farms, commercial buildings, bridges and other forms of infrastructure. Subcontractors perform a variety of tasks, including scaffolding, excavation, electrical services, lifting, steel and concrete works, blasting and operating heavy equipment.
Although subcontractors are an integral part of the delivery of projects, the poor management of subcontractors has the greatest effect on workplace injuries and fatalities, delays of projects and legal non-compliance. The South African construction industry remains one of the highest-risk sectors due to the nature of the work environment and the variety of hazards present on construction sites. Construction workers are exposed to multiple hazards including falling from heights, moving machines, collapses during excavation, electrical exposure, falling debris, the interaction of vehicles and pedestrians, exposure to dangerous chemicals and the elements.
For these reasons, every phase of every project must involve the proper management of health and safety. Responsibilities of health and safety in construction are primarily governed by the Occupational Health and Safety Act 85 of 1993 and the Construction Regulations of 2014. These legislations create duties for clients, principal contractors, contractors and subcontractors to ensure construction work is performed safely and without endangering the health of workers and the public. On construction sites, principal contractors are tasked with managing all other construction activities and ensuring subcontractors meet the legal and health and safety obligations of the project.
The regulations impose responsibilities on clients, principal contractors, contractors and subcontractors with regard to the safety of construction activities and the health of employees and members of the public.
Principal contractors have the overall control and coordination responsibility of construction activities on site, and the same applies to subcontractors with respect to compliance with legislative and project health and safety requirements. Within this framework, the principal contractor coordinates and controls subcontractors’ safety practices, authorises subcontractors based on their safety competency, reviews safety practices, ensures safety assessments are performed and controls safety practices of subcontractors during construction. Furthermore, the principal contractor safeguards effective communication and cooperation of all subcontractors and ensures they do not perform activities that compromise safe working on the site.
Subcontractors, however, are employers in their own right and therefore carry direct legal responsibility for their employees and work operations. Before commencing work, subcontractors are required to prepare site-specific health and safety plans aligned with the principal contractor’s safety specifications. They must conduct baseline and task-specific risk assessments, identify hazards associated with their activities and implement effective control measures to reduce risks to an acceptable level.
Subcontractors need to equip their workforce with adequate PPE, provide medical fitness certificates when required, establish safe work procedures and offer necessary task-related training. Toolbox talks, inductions and regular supervision are essential to ensure workers understand site hazards and safe working methods.
Insufficient supervision and a weak safety culture among subcontractors are two key challenges that the Principal Contractor faces. It is common for workers to circumvent safety procedures due to time pressures and in some cases, a lack of understanding. During site inspections, the following challenges are frequently noted: scaffolding inspections are not done or done poorly, excavations are performed unsafely, housekeeping is done poorly, there is a lack of fall protection, there is incorrect use of personal protective equipment and there is unsafe interaction between workers and mobile plant.
The absence of health and safety files or having files that are not up to date is another challenge. Construction Regulations require subcontractors to have health and safety files that include legal appointments, training records, risk assessments, medical certificates, inspection registers, incident reports and emergency procedures. Poor record keeping can result in work stoppages, fines and action by the Department of Employment and Labour.
Successful management of subcontractors encompasses ongoing observation and directing from principal contractors and clients alike. They should undertake regular site presence, audits, and meetings as well as undertake site-specific toolbox talks. These assist in identifying potential risks, implementing corrective measures and responding appropriately. Principal contractors should only appoint subcontractors who are competent and have the appropriate resources to perform the work.
A positive health and safety culture creates benefits for every person engaged in the project. The effective management of safety among subcontractors enhances safety, increases productivity, decreases delays, enhances the contractor’s reputation and most importantly, safeguards the health and safety of workers, the general public and all contractors involved.
In summary, the health and safety of subcontractors form the backbone of successful construction and civil engineering projects in South Africa. Following the Occupational Health and Safety Act and the Construction Regulations is more than a legal obligation, it is a step towards protecting the workforce and the environment. With effective planning, management of risks and the right degree of supervision and coordination, contractors and subcontractors can improve their safety goals and enhance the construction industry’s safety and sustainability.
Neil Enslin | Head: Occupational Health and Safety
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