PSCS vs PSDP: Who Does What, and the Site Records to Keep
When a client has to appoint a PSDP and a PSCS under the 2013 Construction Regulations, what each one does, the eight records a PSCS should be able to show, and a six-week job that two Saturdays make notifiable.
Contents
A PSCS (Project Supervisor Construction Stage) is the person or company the client appoints in writing, before work starts, to coordinate safety and health on site under the Safety, Health and Welfare at Work (Construction) Regulations 2013. The PSDP (Project Supervisor Design Process) does the same job for the design. Both must be appointed where more than one contractor is involved, where the work involves a particular risk, or where the job must be notified to the Health and Safety Authority (HSA) because it is planned to last more than 30 working days or 500 person-days.
It sounds like paperwork, but the paperwork is what an inspector asks for after something goes wrong. On 20 October 2026 the HSA published a review of construction deaths in 2022–2024: 19 of the 23 fatalities (83%) happened on sites with one to four workers. Small jobs are where the PSCS role goes to "whoever the builder is" and the records are thinnest.
PSCS vs PSDP at a glance
The two roles split the project in time. The same person or company can hold both, and a client can appoint itself, if competent to do the job (Regulation 6(2)).
| PSDP | PSCS | |
|---|---|---|
| Stage | Design, including temporary works | Construction, from site preparation to completion |
| Appointed | At or before the start of design | Before construction work starts |
| Usually | Architect, engineer, surveyor or project manager | Main contractor |
| Safety and Health Plan | Prepares the preliminary plan | Develops it before work starts and keeps it up to date |
| Safety File | Prepares it and hands it to the client | Sends contractors' information to the PSDP |
| HSA notification | No project notice (the client sends the AF1) | Sends the AF2 before work starts |
The client's duties: appointing both in writing
The client is whoever the project is carried out for: a company, a public body or a homeowner paying for an extension (DIY is not covered). Many websites say a PSDP and PSCS are needed on "every project", but Regulation 6(5) is narrower. The duty applies only where at least one of these is true:
- more than one contractor is involved;
- the work involves a particular risk, such as falls from height or burial under earthfalls where the risk is particularly aggravated, or work near high-voltage lines (Schedule 1);
- the project is notifiable.
Almost every extension, fit-out or new build ticks the first box. A window replacement by a single firm with no particular risk does not; that is the HSA's own example. Where the duty applies, the client must:
- appoint the PSDP in writing at or before the start of design, and the PSCS before construction starts, with written acceptance of each;
- be reasonably satisfied that each appointee is competent and adequately resourced (Regulations 6 and 7);
- give the preliminary Safety and Health Plan to everyone tendering for the PSCS role or, on a homeowner's own house, to the PSCS once appointed (Regulation 9);
- notify the HSA on form AF1 if the job is notifiable, as early as possible after appointing the PSDP (Regulation 10);
- keep the Safety File and pass it on if the property is sold (Regulation 8).
Competence. There is no state licence or register for a PSCS. The HSA's guidelines on the Construction Regulations suggest asking about similar projects, safety training, the resources set aside for the job, an up-to-date Safety Statement and the firm's record on accidents, enforcement notices and convictions.
What the PSDP does during design
The PSDP coordinates the designers so hazards are designed out early: safe access for roof maintenance, the erection sequence of a frame, services someone will later dig around. Where the job is notifiable or involves a particular risk, the PSDP prepares a preliminary Safety and Health Plan (Regulation 12): a description of the project and its timescale, other activities on the site, the particular risks, the designers' conclusions and where the electricity, water and sewage connections are. If neither condition applies, no plan is legally required, although the appointments still are.
The PSDP also prepares the Safety File (drawings, design criteria, maintenance procedures, manuals, certificates and the location of services) and gives it to the client at the end (Regulation 13). The HSA's Safety File FAQ is clear that it is the PSDP's document, not the PSCS's.
What the PSCS does during construction
Before work starts, the PSCS develops the preliminary plan into the construction stage Safety and Health Plan, with site rules and measures for particular risks, and keeps it updated (Regulation 16). BeSMART.ie has an HSA template for it. On site, the PSCS coordinates:
- cooperation between contractors, including trades that follow each other;
- checks on safe working procedures, and access for authorised people only;
- Safe Pass cards (renewed every four years) and CSCS cards for tasks such as scaffolding, slinging and plant operation (Regulation 19);
- welfare facilities and accident reporting by contractors;
- Safety File information, sent in writing to the PSDP (Regulation 21).
