Contractor Compliance Register Template (Section 37 Mandataries)
A register of every contractor working on the site and the evidence that lets them be there: a COIDA letter of good standing, public liability cover, a tax clearance, a signed section 37(2) agreement, an approved health and safety file and completed inductions. The register owner keeps it; a second person verifies each entry.
Opened before a contractor starts and kept for as long as they are on site. Reviewed monthly, and before any renewal, extension or new scope of work.
What is in the template
Contractor register
Columns: Contractor · Scope of work · COIDA good standing expiry · Public liability expiry · Tax clearance expiry · Section 37(2) signed · H&S file approved · Inductions done · Review date · 12 rows per page
One row per contractor, including sub-contractors. Write the expiry date, not "yes". A date in the past means the contractor may not be on site until the document is renewed and the row is updated.
Appointed persons (per contractor)
- Contractor
- Supervisor (name and contact number)
- Health and safety representative
- First aider
- Appointment letters seen (date)
Repeat for each contractor. The appointments are the contractor's own, made in writing under the Act and regulations that apply to the work.
Sign-off
- Register owner
- Verified by (second person)
- Date
- Signature
How to fill it in
- 1List every contractor and sub-contractor on site, with the scope of work they are contracted for. A contractor working outside the listed scope is a finding.
- 2Collect the documents before the contractor starts and write the expiry date of each on the row. Copy the date from the document itself, not from the contractor's covering letter.
- 3Confirm the section 37(2) agreement is signed by both parties and dated, and that the health and safety file has been reviewed and approved for the scope, not just received.
- 4Record the contractor's appointed supervisor, health and safety representative and first aider, and see the appointment letters.
- 5Have a second person check each row against the documents and sign the register. Review it monthly, and remove a contractor from site when a row lapses.
A general template, not legal advice. Check it against the Act, the regulations and the codes of practice that apply to your site, and against your own safety management system. The OHS Act section 37(1) makes the employer answerable for the acts and omissions of a mandatary unless the conditions in that section are met, and section 37(2) lets the employer and the mandatary agree in writing on the arrangements and procedures for compliance. The Construction Regulations, 2014, set the client's duties in regulation 5 and the principal contractor's duties in regulation 7, including the health and safety file. A letter of good standing from the Compensation Fund under COIDA shows the contractor's assessments are paid. ISO 45001 clause 8.1 covers the control of contractors and procurement.
Convert this template 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.
The same record in Inspecable
On paper the register is only as current as the last person who updated it. In Inspecable the same record keeps going:
- The contractor compliance register records COIDA, public liability, good standing, tax clearance, the H&S file and B-BBEE with expiry dates, and a second person verifies each entry. Records only, no file upload.
- Appointment letters, induction material and procedures sit in documents with versions, expiry badges and read-and-acknowledge by version; the Android app reads the current version offline.
- The section 37 obligation and the appointments it depends on sit in the legal register, seeded with an OHS Act pack or MHSA obligations, so the contractor evidence and the legal evidence are one record.
Questions
What is a section 37(2) agreement?
A written agreement under section 37(2) of the OHS Act between an employer and a contractor (the mandatary) setting out the arrangements and procedures each will follow to comply with the Act. It is signed before work starts and kept with the contractor's file.
Does a section 37(2) agreement make the contractor fully responsible?
Not on its own. The agreement sets out who does what; the employer still has its own duties under the Act and must see that the arrangements are followed. A register with current evidence, inductions and a second-person check is how an employer shows that it did.
What is a COIDA letter of good standing?
A letter from the Compensation Fund confirming that an employer is registered and its assessments are paid up, so its workers are covered for injury on duty. It expires, usually within a year, so the register records the expiry date rather than a tick.
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