I had a big debate with the client's representatives last week about competence of operatives on site. We take photo copies of permits eg CSCS/CPCS, PAL, PASMA, IPAF and various other permits for going on the railway. However, the question asked was 'how do I know the person using a skill saw has had abrasive wheel training?' There are many courses aimed at various equipment, probably too many to list, including NVQs. The fact is, we as the PC only check core competencies recognised by industry. Needless to say there was a big debate about competence and evidence. I stood my ground and the client has partially conceded. The big question is to what extent is it practical (real world, not theory) to check operatives training and certifcation for all manner of equipment used on site? Bearing in mind much of the training certs are in paper form and therefore operatives cannot be expected to carry around bits of paper. Should the main contractor be as intrusive to ask for evidence of abrasive wheel training, harness, cat & genny and even asbestos awareness? Interested to hear your views. Ray

I’ve noticed more Principal Contractors taking the step of raising training and certification at the order stage. This filters down to the contractor who has to provide proof of training, such as you have mentioned i.e. Stihl Saws, PASMA etc before the operatives arrive on site. This is usually sent with safety method statements and associated risk assessments for task that are to be undertaken. Many undertake random audits to make sure this is being followed however, things still get missed and occasionally ignored by Client, PC and Contractor. A recent example was a site that had dozens of manual handling incidents/accidents on site in a short time frame (1 month). I did a bit of investigating; this was an exceptional site so I was surprised to find that this contractor had not given the workforce suitable training in this area. As their work involved significant manual handling I was quite shocked when the safety advisor stated that they the only ‘training’ was a 10minute toolbox talk, which is hard to justify as competent training. Also noted that the safety advisor had admitted that he had never read the Manual Handling Regulations or associated ACoP and Guidance? I pointed this out to both PC and Client who chose to let them proceed without having to take any action? These were professional ‘household’ names in the industry who regularly pontificate as being the shining beacons to health and safety.

Ray You write: The big question is to what extent is it practical (real world, not theory) to check operatives training and certifcation for all manner of equipment used on site? Bearing in mind much of the training certs are in paper form and therefore operatives cannot be expected to carry around bits of paper. Should the main contractor be as intrusive to ask for evidence of abrasive wheel training, harness, cat & genny and even asbestos awareness? In the real world, many even most people respond to incentives; so, an option is to offer a motivating incentive to those you want to provide what you need. Nothing theoretical about it - just do it or don't and enjoy the consequences of your own actions

Ray For four years, way back in the last century while we were still using biros, the then equivalent of quill pens, I worked in training and development in the construction industry (building and building services sectors). So, I smiled to read your comment: 'Bearing in mind much of the training certs are in paper form and therefore operatives cannot be expected to carry around bits of paper. Should the main contractor be as intrusive to ask for evidence of abrasive wheel training, harness, cat & genny and even asbestos awareness? Have you not yet heard of memory sticks? Incentivise your subcontractors to use them and get a life!

Kieran Are you serious...memory sticks! 'Incentivise your subcontractors to use them and get a life!' Really, I think you need to get a life. Sensible comments still welcome...

Pete Thanks for your comments. I'm not suggesting that my question is a novel idea and I dare say many practitioners have thought much the same at some point. I'm also acutely aware that if there should be a serious accident all and sundry will be asking questions about the competency of the operative. Ironically, CSCS certification is not mandatory on our sites unlike many others, rather, it is seen as good practice. Sometimes guys turn up without a CSCS card and provide a piece of paper, which I don't bother photo copying but it is evidence they have taken the course. Not sure what the answer is? Even if I had a definitive list of skills and training, that would not be much use other than to prevent certain activities if their was no evidence of training - that would make me very popular with the construction team! Take manual handling, for instance, most construction activities require some form of manual handling and MHO training could be in many guises. Anyway, the duty falls on the employer and not the principal contractor, as is the case with asbestos awareness training. The PC has overall site safety, granted, and therefore MHO assessments are often included in method statements, but it does not prove the employee has received MHO training from the employer. Come you construction guys - stop sitting on the fence and tell us how you manage training and competency on your sites....

Ray Having previosuly worked for a client and principal contractor in the house building sector where I would say standards are lower than civil engineering site, we implemented mandatory CSCS/CPCS cards on site or a commitment to getting these i.e. booking operatives onto the touch screen test. I really don't think a PC has much of a choice about checking the competence of contractors it appoints. Indeed the CDM Regs state that the principal contractor must check the competence of all appointees. I agree with Ciaran on this one - we would not allow operators on site without having some sort of proof of competency. Whether a certificate of of training proves competency is another argument all together and could and has formed topics on here before. However if you check the competency of a contractor and have taken necessary steps to check the competency then you are fulfilling your duties as a PC (imho). On a side note though it is always worth checking up with Construction Skills/CSCS about the validity of cards as I had occasion when I checked up on the vailidity of a card and it turned out to be a fake. These can be bought on the black market. Not sure if there have been changes in the card types since i was in that role but worth noting anyway. R

I am a little surprised that this subject is seen as presenting so many problems and that so many people are assuming that possession of a card demonstrates competence. Hence a couple of issues for consideration 1. The PC should have a robust contractor selection process in place in accordance with the requirements of the CDM ACOP. It is not unreasonable for a PC to confirm the competence of persons the contractor is going to use on your site before their appointment. How many PQQ documents actually ask for the names of the operatives who will be used on a site and their corresponding competence? An opportunity missed 2. Possession of a card or a qualification does not demonstrate continuing competence. Cards and qualification do allow the holder to show that in the past they have achieved an acceptable level of performance. On this basis I would say that just asking to see a card falls well short of being able to confirm that someone is competent and is therefore being adequately managed by the PC. There are National Occupational Standards for every activity that is undertaken in every workplace with these being freely available. Now since the NOS sets out competence standards it would be reasonable to use them to confirm someone’s competence in a particular activity. I do not believe that it would be reasonable or practicable to confirm everyone’s competence when they arrive on your site for the first time –a check of their card would probably be reasonable in the short term for most lower risk activities say like wall tiling, bathroom fitting, slab laying etc. However if someone is going to be carrying out a safety critical activity, (an activity which if not adequately controlled would result in a major RIDDOR or a Fatality), I would say that it is perfectly reasonable to expect them to be able to demonstrate their competence against the NOS even if this means that they have to be observed for an hour or so at the start of their first day. The observation results also should be recorded and ideally countersigned by the operative. The arguments against the above approach are `but if I have to carryout an observation and confirm someone’s competence I could be liable and apart from that I am not competent’ If this is the case how are you able to manage that particular process or activity? `we have not got the time for this you can’t do this when you have 100 new people coming onto a job every week etc etc ’. If this is the case and push came to shove and a serious accident occurred, the questions you are likely to get asked are `so tell me how did you plan and manage your contractors and ensure that they were competent? Personally I would prefer to be able to say when this person arrived on my site for the first time I confirmed their competence against industry reconised standards and here is a record to prove it. There are reasonable and practicable solutions that can be introduced into the real world - the problem is they require managing by Managers and not just by health & safety persons.