However, is this actually mandated by law? Consider, for example, a different requirement that places an obligation on staff: we require staff to ensure that their general appearance and dress is appropriate to that expected in a professional office. We do not allow staff to go shopping for a suit in company time, even if they never wear it other than at the office. If we require staff (in some categories) to hold a CSCS card (or any other particular qualification), is it legally required that they have time to study / revise for that in company time? As another comparison, we expect (but do not explicitly require in writing in terms-and-conditions) that professional staff will maintain membership of professional institutions. Most professional institutions now mandate CPD, but we do not necessarily provide places on paid-for training courses for the full CPD requirement of an institution - we expect people to manage their own CPD, and expect that a proportion of that will not be in paid-for company time. (In reality, most is, since most CPD is generated by identifying the personal development benefit from activities that are undertaken in company time for company benefit anyway.) No-one has ever protested this, btw, I'm just musing about what if they did!

Sorry, I need to clarify: We have done risk assessment processes that identify training needed to ensure safety of employees. That training is provided in company time, no question, no problem. I feel comfortable that we satisfy the HSAWA requirements to provide sufficient training to ensure the safety of our employees. (Insert reasonably, practicable, etc throughout) That risk assessment, however, does not include identifying a need for CSCS cards for the safety of the individuals. I do not consider that holding the CSCS card adds to the safety of our individuals - generally because in the areas that matter to them, the CSCS requirements are a base level well below their knowledge / experience. However, it is expedient in that it seems adequate to reassure site managers that the people have some safety awareness. I was wondering if there is a blanket requirement that any training or qualification required by an employer be done in company time. It may be that I really need to find and ask an employment law forum, rather than a H&S one, since here it is probably too intrinsically tangled with the required-for-safety-of-employee type training.

We do have our own assessment of competence - I don't believe the CSCS test to be a useful measure of someone's safety on site. However, it's a case of 'standards' being a pressure to the lowest common denominator: our company ID card (with eight categories of basic safety competencies set out on the back, the very first of which is comparable to the CSCS safety test) means nothing to other organisations on site - they want to see a CSCS card (if anything). In fact, it means so little we've phased it out - the competence records are in the office and on site our people merely brandish CSCS. The possession of a CSCS card means very little to our internal systems, it's for marketing (so we can say that 95% (or whatever) of our eligible personnel have a CSCS card) and so that when we're planning visits to site we can tell the contractor that the people coming to site will have CSCS, which they seem to prefer to us saying they'll have had the safety training we have assessed necessary (even though the latter is generally a much higher standard than the former). The CSCS card test still needs revision though - to catch questions like knowing which gas is in the red cylinders and which in the blue, and which is the higher pressure. Our systems don't cover that specific question, because our people never do anything with gas cylinders - our policy is generally that all gas cylinders contain probably flammable gas at high pressure, and leave them alone. There are probably a dozen or so questions that can catch people out along those lines. (Though the most recent test is better than the old in that respect.)