HSE Professional Guide · Safety and Health Coordination · Issue 5
The Construction Log – The BE Coordinator's Right and Obligation to Make Entries
Industry experience shows that a significant proportion of Safety and Health Coordinators do not know precisely when an entry in the Construction Log is mandatory and when it is merely recommended. This creates a two-sided risk: too few entries mean the coordinator cannot prove their actual activity in a regulatory or accident investigation, while excessive or improperly formatted entries can themselves become a legal vulnerability.
The Construction Log is the sole continuous, officially recognised record of a construction project, and its entries carry legal evidentiary weight.
The Statutory Basis for the Right of Entry
Act C of 2023 on Hungarian Architecture (Méptv.) and the associated implementing government decrees that came into force on 1 October 2024 – in particular Sections 31–39 of the amended Government Decree 191/2009. (IX.15.) (Construction Code) – govern the keeping of the Construction Log.
ℹ️ The BE Coordinator may make entries in three capacities
- Under their own right of entry – recording findings, instructions and measures taken in the course of coordination duties
- On behalf of the client – where expressly authorised by the client
- For informational purposes – recording HSE-related communications made to the authority, designer or other authorised person
Under Decree 4/2002. (II.20.) SzCsM-EüM, the duties of the BE Coordinator constitute occupational safety specialist activity. The coordinator is therefore entitled and obliged to record findings made in the course of their coordination duties under their own right of entry.
💡 Professional recommendation – not a statutory requirement
The applicable legislation does not expressly require that the BE Coordinator's professional qualification and verified experience be uploaded to the Construction Log. Nevertheless, it is strongly recommended good practice that, at the time of appointment, copies of the qualification and experience verification documents are also attached to the e-Construction Log as supporting documentation.
The advantage: in the event of a regulatory inspection or accident investigation, the lawfulness of the appointment can be proven immediately, in one place.
What Should Be Recorded?
⛔ Mandatory entries
- Work stoppage ordered due to immediate danger – under Section 82/A of the OHS Act
- Serious or fatal occupational accident – under Section 64 of the OHS Act and Section 33 of the Construction Code
- Regulatory inspection and its findings – under Section 33 of the Construction Code
- Amendment of the Safety and Health Plan – under Section 7 of Decree 4/2002.
- Discovery of hazardous substances (asbestos, contamination) during construction
⚠️ Strongly recommended entries
- Minor injury accidents and near-miss events – key evidence in regulatory proceedings
- Commencement and completion of hazardous work phases (Permit to Work) – work at height, confined space, fire-risk activities
- Identification of deficiencies and time-bound instructions to the contractor – constitutes a formal, binding notice
ℹ️ Recommended entries
- Confirmation that induction training has been delivered
- Recording of missing personal protective equipment
- Work stoppage due to weather conditions
When Does an Entry Carry Legal Evidentiary Weight?
An HSE-related Construction Log entry only carries legal evidentiary weight if:
- The exact date and time are recorded – hour and minute may be relevant (e.g. work stoppage)
- The name, role and signature of the person making the entry are clearly identified
- The wording is objective and fact-based – an observed fact, not an opinion
- The action taken and the expected response are precisely recorded
- Reference is made to the relevant legislation or internal safety requirement
In the electronic Construction Log (e-Log), entries are time-stamped and cannot be subsequently altered – this also protects the coordinator.
⛔ What the coordinator should never do in the Construction Log
- Never make subjective, evaluative or derogatory remarks about individuals
- Never record a fact not personally observed
- Never leave unrecorded an event that may have regulatory or legal consequences
- Never withdraw or alter a prior entry under pressure
- Never delay an entry – it must be recorded no later than the following day
Sound Documentation Protects the Client
ℹ️ Not directed against the client – it works in their favour
- The coordinator's independence and documented work do not signal distrust toward the client – they serve precisely to protect the client legally and financially in the event of an accident or regulatory proceeding
- Regulatory notification and work stoppage are the rarest, last-resort tools in the coordinator's toolkit – the vast majority of day-to-day work is prevention, cooperation and ongoing communication
- A coordinator who genuinely meets the statutory minimum and actively performs the role is the best insurance a project can have – not a risk factor
⚠️ The market reality – and why this matters for the profession as a whole
- In practice, a site supervisor or other party involved sometimes recommends an acquaintance for the coordinator role who does not meet the statutory requirements – the right and responsibility of appointment, however, always rests with the client. This may seem "simpler" in the short term, but exposes both parties to risk in the long term
- A professionally qualified, legally compliant coordinator is not an obstacle but an asset – the one who genuinely protects the project and the client in a regulatory inspection or accident investigation
- It is in the long-term interest of the profession that the coordinator role be filled by genuinely qualified, actively engaged professionals
"The Construction Log is not the coordinator's adversary – it is their best ally, and by extension the client's best ally too. Every properly documented entry simultaneously proves the coordinator's actual activity and protects the liability position of the entire project."
Statutory references
Act C of 2023 (Méptv.) · Government Decree 191/2009. (Construction Code, amended), Sections 31–39 · Decree 4/2002. (II.20.) SzCsM-EüM, Sections 7 and 14 · Act XCIII of 1993 (OHS Act), Sections 64 and 82/A