Falls Remain South Africa’s Leading Cause of Workplace Fatalities

Falls from height are consistently among the most frequent causes of fatal injuries on South African construction sites and across industries where employees work at elevation. Despite this, the Fall Protection Plan — the document that Construction Regulation 10 requires to be in place on every site where work at height is performed — remains poorly understood and inconsistently implemented.

Many contractors and employers know the Fall Protection Plan exists as a legal requirement, but fewer understand what it must actually contain, who is legally qualified to compile it, or how it connects to the training requirements the Construction Regulations impose on every employee who works at height. This post addresses all three questions.

The Legal Basis: Construction Regulation 10 of the Construction Regulations 2014

The Construction Regulations 2014, promulgated under the OHS Act 85 of 1993, govern health and safety on construction sites and work involving construction activities. Regulation 10 deals specifically with fall protection.

The Regulation places a duty on the contractor to ensure that a Fall Protection Plan is developed and implemented for every site where work is performed at a position where a person could fall and be injured. This duty is not conditional on the height of the work, the duration of the task, or the number of workers involved — if someone could fall and be hurt, a Fall Protection Plan is required.

The Fall Protection Plan must be compiled by a competent person — specifically, a qualified Fall Protection Planner — and must be site-specific. A generic document copied from another project and given a new name does not satisfy the Regulation. The plan must reflect the actual hazards, working conditions and control measures applicable to the specific site and the specific work being performed there.

What Must a Fall Protection Plan Contain?

Construction Regulation 10 sets out the minimum content requirements for a Fall Protection Plan. The plan must address the following:

• A risk assessment of all work at height activities on the site — identifying every location and task where a fall risk exists, assessing the likelihood and severity of harm, and determining appropriate control measures for each.
• The fall prevention and fall arrest measures to be used — specifying which collective protection measures (guardrails, edge protection, safety nets) and personal fall protection equipment (harnesses, lanyards, anchor systems) will be deployed, and where.
• Inspection, testing and maintenance programmes for all fall protection equipment — covering the intervals and procedures for inspecting harnesses, lanyards, anchor points, anchor lines and any other fall protection equipment used on site, and the competency requirements for those conducting inspections.
• Training requirements for all persons who work at height — identifying which training each worker must have completed before being permitted to work at height on the site, and confirming that this training has been received.
• A rescue plan — documenting the procedures and resources that will be used to rescue a worker who has fallen and is suspended in a harness, or who is otherwise incapacitated at height. Suspension trauma is a genuine and time-critical risk; a rescue plan is not optional.
• Personal Protective Equipment (PPE) specifications — identifying the appropriate fall protection PPE for each task and ensuring it is suitable for the hazard, correctly fitted, and used by workers who have been trained in its use.

It is worth emphasising the rescue plan requirement specifically. Many Fall Protection Plans in circulation satisfy most of the above content requirements but contain either no rescue plan or a wholly inadequate one. A person suspended in a harness following a fall can develop suspension trauma — a life-threatening physiological response — within minutes. The rescue plan must specify who will conduct the rescue, what equipment will be used, and how the injured person will be lowered or extracted safely. This is not a tick-box exercise; it is a practical emergency procedure that must be capable of being executed rapidly by trained personnel on site.

Who Is Qualified to Compile a Fall Protection Plan?

Construction Regulation 10 requires the Fall Protection Plan to be compiled by a competent person. In the context of fall protection, competency has a specific meaning: the person must hold a recognised qualification as a Fall Protection Planner.

Altramed’s Fall Protection Planner (FPP) course — aligned to SAQA Unit Standard 229994 — is the qualification that produces this competency. The three-day programme equips learners to conduct site-specific fall risk assessments, select appropriate fall prevention and fall arrest controls, design inspection and maintenance programmes, compile the rescue plan component, and produce a compliant Fall Protection Plan document.

This is a critical point for contractors and principal contractors to understand: appointing a well-meaning but unqualified person to compile a Fall Protection Plan does not satisfy Regulation 10. If an incident occurs and the plan was compiled by someone without the appropriate qualification, the contractor’s legal exposure is substantially increased.

The Hierarchy of Control in Fall Protection

A well-compiled Fall Protection Plan applies controls in the correct order of priority — from elimination through to PPE as the last resort. This hierarchy is fundamental to understanding how the plan should be structured:

1. Elimination — can the work at height be avoided entirely? If the task can be performed from ground level using extended tools or equipment, this is always the preferred option.
2. Collective fall prevention — where work at height cannot be avoided, the first physical control must be collective: guardrails, edge protection, safety nets or working platforms with toe boards and handrails. These protect all workers without requiring individual action.
3. Fall arrest systems — where collective prevention is not practicable, personal fall arrest systems are deployed: full-body harnesses connected via lanyards or retractable devices to certified anchor points or anchor lines. These do not prevent a fall but limit its consequences.
4. Administrative controls and training — safe work procedures, permit-to-work systems, supervision and the training requirements discussed below.

A Fall Protection Plan that skips directly to harnesses without considering whether collective prevention was practicable fails the hierarchy test — and fails to reflect a genuine risk assessment.

