Safety Training for the Construction Industry in Hong Kong
By Dominic Mak, Assistant Commissioner for Labour & Michael Chan, Deputy Chief Occupational Safety Officer (Training) From Hong Kong Labour Department
This paper briefly examines the various safety-training schemes designed for the construction industry in Hong Kong.
During 1999, the overall occupational safety and health performance in Hong Kong industries recorded significant improvements compared to the 1998 figures. The number of industrial accidents in Hong Kong decreased by over 16% compared with the figures for 1998. The accident rate per 1,000 workers for all industries also dropped by 15% over the same periods. More remarkably, the number of accidents in the construction industry recorded a sharp reduction of 28%. In spite of the improvements, the 1999 accident rate for the construction industry, which stands at 198 per 1,000 workers, is still unacceptably high. Figure 1 is an analysis of the 1999 industrial accidents in Hong Kong by industry groups. The industry’s occupational safety and health performance certainly has room for improvement.
Requirements for compulsory safety training
As part of the overall strategy to improve the OSH performance in the construction industry, a number of compulsory training schemes were introduced by the Government in the last few years. Such schemes include the basic safety induction training for all construction workers, training for confined space workers, training for operators of high-risk machinery (e.g. cranes, suspended working platforms and other loadshifting machinery) and training requirements for registered safety officers and safety auditors.
Safety induction training
It is widely recognized that basic safety induction training for workers helps to enhance safety awareness at work and consequently helps to reduce accidents at the workplace. For example in 1995 and 1996, contractors in some Government building projects in Hong Kong were required, as part of their contract conditions, to provide basic induction training to site workers. After a two-year pilot run, the accident rate for these projects was 78% lower than corresponding figures for other private construction projects, where no safety induction training was provided during the same period.
Knowing the proven benefits of safety induction training and after wide industry consultation, the Hong Kong Labour Department (the Department) introduced compulsory basic safety induction training to the construction and container-handling industries in July 1999 with a 14 months grace period before it becomes effective.
In January 1999, the Department introduced an amendment to the Confined Spaces Regulations to require all workers working in confined spaces to be suitably trained. Employers are also required to engage the services of a competent person to carry out an assessment of the working conditions and nature of tasks to be performed in the confined space before work can commence in the confined spaces. This compulsory training requirement became effective on 19 June 2000
Operators of High-risk Machinery
On a construction site, operators of high-risk machinery, such as cranes, suspended working platforms and loadshifting machinery (e.g. excavators) are required to hold the relevant certificates. The Department does not issue these certificates. They are issued by training providers approved by the Department. With the exception of loadshifting machinery, which will come into effect around the end of 2001, requirements for other high-risk machinery are already in force.
Accreditation Process for the Safety Training Schemes
The Department administers the accreditation process for the basic safety induction, confined spaces and machinery-operator training schemes. The entire process is structured to ensure transparency, consistency and fairness in implementation. The quality of training is also regularly monitored by the Department to ensure that it remains well above the minimum acceptable quality.
A course guideline, setting out the detailed curriculum for the particular training course, as well as the accreditation process, is published by the Department to assist all training providers intending to seek approval to conduct such training. These course guidelines improve transparency of the entire accreditation process.
Accredited training providers issue the relevant certificates to all successful trainees. Such certificates are valid for a fixed number of years and holders of expired certificates are required to satisfactorily complete a revalidation training course to renew their certificates for another fixed term.
Registered Safety Officer
Proprietors of construction projects employing over 100 workers are required, under the Hong Kong OSH legislation, to employ a full-time safety officer registered with the Department. Additionally, a safety supervisor is to be appointed for each construction site where there are 20 or more persons employed. Although the safety officer and safety supervisor requirements may not be categorized as a compulsory training requirement, it nevertheless has an in-built training component.
A person must satisfy certain requirements before the person can be considered for registration as a safety officer. The academic qualifications and working experience required are very stringent as set out in the relevant Regulation. In general, a person is required to hold a tertiary qualification in a specified subject and possesses one to two years working experience relevant to the duties of a safety officer.
Since 1987, when the safety officer registration scheme was first introduced in Hong Kong, over 1,900 safety officers have been registered. It is, however, estimated that only 40 % of these registered persons are actively engaged as safety officers in industry.
After extensive industry consultation, the Department intends to amend the current Regulation to require registered safety officers to revalidate their registration once every four years. As a condition for revalidation, they are required to attend 100 hours of continuing professional development (CPD) programmes over a four-year period. CPD will indirectly become another training requirement for the construction industry.
In November 1999, the Government introduced a Safety Management Regulation to require proprietors, who employ more than 100 workers in certain high-risk industries (including construction sites) to implement a safety management system. Such employers are also required to engage the services of a registered safety auditor to conduct regular safety audits to ensure that the safety management system is implemented effectively. There is a twelve-month grace period before the Regulation will become effective.
The qualification required for a person to be registered as a safety auditor is spelt out in the Regulation. In general, a person has to complete an approved training scheme and possess relevant working experience in the management of occupational safety and health. Only approved training providers are authorized to conduct the safety auditor-training scheme. The Safety Management Regulation has in fact become another indirect training requirement for the construction industry.
Other Safety Training for Supervisors and Managerial Staff
Apart from the education and training requirements for safety officers, who would normally occupy supervisory or middle managerial positions in construction sites, there are other safety training courses for supervisors and managerial staff. Examples of such courses are those specifically developed for assistant safety officers and safety supervisors. A number of training providers in Hong Kong conducts these courses.
Training is a long-term strategy. While the effectiveness of the accreditation process and the actual knowledge transfer to trainees could be monitored, its immediate and direct contributions to the reduction of workplace injuries are always more difficult to assess. In any case, extensive research has indeed established that safety training will have a positive long-term effect, especially on improving the overall safety culture of the industry.
From the list of safety training conducted for the construction industry, it is evident that the industry already bears a heavy burden on training. In view of their existing training burden, any additional compulsory training for the construction industry must only be considered if the training is absolutely necessary and that the benefits far outweigh the implementation costs.
It should also be noted that compulsory training schemes, by design and administration, are generic in nature. The bulk of these courses are open to the public. In general, the training contents delivered to the groups of mixed audience would only address generic safety issues that are common and applicable to all construction sites. Such generic training cannot effectively deal with site-specific issues, such as emergency planning and procedures for a particular site.
Contractors should be given the flexibility to develop and conduct their own in-house training to supplement generic safety training. Contractors must have the opportunity to ensure that their workers are trained on site-specific issues. The obligation for contractors to conduct such training is already enshrined in the general duty provisions of the main Ordinance and need not be the subject of another Regulation.
Furthermore, it is suggested that more effort should be placed on the integration of relevant safety topics into existing vocational training courses. This is to ensure that when a person is initially trained for a particular vocation (such as erecting a scaffold), more training effort is spent on the safety aspect of the job. If a positive safety culture is inculcated at the early stage, there will be minimal need to impose any further compulsory training for the construction industry.
Dominic Mak has been with the Hong Kong Labour Department for many years and is a very experienced senior inspector. He is presently Assistant Commissioner for Labour, Occupational Safety responsible for over 400 inspectors.
Michael Chan is a mechanical engineer. He is presently employed as Deputy Chief Occupational Safety Officer by the Hong Kong Labour Department responsible for all training activities related to occupational safety and health (OSH). Prior to that Michael was employed for 17 years (1981 to 1997) with the Division of Workplace Health and Safety, Queensland Government in Australia.
The Hong Kong Labour Department Occupational Safety and Health Branch web site is www.labour.gov.hk/eng/osh/content.htm