On a notifiable job the PSCS sends the AF2 before work starts and displays it on site (Regulation 22). Where more than 20 people are normally employed at once, the PSCS helps arrange a site safety representative; above 100, it appoints a full-time safety adviser.
Contractors must see each worker's cards on day one and confirm them to the PSCS in writing (Regulation 25), give site-specific induction and follow the plan. An injury that keeps an employee off normal work for more than three consecutive days, not counting the day of the accident, is reported to the HSA on an IR1 within ten working days, with a copy to the PSCS.
The 8 site records a PSCS should be able to show
When the client or an inspector asks who was on site and whether their cards were valid, the answer has to be on paper or on screen. Only some of these registers are spelled out in the Regulations; the rest show the coordination happened.
| Record | What it shows | Basis |
|---|---|---|
| 1. Induction register with Safe Pass and CSCS | Everyone inducted and carded before starting | Reg. 17(5), 19, 25 |
| 2. Daily sign-in and sign-out | Who was on site each day | Supports Reg. 17(1)(h) |
| 3. Permits to work | Hot works, excavations, confined spaces, roof work closed out | Good practice |
| 4. Weekly site inspection | Hazards found, each with an action | Supports Reg. 17(1)(g) |
| 5. Toolbox talks | Rules and risks briefed, with attendance | Good practice |
| 6. RAMS register | Method statements received, reviewed, briefed | Supports Reg. 24(1)(c) |
| 7. Incidents and IR1 copies | Accidents reported and followed up | Reg. 17(1)(e), 24(1)(d) |
| 8. Directions and Safety File information | Written instructions, and what went to the PSDP | Reg. 20(3), 21 |
Statutory inspection reports sit alongside them (forms on the HSA forms page):
- Scaffolds with a fall of 2 m or more: inspected within the previous 7 days, report within 24 hours (General Application Regulations 2007, Regulation 119). The GA3 form is optional.
- Excavations where a collapse could bury or trap someone: inspected daily, with a thorough examination at least every 7 days on the approved form AF3 (Regulation 52).
- Lifting equipment: GA1 and GA2 reports.
Records are kept on site, or at the contractor's office on jobs under 30 working days. Computer records are fine if they follow the approved form and are authenticated (Regulation 3).
Worked example: a six-week extension and the 30-day line
Example (fictitious): A homeowner in Navan is adding a two-storey rear extension. Five firms do the groundworks, blocks, roof, electrics and plumbing, so a PSDP and PSCS are needed whatever the duration. The programme runs from Monday 11 January to Friday 19 February 2027.
Six weeks of weekdays is 30 days, but Monday 1 February is the St Brigid's Day bank holiday, so 29 are worked. The builder adds two Saturdays (6 and 13 February) to get the roof on: 31 days with construction work, and the HSA counts weekends. The job is notifiable, even at 127 person-days.
| Date | Who | What |
|---|---|---|
| Mon 2 Nov 2026 | Client | Appoints the architect as PSDP in writing; written acceptance |
| Mon 14 Dec 2026 | Client | Appoints the builder as PSCS, hands over the preliminary plan; sends the AF1 as soon as the programme shows 31 days |
| Mon 4 Jan 2027 | PSCS | Construction stage plan ready; AF2 submitted online, copy on the notice board |
| Mon 11 Jan 2027 | PSCS, groundworker | Inductions, card checks, first toolbox talk; AF3 before anyone enters the trench |
| Mon 18 Jan 2027 | Groundworker | Next AF3, 7 days later |
| Tue 2, 9, 16 Feb 2027 | Scaffolder | Scaffold inspected before first use, then every 7 days (GA3) |
| Fri 26 Feb 2027 | PSCS | Safety File information sent to the PSDP, a week after completion |
Crews of three to five, and three on the Saturdays, give 15 + 20 + 20 + 19 + 28 + 25 = 127 person-days. On weekdays only, the job lasts 29 working days: no AF1 or AF2, but the PSDP and PSCS are still required (five contractors), and so is a plan if the roof work is a particular risk.
A weekly routine for small contractors acting as PSCS
On a small job the PSCS work falls to the site manager or foreman. A routine that keeps the evidence current:
- Daily: sign everyone in and out, nobody starts before induction and a card check; issue today's permits and close out yesterday's; inspect excavations in use.
