Pre-start safety evidence for construction subcontractors in New Zealand

A subcontractor can pass a general prequalification review and still arrive at a building site without a plan for the actual workfront. Before work starts, the lead contractor and subcontractor need to exchange information about the job, identify shared risks, agree who will control them and make sure the people doing the work understand the arrangement. The evidence should be proportionate to the work rather than a fixed collection of certificates.

WorkSafe New Zealand's position on information needed before hiring contractors says prequalification is one way to assess general capability, but it is not compulsory and does not complete ongoing duties. Its guidance on PCBUs working together explains why the contracting chain must share information and coordinate. This page focuses on task and site evidence immediately before mobilisation, separate from a generic prequalification process.

Describe the actual work and shared site

Begin with the subcontract package, dates, work area, plant, likely hazards and other businesses nearby. A tender submission can establish broad capability but may predate a new excavation, altered access or different programme. The lead contractor should provide current site constraints and known risks; the subcontractor should explain how its own work could affect others. WorkSafe's construction guidance notes that multiple businesses and changing conditions require planning and communication.

Record the scope of the decision. Evidence for roofing on one building is not automatic approval for confined-space work at another site. If the named supervisor, plant or method changes, revisit the relevant checks. A pre-start review is an operational control, not a permanent badge of compliance.

Ask for evidence tied to the risk

The contractor may need to provide a task method or job safety analysis, worker competence information, relevant plant inspection records, emergency arrangements and details of any specialist design or permit. The exact set depends on the task. A brief low-risk service visit should not be burdened with irrelevant paperwork, while a complex lift or demolition package needs far more than a generic safety policy.

Check whether evidence is current, applicable and understood. A certificate bearing a company name may not show that this crew has the right skills. A generic method statement may not reflect a public access route or live electrical installation. Ask the supervisor to walk through the activity and describe the controls. Document any discrepancy and give it an owner before the workfront opens.

Coordinate overlapping duties

Under the Health and Safety at Work Act 2015, persons conducting a business or undertaking (PCBUs) can share duties in relation to the same matter. WorkSafe's overlapping-duties guidance says PCBUs must consult, cooperate and coordinate so far as reasonably practicable. A contract cannot simply pass the risk to another party. The parties should identify who has influence and control over each risk and agree practical arrangements.

For example, the subcontractor may control its cutting equipment, while the lead contractor controls access and sequencing around other trades. Both need to understand how dust, noise and pedestrians will be protected. Record the control, responsible person, communication route and how it will be checked during work. Do not rely on a sentence saying “subcontractor responsible for all safety” to solve a shared interface.

Make the decision before the crew starts

Use an explicit outcome: start under agreed controls, delay a defined activity pending evidence, or redesign the arrangement. Name the person who made the decision and the scope it covers. A missing technical approval should not be treated like a routine document that can arrive later. Equally, a minor administrative correction need not prevent unrelated safe work if the site has a documented way to manage it.

Give the subcontractor the current site rules, emergency arrangements, reporting route and workfront restrictions. Confirm that the crew receives an induction or briefing appropriate to its work. WorkSafe's contracting advice describes information sharing after contractor selection and ongoing monitoring, not a one-time document exchange.

Example: changed delivery and lifting sequence

A precast installer was prequalified before the construction programme changed. At pre-start, the lead contractor learns that the crane will operate beside an active pedestrian route and another trade's material store. The installer supplies its lift planning and named competent people; the lead contractor provides ground and traffic information. The parties agree an exclusion zone and delivery window, brief affected crews and check that the actual site matches the plan. The workfront is delayed until the missing ground information is resolved.

The original prequalification remains useful background, but it could not have established the controls for this particular lift. The pre-start record shows the new evidence, decision and communication.

Keep checks live during the job

Retain the work scope, evidence reviewed, agreed controls, conditions, briefings and monitoring results. When another subcontractor enters the same area, reassess the overlap. When the method changes, revise the task plan and tell affected PCBUs. Sample actual work rather than assuming that signed documents prove implementation. A repeated gap may require better scheduling or contractor selection rather than another form.

At project handover, identify conditions still open and who will verify them on the next shift. Keep obsolete versions of the task plan in the audit trail, while making the current version unmistakable to the crew. That distinction matters when an incident occurs after a change in sequence.

For a current-product discussion, use the Complys New Zealand health and safety page to ask how evidence, owners and follow-up can be organised in the implemented product. Verify any specific feature before publication. This guide does not claim that Complys legally approves contractors, verifies technical qualifications, monitors a site automatically or transfers PCBU duties.