Hi Dannyold
One of the lesser well known parts of the Health and Safety at Work etc Act 1974 [Section 33(1)(l) or (m)] says, amongst other things:
33 Offences
(1) It is an offence for a person—
(l) intentionally to make a false entry in any register, book, notice or other document required by or under any of the relevant statutory provisions to be kept, served or given or, with intent to deceive, to make use of any such entry which he knows to be false ;
(m) with intent to deceive, to forge or use a document issued or authorised tobe issued under any of the relevant statutory provisions or required for anypurpose thereunder or to make or have in his possession a document so closely resembling any such document as to be calculated to deceive;
The "relevant statutory provisions" includes all Codes of Regulations made under HSWA inclusive of the Management of Health and Safety at Work Regulations that require the recording of risk assessments by employers of 5 or more people.
But on the basis of what you have written you have not deliberately included inaccurate information in your RAMS.
But going forward you might do so if you continue to include such misinformation.
To be honest this is a scenario where the person allocated responsibility for keeping accreditations up to date is much more likely to be in the focus of an investigator than you.
So, time to raise the issue and let the organisation sort it out.
May be the people doing the work don't actually need DBS checks, whilst CSCS is not a legislative requirement but either might be a contractual requirement for doing business.
It might be that client contracts demand DBS and/or CSCS [or equivalent].
Might be that some client contracts demand DBS but not CSCS and vice versa.
So, it might be that your organisation has unnecessarily overegged the pudding by opting for both for all its staff, though that might have been a pragmatic decision to enable maximise flexibility of how people are sent out to do work.
But this is one for management to resolve - your responsbility is to highlight the discrepancy.
Good luck, Peter