Process plantsManufacturing and industrial sites

OHS Act Legal Compliance Audit Checklist (South Africa)

The records a plant should be able to produce when the Department of Employment and Labour or an ISO 45001 auditor asks. Work through it per site, attach the evidence, and give every gap an owner and a due date.

Before a Department of Employment and Labour visit, and at least once a year · 25 checks · free printable PDF

An inspector with a checklist at stainless process equipment

What the checklist covers

Appointments and responsibilities

Chief executive officer's duties assigned to managers and recorded in writing (the CEO stays accountable), section 16(2)
Health and safety representatives designated in writing where there are more than 20 employees, section 17
Health and safety committee established where there are two or more representatives, and meeting at least every three months, section 19
Every appointment the regulations that apply to the site require is made in writing, with evidence of competence
Appointment letters current: no one listed who has left or changed role

Risk and documentation

Hazard identification and risk assessments done for the site's tasks and reviewed
Health and safety policy current and communicated
A copy of the Act and the regulations that apply is readily available at the workplace where there are five or more employees, General Administrative Regulations, regulation 4
Safe work procedures exist for the high-risk tasks the risk assessment identified

Contractors

A written agreement with each contractor (mandatary) on the arrangements for complying with the Act, so the employer is not liable for the contractor's acts under section 37(1); section 37(2)
Contractors' safety files reviewed before work starts
Contractor inductions recorded

Incidents

Every incident recorded and investigated
Reportable incidents reported to the Department of Employment and Labour, section 24
Corrective actions from investigations closed, with evidence the fix worked

Equipment and inspections

Statutory inspections current for lifting machinery, pressure equipment and electrical installations, with the records on file
Pre-use and periodic inspection records available for plant and equipment
Fire equipment serviced and records kept

Training, health and PPE

Inductions and task training recorded per employee
Medical surveillance done where the risk assessment requires it
PPE issued free of charge, with issue records
First aiders trained and certificates current

Closing the audit

Findings from the previous audit closed and verified
Every new gap recorded with an owner and a due date
Audit report signed and shared with the health and safety committee

How to use this checklist

1Audit one site at a time, with the site representative who knows where the records are kept.
2Work through each section and ask to see the evidence: an appointment letter, minutes, a register or a certificate.
3Mark each item Yes, No or N/A. "We have it somewhere" is a No until the document is produced.
4Note where each piece of evidence is kept, so the next audit and the inspector can find it quickly.
5Give every gap an owner and a due date, and set the date of the next audit before you close this one.

A general guide, not legal advice. Section references are to the Occupational Health and Safety Act, 85 of 1993. Check each item against the current Act and the regulations that apply to your site, which add their own appointments, inspections and records.

Convert this checklist into a digital form

Run it on an Android phone with no signal, attach photos as evidence, and every failed item raises an issue with an owner and a due date.

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Paper finds the defect. Then what?

On paper, a ticked "Defect" box often stays a ticked box. In Inspecable the same checklist keeps going after it is signed:

Run the checklist on an Android phone with no signal; it syncs when the crew is back in range.
A failed item raises an issue with an owner and a due date.
A corrective action cannot close without evidence and a signature.
Every completed inspection produces a signed PDF with its photos.

Questions

What does an OHS Act compliance audit check?

Whether the site can show it meets the Act: section 16 appointments, health and safety representatives and committees, risk assessments, contractor agreements, incident reporting, equipment inspections and training. It checks records and systems, not just conditions on the floor.

How often should we audit legal compliance?

At least once a year per site, and before a planned inspection by the Department of Employment and Labour or an ISO 45001 certification audit. Sites with many changes, contractors or new equipment benefit from a check every six months.

Who should do the audit?

Someone who knows the Act and is independent of the area: a SHEQ manager from another site, a consultant or an internal auditor. The site representative takes part to produce the evidence and own the gaps.

Does this replace a legal register?

No. A legal register lists every Act and regulation that applies to the site and how you comply. This checklist tests the core OHS Act records against it. Use both, and keep the register current when the law changes.

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