What legislation imposes the obligation to prepare the Safety and Coordination Plan for a construction site?
The preparation of the PSC is governed by Title IV of Legislative Decree 81/08 (TUS) in the context of a temporary and mobile construction site hereinafter referred to as “construction site”, i.e. any place where construction or civil engineering works are carried out.
Specifically, ANNEX X defines as construction sites:
Construction, maintenance, repair, demolition, conservation, rehabilitation, renovation or equipping, conversion, renewal or dismantling of fixed, permanent or temporary works of masonry, reinforced concrete, metal, wood or other materials, including structural parts of power lines and structural parts of electrical installations, road or railway works, hydraulic, maritime, hydroelectric and, only for the part involving construction or civil engineering work, reclamation, forestry and earthworks works. As well as building construction or civil engineering works, excavations, and assembly and dismantling of prefabricated elements used for the realization of construction or civil engineering works.
As can be seen, many activities fall within the scope of Title IV, from the renovation of an apartment, to the plant adaptation of a plant to a forestry arrangement.
Who prepares the Safety and Coordination Plan for a construction site?
Within a construction site, the subject who has the obligation and skills to prepare the PSC, is the Coordinator for safety in the design phase (CSP).
The tasks and responsibilities of these are defined by Article 91 of Legislative Decree 81/08.
The CSP during the design of the work and in any case before the request for submission of offers provides for the preparation of the Safety and Coordination Plan (PSC) and the preparation of the Technical File of the work (FT).
When is the Safety and Coordination Plan mandatory?
In construction sites where there is the presence of several executing companies, even if not at the same time, the client, together with the assignment of the design assignment, designates the design coordinator (CSP) who, as already indicated, has the obligation to prepare the PSC.
What responsibilities does the Client have for the contents of the PSC?
Article 93 of the TUS – Responsibilities of clients and project managers – paragraph 2 establishes that “the designation of the coordinator for the design and the coordinator for the execution of the works, does not exempt the client or the person in charge of the works from the responsibilities related to the verification of the fulfillment of the obligations referred to in Article 91, paragraph 1” or from the verification of the correct preparation of the PSC.
It is clear that in most cases the Client (especially if private) does not have the technical skills to verify the suitability of this document, but this does not exclude a profile of co-responsibility especially in the context of complex building interventions or in relation to the choice of the CSP based only on economic criteria.
But how do you avoid civil and criminal liability on the adequacy of the SGP?
The aspects that the Customer (especially if a company) must evaluate are:
- CSP requirements by requesting the specific CSP/CSE attestation and related updates (valid for five years)
- Skills of the CSP through the analysis of previous experiences on similar jobs (through the CV)
- Compliance with the minimum contents of the PSC.
On this last issue (more complex to analyze) our suggestion is to check if it respects in a macroscopic way the specifications indicated in the following paragraph and in particular if:
- is specific and detailed of the construction site in question
- contains photos and graphics
- contains a work schedule
- assesses the risks (including interference) related to the individual work phases
What are the minimum PSC contents? Analysis of Annex XV of Legislative Decree 81/08
According to Annex XV of the SUP, the PSC must contain:
- the identification and description of the work, explained with the particulars of the construction site, the description of the context in which the intervention area is located and a summary description of the work, with particular reference to the design, architectural, structural and technological specifications of the same;
- the identification of subjects with security tasks, showing the names and references of the subjects already identified such as: RdL, CSP and CSE and of the main functions with top roles in security matters
- a specific section (to be completed by the CSE) with the list of executing companies and their references (registered offices and names of employers);
- a report concerning the identification, analysis and assessment of concrete risks, with reference to the area and organization of the construction site, the works and their interferences;
- the indication of the design and organizational choices, as well as the preventive and protective measures, with reference to the site area, the organization of the construction site and the works
- the indication of the operating requirements and of the preventive and protective measures and the personal protective equipment to be used in relation to interferences between the processes
- coordination measures relating to the common use by several companies and self-employed workers, as a choice of work planning aimed at safety, of collective protection equipment, equipment, infrastructure, means and services;
- organisational arrangements for cooperation, coordination and mutual information between employers;
- the planned organisation of the first aid, fire-fighting and evacuation of workers,
- the analysis of the expected duration of the work phases and the work sub-phases taken from the work schedule provided by the Client
- the calculation of the presumed size of the construction site expressed in man-days;
- estimating the costs of security
In relation to point 2.1.3 of Annex XV, the complementary and detailed procedures to the SGP related to the autonomous choices of the executing companies, to be explained in the SOPs, must also be indicated.
With reference to the construction site, the PSC must also contain the analysis of the elements related to the state of the places that may determine interference criticalities such as:
- presence of airlines and subservices
- external factors that pose risks to the construction site, with particular attention to the surrounding vehicular traffic
- any risks that construction work may entail for the surrounding area (such as noise, dust, material fall from above).
The PSC must also analyze the phases and sub-phases of work by assessing the risks potentially present, with reference to the area and organization of the construction site, to the processes and their interference, with particular attention to the risk of:
- investment from vehicles circulating in the construction site area
- Burial in excavations
- fall from above
- resulting from the demolition and maintenance of preserved parts
- fire and explosion for hazardous processes and materials used on site
- related to the use of chemicals.
The PSC, moreover, for each element referred to in the previous points must report:
- the design and organizational choices aimed at defining the preventive and protective measures required to eliminate or minimize the risks of each individual phase of work as well as the related coordination measures
With reference to the interference between the processes and their coordination, the PSC will also report:
- a detailed analysis of work interferences with the help of the work schedule
- the operational requirements for the spatial or temporal phase shift of interfering processes and the procedures for verifying compliance with these requirements
- where risks of interference remain, preventive and protective measures and personal protective equipment to minimise such risks.
- coordination measures relating to the common use of collective protection facilities, equipment, infrastructure, assets and services.
The PSC must also be accompanied by drawings, relating to safety aspects, including the timing of the processing and explanatory tables of the preparations (including scaffolding and provisional works) and the most critical operational phases.
PSC: why turn to construction site safety experts?
Too often, in the context of a temporary and mobile construction site, technicians (architects, engineers and surveyors) are forced to deal with multiple issues, from design to construction supervision, from energy efficiency to structural ones, from building practices to cadastral ones.
It is clear that only professionals specialized in safety and hygiene at work are able to better manage all issues related to site safety, preparing PSCs that comply with legal requirements and protect customers
Need to set up a PSC and appoint a CSP?
Safetyone Ingegneria Srl, thanks to its twenty years of experience in the sector, is able to provide you with a fast, economical and professional service.