Training Requirements That Flow From the Fall Protection Plan

One of the key outputs of a Fall Protection Plan is the identification of the training that every worker who operates at height on the site must hold. The Construction Regulations 2014 require that workers be competent for the tasks they perform, and work at height is explicitly addressed.

Altramed’s Work at Heights training suite covers the full range of competencies the Fall Protection Plan will identify:

• Fall Prevention (FP) — a one-day course covering the principles of fall prevention, collective protection measures, safe work practices at height and the correct use of fall prevention equipment. This is the appropriate training for workers whose tasks can be managed through prevention rather than arrest.
• Fall Arrest Level 1 (FA) (SAQA US 229998) — a one-day course covering the selection, inspection, correct donning and use of full-body harnesses, lanyards, connectors and anchor points for workers whose tasks involve fall arrest systems.
• Fall Arrest Rescue (FAR) (SAQA US 229995) — a two-day course that addresses the rescue plan requirements of the Fall Protection Plan directly, training designated rescue personnel to safely retrieve a suspended or incapacitated worker.
• Fall Protection Planner (FPP) (SAQA US 229994) — the three-day qualification for the competent person who compiles and maintains the Fall Protection Plan itself.

For a full explanation of the difference between fall prevention and fall arrest, and how to determine which training applies to which workers, see our earlier post: Fall Prevention vs Fall Arrest — Understanding the Difference.

Who Is Responsible — Contractor, Principal Contractor or Client?

The Construction Regulations 2014 distinguish between the client, the principal contractor and contractors. Regulation 10’s Fall Protection Plan obligation rests on the contractor performing the work at height. However, the principal contractor — the party appointed by the client to manage the overall project — carries responsibility for ensuring that all contractors on site have compliant Fall Protection Plans in place and that those plans are being implemented.

This means that a principal contractor who allows a subcontractor to perform work at height without a compliant Fall Protection Plan is not insulated from liability simply because the subcontractor is the direct employer of the workers. The chain of responsibility under the Construction Regulations runs upward, and principal contractors and clients who do not exercise appropriate oversight bear real legal risk.

Common Fall Protection Plan Failures

Based on Altramed’s experience across South African construction and industrial sites, these are the most frequently encountered deficiencies in Fall Protection Plans — precisely the issues a Department of Labour inspector will scrutinise:

• The plan is generic rather than site-specific — it does not identify actual locations, actual tasks or actual hazards on the project.
• The rescue plan is absent or consists of a single sentence stating that the emergency services will be called — not an acceptable rescue procedure for a suspended worker.
• The inspection and maintenance records for fall protection equipment are not kept or are not linked back to the plan.
• Workers on site cannot produce evidence of the training the plan specifies they must hold.
• The plan was compiled by an unqualified person who does not hold SAQA US 229994 or an equivalent recognised qualification.
• The plan has not been updated when the scope of work changed or a new phase of the project commenced.

How Altramed Can Help

Altramed provides both the training and the consulting support needed to achieve full compliance with Construction Regulation 10:

• Fall Protection Plan consulting — our qualified Fall Protection Planners compile site-specific, Regulation 10-compliant plans including risk assessments, equipment specifications, inspection programmes and rescue plans.
• Fall Protection Planner training (SAQA US 229994) — for contractors who want to build in-house competency to compile and maintain their own plans.
• Fall Arrest Level 1 and Fall Arrest Rescue training — to ensure workers and rescue personnel hold the competencies the plan requires.

To discuss a Fall Protection Plan for your site, or to enrol workers in any of Altramed’s Work at Heights courses, contact us on 086 111 1504 or visit www.altramed.co.za/work-at-heights-training/.

Frequently Asked Questions

Is a Fall Protection Plan required even for short-duration work at height?

Yes. Construction Regulation 10 does not set a minimum duration or height threshold. If a person could fall and be injured, the contractor is required to have a Fall Protection Plan in place. Short-duration tasks are among the highest-risk scenarios precisely because shortcuts are more likely to be taken when the work seems quick.

Who must compile the Fall Protection Plan?

A competent person — in practice, a qualified Fall Protection Planner holding SAQA Unit Standard 229994 or a recognised equivalent. An unqualified person compiling the plan does not satisfy the Regulation.

How often must the Fall Protection Plan be updated?

The plan must be updated whenever there is a change in the scope of work, the methods used, the equipment deployed, the personnel working at height, or the site conditions. It must also be reviewed following any incident involving a fall or near-miss. A plan that accurately described the site six months ago may not reflect current conditions.

Does every worker on site need to see the Fall Protection Plan?

Every worker who performs work at height, or who works in the vicinity of work at height, must be familiar with the relevant sections of the Fall Protection Plan — particularly the emergency and rescue procedures. The plan must be communicated, not merely filed.

Can the Fall Protection Plan and the site HIRA be combined?

The Fall Protection Plan must contain its own risk assessment for work at height activities, which can form part of the broader site HIRA. In practice the two documents are often developed together, with the Fall Protection Plan serving as a specialist component of the overall risk management framework for the project. See our post on What Is a HIRA? for more on how the risk assessment process works.