Construction consistently ranks among the highest-risk sectors for workplace injury in South Africa. Falls, machinery-related trauma, and manual handling injuries occur regularly on active sites, which makes proper first aid provision one of the most practically important — and most frequently under-resourced — compliance areas for contractors.

The Legal Foundation: General Safety Regulation 3

First aid obligations on construction sites flow from the same source that applies to every South African workplace: General Safety Regulation 3 (GSR 3) under the OHS Act. GSR 3 requires at least one trained first aider for every 50 employees. We’ve set out the full ratio requirements in our guide to first aider ratios.

On a construction site, this ratio is a floor, not a ceiling. Given the elevated risk profile of construction work, a properly conducted HIRA will frequently indicate that more first aiders — and first aiders trained to a higher level — are appropriate than the bare legal minimum.

Why Construction Sites Need a Different Approach

Several factors specific to construction environments push first aid provision beyond what a typical office or light-industrial site would require:

• Elevated injury severity — falls from height, crush injuries, and machinery-related trauma tend to be more severe than typical office injuries
• Site dispersion — large sites may have workers spread across multiple locations, meaning first aid needs to be genuinely accessible, not just present somewhere on site
• Multiple employers on one site — principal contractors and subcontractors often share a site, which can create confusion about who is responsible for first aid coverage if it isn’t addressed directly
• Changing site conditions — as a project progresses through different phases, the specific hazards present — and therefore the first aid needs — can shift significantly

Linking First Aid Provision to Your HIRA

As we’ve covered in our HIRA guide and our post on matching first aid training level to risk, the appropriate level of first aid competency for any workplace is determined by risk assessment, not assumed. Construction sites should have this addressed explicitly within their site-specific risk documentation, covering:

• The number of first aiders required to meet the GSR 3 ratio across the full site workforce
• The level of first aid training appropriate to the hazards actually present (falls, heavy machinery, excavation work, and so on)
• Where first aid equipment and trained personnel will be physically located so they are genuinely accessible from all active work areas
• How first aid coverage is coordinated when multiple contractors are working on the same site

Responsibility When Multiple Contractors Share a Site

A common point of confusion on construction sites is who is actually responsible for first aid coverage — the principal contractor, or each individual subcontractor. In practice, every employer retains their own GSR 3 obligation for their own employees. However, principal contractors typically take the lead in coordinating overall site first aid arrangements as part of the site’s broader health and safety planning, to avoid gaps where no single party has actually accounted for coverage.

This coordination should be addressed and documented before work begins, not worked out reactively after an incident occurs.

Practical Steps for Contractors

1. Confirm first aider numbers against the full on-site workforce, including subcontractor employees where relevant
2. Match first aid training level to the hazards identified in the site HIRA — not a generic minimum
3. Position first aid equipment and personnel so they are genuinely accessible across a physically dispersed site
4. Document coordination arrangements clearly where multiple contractors share a site
5. Review and adjust first aid provision as the site progresses through different phases of work

Frequently Asked Questions

Does GSR 3 apply differently on construction sites than other workplaces?

The ratio requirement itself is the same — at least one first aider per 50 employees. What differs is that a construction site’s HIRA will typically identify higher-severity risks, which in turn calls for a higher level of first aid training and, often, more first aiders than the bare minimum ratio would suggest on its own.

Who is responsible for first aid when subcontractors are on site?

Each employer retains their own GSR 3 obligation for their own employees. Principal contractors typically coordinate overall site first aid arrangements to prevent gaps in coverage, and this should be documented as part of the site’s health and safety planning.

Should first aid provision change as a construction project progresses?

Yes. As the hazards present on site change through different phases of work, first aid provision should be reviewed and adjusted to match the current risk profile, not left as a static, once-off arrangement.

Need help getting your site’s first aid provision right? Contact Altramed — call 086 111 1504 or visit our First Aid Training page.