- Weekly: walk the site with a checklist and log each defect as an action with an owner and a date; check the last scaffold and excavation reports are under 7 days old; give a toolbox talk on next week's main risk; review the RAMS of trades starting next week; update the plan.
- At milestones and handover: collect certificates, manuals and as-built information for the Safety File, and check every reportable accident has an IR1 copy.
A training matrix that warns before cards expire keeps your own crew's Safe Pass and CSCS dates ahead of induction. Each contractor's hazards still belong in a risk assessment with a 5×5 matrix and action plan, and an accident register that works out the HSA reporting date helps with IR1 follow-up.
Our PSCS site records workbook brings the eight registers together: inductions with Safe Pass and CSCS expiry dates, a daily sign-in that flags anyone not inducted or with an expired card, permits with their status to the minute, a weekly inspection of 58 checks, toolbox talks, RAMS, and actions with owners and due dates. It does not write the Safety and Health Plan or replace the GA3, AF3 or IR1 forms.
This guide summarises the Construction Regulations 2013 (as amended up to 2021) and HSA guidance as at 21 October 2026. It is not legal advice. Check the HSA guidance for your own project and get competent advice on large, complex or high-risk work.
Frequently asked questions
Can the same company be PSDP and PSCS?
Yes. Regulation 6(2) allows one individual or company to be appointed to both roles, and a client can appoint itself, provided it is competent to carry out the duties. It is common on design-and-build contracts and small jobs with little design input.
Do I need a PSDP and PSCS for a house extension?
Usually yes, because an extension almost always involves more than one contractor. The Regulations apply to construction work you pay for in your home, not to DIY. On your own house you give the preliminary Safety and Health Plan to the PSCS once appointed, and the people you appoint must show you they are competent before work starts.
What qualifications does a PSCS need?
The Regulations require a competent PSCS with adequate resources, but there is no state licence, register or set course. The HSA guidelines suggest the client asks about similar projects, safety training, staff and resources, the Safety Statement and the firm's record on accidents, enforcement notices and convictions.
Does the PSCS have to be on site all the time?
No rule says the PSCS must be on site full time; the duty is to coordinate and monitor. On most jobs a site manager or foreman does this day to day. A full-time safety adviser is required only where more than 100 people are normally on site at any one time.
Can site safety records be kept on a computer?
Yes. Regulation 3 allows records, reports and certificates required by the Construction Regulations to be kept on a computer, provided they follow the approved form where there is one and are authenticated as soon as practicable. Inspectors must be able to see them on request.
How long should scaffold inspection records be kept?
Under Regulation 119 of the General Application Regulations 2007, the scaffold inspection report stays on site until the work is finished and then at the employer's office, and the result must be available to an inspector for five years from the date of the inspection.
Sources
- Irish Statute Book – S.I. No. 291/2013 Safety, Health and Welfare at Work (Construction) Regulations 2013 – Reg 3, 6–10, 12–13, 16–25, 52, Schedules 1 and 3
- Irish Statute Book – S.I. No. 129/2019 Construction (Amendment) Regulations 2019 – Schedule 4: Safe Pass card valid for 4 years
- Irish Statute Book – S.I. No. 528/2021 Construction (Amendment) Regulations 2021 – Safe Pass four-year period
- HSA – Guidelines on the Procurement, Design and Management Requirements of the Construction Regulations 2013 (updated) – appointments, competence, AF1/AF2, counting days
- HSA – Summary of Key Duties under the Construction Regulations 2013
- HSA – Project Supervisor Construction Stage (PSCS)
- HSA – Project Supervisor Design Process (PSDP)
- HSA – Client duties
- HSA – Construction FAQs: Safety File
- HSA – Approved Form AF1 (notification by the client)
- HSA – Construction Notification (AF1 and AF2) online system
- HSA – Forms (AF1–AF4, GA1–GA3, IR1)
- HSA – Approved Form AF3: thorough examination of excavations
- HSA – Form GA3: scaffold inspection (with Regulation 119 text)
- HSA – Accident and dangerous occurrence reporting
- HSA – Construction FAQs: Safe Pass
- HSA – Create a construction stage Safety and Health Plan using BeSMART.ie
- HSA – Guide for Homeowners
- HSA – Review finds 83% of construction fatalities occurred on sites with four workers or fewer (20 October 2026)
- Workplace Relations Commission – Public holidays – St Brigid's Day: Monday 1 February 2027

