What is a baseline risk assessment, and when do you need one?

Short answer: a baseline risk assessment is the first, broad assessment of the hazards in a workplace or project, and the starting point for every later risk assessment. The Construction Regulations, 2014 require a client to prepare one for an intended construction work project. Every employer needs the same groundwork under section 8 of the Occupational Health and Safety Act.

The Construction Regulations, 2014 (Government Notice R. 84, Government Gazette 37305, 7 February 2014) took effect on publication, apart from regulations 3 and 5(7)(b), and replaced the Construction Regulations, 2003. They use the term in regulation 5(1) but do not define it. Draft replacement regulations (Government Notice 5983, 12 March 2025), not yet in force, would call for a "documented design risk assessment". Neither the Occupational Health and Safety Act 85 of 1993 nor the occupational hygiene regulations listed below use the term.

Where the law asks for one

If you commission construction work, including altering, renovating or extending a building, you are the client: "any person for whom construction work is being performed". The duties form a chain that starts with the baseline:

• Baseline risk assessment: the client must prepare one for an intended construction work project (regulation 5(1)(a)).

• Health and safety specification: the client bases a site-specific specification on the baseline (regulation 5(1)(b)), gives it to the designer (5(1)(c)) and includes it in the tender documents (5(1)(f)).

• Health and safety plan: the principal contractor's site-specific plan is based on that specification (regulation 7(1)(a)), and the client must finally approve it (5(1)(l)).

• Contractor risk assessments: each contractor must have risk assessments done by a competent person appointed in writing, before and during the work, as part of that plan, addressing ergonomic hazards as far as is reasonably practicable (regulation 9(1) and (2)).

In every workplace, section 8(2)(d) of the Act requires the employer to establish, as far as is reasonably practicable, the hazards attached to its work, substances, plant and machinery, and the precautions needed, and to provide the means to apply them. A documented baseline shows you have done that. Issue-based and continuous assessments often follow; that split is industry practice, not law.

What a baseline triggers

For health hazards, the baseline shows which regulations apply, each with its own exposure risk assessment:

• Noise: before exposure, as far as is reasonably practicable, then at intervals not exceeding 24 months, by a competent person (Noise Exposure Regulations, 2024, regulation 7(1)).

• Hazardous chemical agents: immediately, then at intervals not exceeding two years (HCA Regulations, 2021, regulation 5(1)).

• Physical agents (heat, cold, lighting, indoor air quality, vibration and non-ionising radiation): a documented assessment before exposure, then at intervals not exceeding 24 months, by a competent person (Physical Agents Regulations, 2024, regulation 6(1)).

• Ergonomics: by a competent person before work that may expose employees to ergonomic risks starts, then at intervals not exceeding two years (Ergonomics Regulations, 2019, regulation 6).

• Lead, asbestos and biological agents: each has its own assessment, repeated or reviewed at intervals not exceeding 24 months (Lead Regulations, 2001, regulation 6(1); Asbestos Abatement Regulations, 2020, regulation 5(1); Regulations for Hazardous Biological Agents, 2022, regulation 6(6)).

Noise and airborne chemical monitoring that follows must be done by an approved inspection authority (Noise Exposure Regulations, regulation 8(2)(b); HCA Regulations, regulation 6(1)(c)).

Doing, recording and reviewing it

• Who: the employer or, in construction, the client, even where it appoints an agent (regulation 5(5) and (6)). Involve people who know the work, and your health and safety representatives; the noise, chemical agents, physical agents, lead, asbestos and ergonomics regulations require consultation before the assessment.

• How to record it: the Act prescribes no format. Regulation 9(1) of the Construction Regulations is a useful model: identify the hazards, analyse and evaluate the risks "based on a documented method", document the controls and safe work procedures, and add monitoring and review plans.

• When to review it: the Act sets no interval. On a construction site, the contractor must review the risk assessment when design or construction changes alter the risk profile, or after an incident (regulation 9(7)). Elsewhere, review the baseline after incidents and changes such as a new process, chemical, machine or building.

A quick self-check

• Find your baseline risk assessment. If it predates your current layout, processes or chemicals, plan a new one.

• Check that it covers health hazards such as chemicals, noise, heat, lighting, vibration and ergonomics, not only safety.

• For each health hazard it identifies, confirm the specific risk assessment exists and is within its interval.

• Planning an extension, renovation or new building? Prepare the baseline and health and safety specification before design and tender.

• Check that each assessment records who did it, the method used and its review date.

How Qualitas can help

Our health risk assessments can form the occupational health part of your baseline, for an operating site or a construction project. The report sets out hazards per area and task, risk ratings, existing controls and the monitoring each regulation requires, written for management, SHEQ teams and auditors.

Qualitas Occupational Consulting is a Department of Employment and Labour Approved Inspection Authority and a SANAS-accredited (ISO/IEC 17020) inspection body for asbestos, lead, noise and hazardous chemical agents. See also our guides to occupational health risk assessments and approved inspection authorities and competent persons.

Not sure what your site needs? Start with our free Compliance Gap Analysis, request a quote, or call or WhatsApp 082 649 6599.

This article is general guidance based on section 8 of the Occupational Health and Safety Act 85 of 1993, the Construction Regulations, 2014 (Government Notice R. 84, Government Gazette 37305, 7 February 2014) and the regulations named above. It is not legal advice; refer to the Act and the regulations for the full requirements.

Christo de Wet is a SAIOH-registered occupational hygienist with 15 years' experience and the founder of Qualitas Occupational Consulting.