As you might be aware there are new proposed changes to the Construction Regulations 2024 published for public comment for a period of 90 days. We have deep concerns regarding specific provisions that will affect every construction project going forward.
We urge you to read through our concerns, and if you agree please add your name to the petition. The link is at the bottom of this article.
Main Concerns with the Draft Construction Regulations 2024
1. Exclusion of CHSMs from Acting as Agents
Only PrCHSAs (Professional Construction Health and Safety Agents) can act as “agents” on behalf of clients.
This excludes CHSMs (Construction Health and Safety Managers), despite their qualifications and experience.
Only ~150 PrCHSAs exist in SA, which is insufficient to meet national demand.
2. Unfair Professional Limitations
CHSMs can’t gain the experience needed to become PrCHSAs due to being blocked from early project stages.
Violates rights to fair labour and professional development (Constitution Section 22 & 23).
3. Negative Impact on Projects
Fewer available professionals will lead to:
Delays, especially for large-scale or rural projects
Increased costs
Job losses and smaller businesses being priced out
Objection to Construction Work Permit for Double-Storey Houses
Current rules apply to large projects (>R60m), but the new rules apply even to small double-storey homes.
Unfair jump in regulation level, harming:
Small developers
Informal contractors
Low- and middle-income homeowners
Adds bureaucratic burden and costs without improving safety.
⚠️ Overreach of PrCHSA Inspection Role
Regulation 6 suggests PrCHSAs may be responsible for technical/structural inspections — a role meant for engineers/architects.
PrCHSAs are not qualified for structural compliance inspections.
Problem with CR 8(4): “May” vs “Must”
Changing the wording from “must appoint CHSO” to “may” weakens site safety.
Puts too much discretion in the hands of contractors, possibly prioritizing cost over safety.
⚙️ Concerns About “Steel Cables Only” in Suspended Platforms
Draft limits “suspended platforms” to those using steel cables, excluding safe modern alternatives like Kevlar or synthetic ropes.
✅ Proposed Solutions
Allow CHSMs to act under supervision of PrCHSAs
Create a 3–5 year transition period for CHSMs
Establish mentorship and alternative pathways
Let clients appoint safety professionals based on experience and project needs.
Petition Link:
https://chng.it/SqMpWjCtCJ
About Michelle Herbst
I started working at Leads 2 Business in February 2014. I'm a Senior L2Q Account Executive for the Cape Town Region.
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