If your site has any activity where a worker could fall — from a roof edge, a suspended platform, a ladder, or an open floor slab — the Occupational Health and Safety Act places the duty on you as the employer or principal contractor to eliminate or, where that is not reasonably practicable, mitigate that hazard. On a construction site, Construction Regulation 10 of the Construction Regulations 2014 turns that general duty into a specific, non-negotiable requirement: a Fall Protection Plan must be in place before work at height begins.
Sites without one aren’t just exposed to enforcement risk. They’re exposed to the much larger problem of an incident happening on a site with no documented plan for preventing or responding to it.
What Construction Regulation 10 Actually Requires
CR10 requires that before any person carries out work at height on a construction site, a competent person must have compiled a site-specific Fall Protection Plan covering every location and task where a fall risk exists. It isn’t a generic template pulled from a previous project and rebadged — the plan has to reflect the actual site, the actual sequence of work, and the actual equipment being used.
The contractor’s obligations under CR10 don’t end at compilation. A contractor must:
- Designate a competent person to be responsible for preparing the Fall Protection Plan;
- Ensure the plan is implemented, kept current, and amended whenever site conditions or the scope of work change; and
- Take active steps to ensure ongoing adherence to the plan on site, not just sign-off at the start of the project.
Who Qualifies as a “Competent Person” to Compile It
The OHS Act’s competent person standard applies here, not just a job title. A competent person compiling a Fall Protection Plan needs demonstrable training, knowledge, and experience specific to work-at-height risk assessment and fall protection systems — not general construction safety experience. This is why WAHS compiles and reviews Fall Protection Plans as a dedicated service, rather than treating it as a line item bundled into a broader safety file.
For sites using WAHS-installed anchor points, mono-rail systems, or suspended access equipment, having the same specialist compile the FPP and specify the fall protection hardware closes a gap that catches a lot of sites out: a plan written without direct knowledge of the actual anchor devices or suspended access equipment installed.
What Your Fall Protection Plan Must Contain
CR10(2) sets out five specific components a Fall Protection Plan must include. This is the actual statutory list — not a general safety-file interpretation of it:
| CR10(2) reference | Component | What it must cover |
|---|---|---|
| (a) | Risk assessment | All work carried out from a fall risk position, and the procedures and methods used to address every risk identified, per location |
| (b) | Medical fitness evaluation | The process for evaluating employees’ medical fitness to work at a fall risk position, and the records of those evaluations |
| (c) | Training programme | A programme for training employees who work from a fall risk position, and the training records |
| (d) | Inspection, testing and maintenance | The procedure addressing inspection, testing and maintenance of all fall protection equipment |
| (e) | Rescue plan | The procedure, personnel and equipment required to rescue a person following a fall, implemented immediately after the incident |
Two of these get missed more often than you’d expect. The medical fitness evaluation process — item (b) — is easy to overlook because it sits outside the equipment and procedure focus most people associate with fall protection, but CR10 treats it as a mandatory, standalone component with its own record-keeping requirement. And the rescue plan — item (e) — is where a lot of otherwise well-drafted plans fall short: a plan that specifies harnesses and anchor points but has no documented rescue procedure isn’t complete. Suspension trauma can become life-threatening within minutes, and “call emergency services” is not a rescue plan.
CR10 also carries separate, related duties beyond this list — under subregulation (4), fall prevention and fall arrest equipment must be approved as suitable and of sufficient strength for its purpose, and securely attached to a structure capable of bearing the load. These duties apply alongside the five-part plan, not instead of it.
Common gap we see on site audits: Fall Protection Plans that reference anchor points generically (“engineered anchor points as per manufacturer specification”) in the inspection, testing and maintenance procedure without naming the actual installed system, its rated capacity, or its inspection status. If the plan and the hardware on the wall don’t match, the plan doesn’t hold up under scrutiny.
Where a Fall Protection Plan Fits Into Your Broader Compliance Chain
A Fall Protection Plan doesn’t operate in isolation. It should reference the inspection and certification records for the anchor points and suspended access equipment it relies on — see our guide to anchor point types and standards and, for the annual certification side, our overview of LMI inspection and certification requirements. A plan that’s current but references equipment with an expired inspection certificate is a liability gap waiting to be found during a Department of Employment and Labour site visit.
Frequently Asked Questions
Does every construction site need a Fall Protection Plan?
Any site where work at height creates a fall risk requires one before that work commences — this isn’t limited to high-rise or façade work. Roof work, scaffold access, and open-edge floor slabs all trigger the requirement.
Can the principal contractor’s safety officer compile the FPP?
Only if that person meets the competent person standard specifically for work-at-height risk assessment and fall protection systems — general SHE officer experience alone doesn’t automatically satisfy this.
How often does the Fall Protection Plan need to be updated?
Whenever site conditions, the sequence of work, or the fall protection equipment in use change. It’s a live document for the duration of the project, not a once-off sign-off.
Does WAHS compile Fall Protection Plans, or only supply the equipment?
Both. WAHS compiles and reviews Fall Protection Plans as a dedicated service, and because we also design, supply, install and certify the anchor points, mono-rail systems and suspended access equipment those plans rely on, the plan and the hardware are specified by the same team.
Get a Quote
Need a Fall Protection Plan compiled or reviewed before work starts on your site? Tell us about the project and a WAHS specialist will get back to you.
Published by Jaco Coetzer | Work at Height Solutions (Pty) Ltd