Site manager in a hard hat and hi-vis vest checks a small card held out by a worker on site

Safe Pass: What an Irish Site Employer Must Check Before Day One

Under the Construction Regulations the contractor must ensure every worker on site holds a valid Safe Pass, see it on their first day and confirm it in writing to the PSCS. Who needs a card and who doesn't, the narrow exemption, getting a first card, renewing by test, and what to record.

Safe Pass looks like the worker’s card, but in law it is your duty. The card itself is a safety awareness registration card run by SOLAS, the State agency for further education and training. Holding a valid one is a legal requirement for construction workers, not an optional course. The Safety, Health and Welfare at Work (Construction) Regulations 2013 put the obligation on the contractor: every person working under your direct control on a site must hold a valid Safe Pass. On each person’s first day, you must ask to see it and confirm it in writing to the project supervisor for the construction stage. A worker who turns up with an expired card is your problem that morning, not just theirs.

That holds whether you are a builder taking on a labourer, an electrical firm sending an apprentice or a groundworks crew bringing in a driver. Before that person’s first morning, you need to know whether they need a card, how they get or renew one, and what you check and record when they arrive.

What the regulations require of you

Regulation 25(1) applies to every contractor, or other person under whose direct control people work on a site. It says they “shall ensure” that each worker covered holds “a valid safety awareness registration card”. Since the 2019 amendment, that card is the SOLAS Safe Pass registration card, or an equivalent SOLAS has approved.

Regulation 25(2) then sets two steps for the day a worker first starts on a site:

  1. ask to see the worker’s valid registration card; and
  2. give the project supervisor for the construction stage (the PSCS) written confirmation that the worker has it.

Put simply, on the first morning someone starts with you on a site, you look at their card and you tell the PSCS in writing that you have. Under Regulation 19 the PSCS has its own duty to coordinate arrangements, so that everyone on site who needs a card has one. If a worker is slow to produce theirs, point out that workers must show their cards when asked, under Regulation 29. And if you are bringing in someone in a trade that needs a CSCS card, such as a scaffolder or plant operator, check for both cards. The two requirements sit side by side in Regulation 25.

Who needs a Safe Pass, and who doesn’t

The regulations apply the Safe Pass requirement to “craft and general construction workers” and to people doing on-site security work. SOLAS puts it more simply: “all construction workers in Ireland – including apprentices and trainees – are legally bound to hold a valid Safe Pass Registration Card.” Being self-employed does not change that; the test is the work, not the contract.

For the people who actually turn up on a site, the Health and Safety Authority’s Safe Pass FAQ gives a working list:

On site as Needs a Safe Pass?
Craft workers, general operatives, apprentices, working chargehands Yes
On-site security, contractors’ drivers on site, delivery drivers on site such as concrete trucks Yes
Students on placement on site Yes
Supervised visitors, canteen and site office staff No
Clients, architects, engineers, surveyors, the PSDP and PSCS No
Site managers and safety officers not involved in construction activities No

The HSA adds that a client, PSCS or contractor may require everyone entering their site to hold one anyway, so a “no” on the list does not guarantee access to someone else’s site. If you are sending someone onto a main contractor’s job, ask what that site requires before the day.

The one exemption, for visiting specialists

There is one narrow exemption, in Regulation 4(3), and it is aimed at visiting specialists, so it is unlikely to fit your own crew. It covers people who install, commission, maintain, repair or remove services such as mechanical, electrical, gas or computer systems, and all three conditions must be met. The person must normally live and work outside the State. They must have worked on the project for no more than 20 working days in any 12 months. And they must carry a letter from their employer describing the work, their competence and the dates. If you are relying on the exemption, see that letter before they go on site.

Group of construction workers listen to a safety instructor standing by a flip chart in a training room
A first Safe Pass means the one-day classroom course. You can renew by computer-based test instead.

Getting a first card

For a labourer or apprentice who has never held a card, a first Safe Pass means the one-day health and safety awareness programme, delivered by SOLAS-approved training organisations and tutors. You can check a tutor is approved on constructioncourses.ie. SOLAS says the card is issued to the tutor about five working days after they upload the trainee’s details, so build the course day and that wait into the start date you give a new starter. SOLAS does not publish a set course fee; the tutor charges it.

On who pays, SOLAS says that “generally, your employer pays”. Employers must also allow paid time off for safety awareness training. The HSA adds that a student looking for seasonal site work would have to pay before being hired. The card lasts four years from the date of the course.

Renewing, replacing and checking dates

Anyone who has held a Safe Pass can renew by a computer-based test at a Pearson VUE centre, so renewing does not have to mean repeating the classroom day. It does still mean booking a test, which is why someone has to spot the date in time. The SOLAS renewal FAQs set out the details. The test costs €93.84, including the card. It is 50 multiple-choice questions in 45 minutes, and 45 correct answers pass. The FAQs say you can still renew a card this way after it has expired. Candidates book through a SOLAS online account and bring a passport, driving licence or Public Services Card. The constructioncourses.ie site says you need a verified MyGovID account to use all its services, and that account needs a Public Services Card and a verified phone number.

A lost or damaged card that is still in date can be replaced for €32, with the same expiry date. You cannot replace an expired card; you have to renew it.

For you, the practical risk is the expiry date. A card that ran out last month does not satisfy Regulation 25. A worker renewing by test also needs time to book. At induction, check the date on the card, not just the card, and diary the expiry for anyone staying on the job past it.

Where this sits in taking someone on

Safe Pass is one line in the start-of-job paperwork, beside the payroll and insurance decisions. The article on what a first hire really costs covers the payroll side. The article on contractor insurance in Ireland covers the employers’ liability cover a main contractor may ask you for before you start.

As for the Regulation 25 check, it takes a minute. Look at the card on the first morning and note the name and expiry date. Send the written confirmation to the PSCS the same day. Keep a copy with the job, and look again before the card runs out. Failing to do it is an offence under the Safety, Health and Welfare at Work Act 2005. The failure is the contractor’s, not only the worker’s.

ON THE CARD CHECK AT THE GATE

A Safe Pass card only counts on site until its expiry date.

The check takes a minute; remembering when each card runs out is the hard part. SendWork keeps crew assignments, job records and reminders together, so a card’s expiry can sit on the worker’s record and come up before the job needs them.

See how Irish contractors keep crew records on the job →