Quick Checks · 10 checks · 1 critical

Subcontractor Review
safety audit checklist

Safety performance review of a subcontractor.

Every check below says what good looks like, when it passes, the regulation or HSE guidance it rests on and the defects that usually fail it. Critical checks are marked: a fail on one of those stops the activity.

  1. 1.
    Valid insurance certificates held
    What to look forEmployers' Liability Insurance min £5m (often £10m), Public Liability typical £5m-£10m. Both in date. Subcontractor name on certificate matches contracted entity. Pre-qualification (PAS 91 or equivalent) on file. Annual refresh.
    Acceptable whenEmployers' Liability (Compulsory Insurance) Act 1969. CDM 2015 Reg 8 (PC must check competence and resource). PAS 91 / Common Assessment Standard for procurement.
    StandardEmployers' Liability (Compulsory Insurance) Act 1969. CDM 2015 Reg 8. PAS 91 / Common Assessment Standard.
    Common defectsEL cover under £5m statutory minimumCertificate expiredCertificate in trading name different from contracted entityNo PL coverCover gap discovered mid-contract
  2. 2.
    RAMS submitted and approved before start
    What to look forSubcontractor RAMS submitted to PC, reviewed, approved by competent person, returned with comments addressed. Activity-specific. Briefed to team with sign-up. Updated when method changes.
    Acceptable whenCDM 2015 Reg 9 (PC organising and managing project). MHSWR 1999 Reg 3. Reviewed against PC site rules and other contractors' activities.
    StandardCDM 2015 Reg 9. MHSWR 1999.
    Common defectsGeneric supplier RAMS, not site-specificStarted work before RAMS submittedPC review tick-and-flick, no genuine challengeTeam not briefed, RAMS in supervisor van
  3. 3.
    All operatives inducted
    What to look forEvery operative (including new starters and short-term labour) inducted before going to work face. Records signed. Refresher when site phase changes. Subcontractor cannot self-induct, must be PC-led.
    Acceptable whenCDM 2015 Reg 13(4), site induction for all on site. PC responsible for ensuring induction quality.
    StandardCDM 2015 Reg 13.
    Common defectsNew starter on site without induction (just turned up)Induction by subcontractor not PCNo record retainedNo refresher when phase changed
  4. 4.
    CSCS cards valid for all operatives
    What to look forSpot-check 25%+ of subcontractor team. Card colour matches role, in date, photo matches operative, verified through Smart Check app. Trade-tested cards (vs visitor/labourer) for skilled work.
    Acceptable whenCSCS Alliance scheme rules. CDM 2015 Reg 13 (competence). Construction Leadership Council mandate.
    StandardCSCS Alliance scheme. CDM 2015 Reg 13.
    Common defectsExpired cardsPhoto card mismatch, sharingWrong colour for role (Labourer card on bricklayer)Smart Check not used
  5. 5.
    Supervisor identified and competent
    What to look forNamed supervisor on site for the subcontractor team at all times. SSSTS minimum (or SMSTS for senior). Aware of RAMS, permits, site rules. Photo + name on noticeboard. Authority to stop work for safety. On-site, not remote.
    Acceptable whenCDM 2015 Reg 8 + 13, competent persons, supervised work. CITB SSSTS / SMSTS recognised competence schemes.
    StandardCDM 2015 Reg 8 + 13. CITB SSSTS / SMSTS.
    Common defectsNo supervisor on site, team unsupervisedSupervisor working with tools, split attentionNo SSSTS / SMSTSSupervisor remote (covering multiple sites)
  6. 6.
    Working to approved RAMS
    What to look forObserved activity matches approved method statement. Sequence followed. Specified equipment used. Controls in place. If method has changed (problem on site), revised RAMS submitted before continuing.
    Acceptable whenCDM 2015 Reg 9. MHSWR 1999 Reg 3. RAMS is a live document, must be updated if reality differs.
    StandardCDM 2015 Reg 9. MHSWR 1999.
