On Irish construction projects, Working at Heights compliance is shared. The main contractor cannot point at the sub-contractor; the sub-contractor cannot point at the main contractor. Both share the duty, and the Project Supervisor Construction Stage (PSCS) coordinates between them. Here is how the duty actually splits.
Who is who under Irish construction law
- Client: the developer, the owner, the public body procuring the work
- PSDP: Project Supervisor Design Process - manages the design phase
- PSCS: Project Supervisor Construction Stage - manages the construction phase
- Main contractor: often, but not always, the same legal entity as the PSCS
- Sub-contractor: trade specialists working under the main contractor
- Worker: the individual employee or self-employed contractor on site
Each level has duties. The Working at Heights cert lives with the worker; the duties live with the legal entities above.
The PSCS duty for Working at Heights
The PSCS must:
- Maintain a Construction Phase Health and Safety Plan covering work at height
- Coordinate work between contractors so two trades do not create a dangerous interface (e.g. roofer above scaffolder)
- Keep training records for every worker on site
- Manage the permit-to-work system for fragile roofs and high-risk activities
- Conduct site safety inductions covering the work-at-height controls
- Notify the HSA of the site (AF1 form) before work commences
Sub-contractor duties
Each sub-contractor must:
- Provide their own risk assessment and method statement for their activity
- Hold valid Working at Heights Certificates for every worker on site
- Inspect and maintain their own equipment
- Brief their workers on the PSCS's site-wide controls
- Report incidents and near-misses to the PSCS within 24 hours
- Sign on / sign off the daily site induction
The interface between trades
Most Irish construction fall incidents happen at the interface between trades, not within one trade. Examples:
- Scaffolder finishing a lift while M&E moves equipment to the deck
- Roofer working above electricians on a flat roof
- Painter using a tower scaffold while a delivery is unloaded against the same wall
- Solar PV installer working while plumbers come up the same scaffold
The PSCS owns these interface decisions. Sub-contractors must follow them. Both must document.
What inspectors check on multi-contractor sites
- Construction Phase Plan present, dated, signed by PSCS
- Sub-contractor risk assessments aligned with the PSCS plan
- Working at Heights Certificates for every worker - including the new face who started this morning
- Daily induction records signed
- Equipment inspection logs
- Permit-to-work records for fragile roof or high-risk work
- Coordination meetings minuted (weekly typically)
The "we just turned up today" problem
Sub-contractor crews arriving for a one-day job often have outdated training, no risk assessment, and a Safe Pass card from 2018. The PSCS cannot let them work. Solution: the sub-contractor sends the Working at Heights Course online link the night before. Workers complete it in 45 minutes, download cert, ready for the morning. Volume rates for crews of 5+.
Worker self-protection
Even in a multi-tier contracting chain, a worker has the right (and duty) to refuse unsafe work. The SHWW Act protects against retaliation for raising legitimate safety concerns. If a worker is told to step onto a fragile roof without permit-to-work, they can refuse - and the law backs them.
The training piece
Every level (PSCS, main contractor, sub-contractor, worker) needs Working at Heights training appropriate to their role. The Working at Heights Course online handles the worker level. PSCS and contractor management can take it as well, then layer on additional management-of-safety qualifications. 45 minutes, 35 euro, instant Working at Heights Certificate.
FAQs
If I am a self-employed sub-contractor with no employees, do I still need the cert?
Yes. The Working at Heights duties apply to the self-employed under Section 13 of the SHWW Act.
Can a CSCS card from the UK substitute for the Working at Heights Course?
No. CSCS is a UK card; the Working at Heights Course is task-specific competency. Most Irish PSCS will not accept CSCS alone.
What happens if a worker arrives on site with an expired cert?
The PSCS must turn them away from work at height until renewed. The fastest fix is the 45-minute online refresher.
Get the whole sub-contractor crew certified before mobilisation. Start the Working at Heights Course online, instant Working at Heights Certificate, recognised by every Irish PSCS.