    Common defectsRAMS says use MEWP, team using ladderSequence reversed, control failsNew hazard found, RAMS not updatedSubstitute equipment used without RAMS amendment
  7. 7.
    PPE compliance by all operatives
    What to look forWalk subcontractor area. 100% compliance, hard hats, hi-vis, boots; task PPE matched (gloves, eye, ear, RPE). PPE issued by employer (subcontractor must provide). Damaged kit replaced.
    Acceptable whenPPE at Work Regs 1992 (amended 2022). Subcontractor provides own PPE per HSWA 1974 s.9. PC enforces site rules.
    StandardPPE at Work Regs 1992. HSWA 1974 s.9.
    Common defectsSubcontractor team without RPE for dusty workDamaged hard hats, no replacement on handEar protection in pocket, not wornWrong gloves for the cut hazard
  8. 8.
    Housekeeping in their work area acceptable
    What to look forSubcontractor work area tidy: own off-cuts, packaging, dust cleared at end of shift. Materials stored neatly. No accumulation. Clean-as-you-go culture.
    Acceptable whenCDM 2015 Reg 25. Workplace (HSW) Regs 1992 Reg 9. Subcontractor responsible for own area.
    StandardCDM 2015 Reg 25. HSG155.
    Common defectsEnd-of-shift mess passed to next tradeOff-cuts stockpiled at workstationSkip overflowing, own wasteNo clean-down agreed
  9. 9.
    No unsafe practices observed
    Critical: a fail stops the work
    What to look forDirect observation period (15-30 mins). Look for: shortcuts, missing controls, untrained operatives, removed guards, riding on plant, unsecured ladders. Document anything observed.
    Acceptable whenCDM 2015 Reg 9. HSWA 1974 s.7 (employee duty). Direct intervention required if imminent danger.
    StandardCDM 2015 Reg 9. HSWA 1974 s.7. Site safety culture.
    Common defectsClimbing scaffold framework instead of using ladderUnauthorised use of plantGuards removed from grinderHard hat off in operating zoneOperatives unclipped at heightCutting without dust suppression
  10. 10.
    Waste managed and segregated
    What to look forSubcontractor waste in correct skip, wood, metal, plasterboard, hazardous separately. Carrier registration valid. WTNs / hazardous CNs retained. No fly-tipping, no burning.
    Acceptable whenEPA 1990 s.34, duty of care. Hazardous Waste Regs 2005. Waste (England & Wales) Regs 2011.
    StandardEPA 1990 s.34. Hazardous Waste Regs 2005.
    Common defectsPlasterboard mixed with general wasteNo carrier licence checkedHazardous waste in general skipWTNs not retainedWaste taken away by uncontracted "man with van", fly-tip risk

Questions people ask

How often should a subcontractor review audit be done?

These are the short ones: daily or at the start of every shift, before the work begins. Two minutes and a signature.

What is the difference between a safety audit and an inspection?

An inspection looks at the site. An audit checks the system as well: is the paperwork there, do the people know it, is what was promised actually happening. On a small site the words blur, and that is fine. The checks below cover both.

What happens with a failed item?

A corrective action with an owner and a date, and a photo of the fail so nobody argues later. 1 of the 10 checks here are marked critical: a fail on one of those stops that activity until it is put right.

Who should carry out the audit?

A competent person, and where possible not the person whose work is being looked at. The site manager auditing the site manager's housekeeping is better than nothing, but a visiting supervisor or the SHEQ lead sees what the regular eye has stopped noticing.

Is a site safety audit a legal requirement?

The Management of Health and Safety at Work Regulations 1999 require arrangements for monitoring your health and safety measures (regulation 5), and CDM 2015 requires every contractor to plan, manage and monitor the work under their control (regulation 15). A recorded, scored audit is how you show that is happening. Guidance, not legal advice.

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