HSE Professional Guide · Safety & Health Coordination · Issue 3
Who Can Be Appointed as Safety and Health Coordinator on a Construction Site?
Industry experience shows that a significant proportion of appointed Safety and Health Coordinators on construction projects do not meet the applicable statutory requirements. In most cases this is not a deliberate breach – it stems from a lack of awareness that Decree 4/2002. sets out three separate, concurrently mandatory requirements.
If any one of these is missing, the appointment is legally invalid. The County Government Office's Occupational Safety and Labour Inspectorate will identify the deficiency on inspection and require remediation – repeated non-compliance may result in a fine. In the event of a serious or fatal occupational accident, the client bears direct personal liability.
The Three-Part Requirement – Exactly as the Legislation States
Section 2 of Decree 4/2002. defines the Safety and Health Coordinator as a person holding concurrently: a professional qualification in occupational safety, at least a secondary-level technical or construction qualification, and three years of verified construction industry experience.
Occupational safety qualification
A state-recognised qualification is required – occupational safety engineering degree (postgraduate), occupational safety specialist (higher education), or occupational safety technician / officer (secondary level). Under Section 82 of the OHS Act, no other technical degree satisfies this requirement.
Secondary-level technical or construction qualification
An independent, mandatory requirement – cannot be substituted by the occupational safety qualification. Accepted qualifications include construction engineer, architect, construction technician. Economics or management degrees are not accepted.
3 years of verified construction experience
The Decree does not prescribe the method of verification – any reliable document is acceptable (employer's certificate, employment contract, social security record, or for self-employed: contracts and invoices). The three years need not be continuous. Office-based or design roles are not sufficient.
⚠️ Key rule
- Occupational safety qualification without technical qualification and experience → invalid
- Technical qualification without occupational safety qualification → invalid
- Both qualifications present but 3 years' verified field experience missing → invalid
The Most Common Errors
The client appoints the site manager or construction manager as coordinator. The coordinator's role is to independently inspect the work directed by the site manager. If the same person holds both roles, this oversight function is lost. The primary disqualifying reason is typically the absence of the required occupational safety qualification.
Engineering degree only, without occupational safety qualification. Under Section 82 of the OHS Act, occupational safety specialist activities may only be performed by a person holding an occupational safety qualification.
Both qualifications present but no verified 3-year field experience. Section 2 of the Decree requires all three requirements to be met concurrently.
Appointed on paper but not actively performing the role. The Inspectorate examines actual, documented coordinator activity. The appointment document alone does not protect the client.
Appointment covers only the design phase. Under Section 3(1)–(2), a coordinator must be in place in both phases.
How to Make a Legally Compliant Appointment
Needs assessment – determine the required experience level based on the project's scale and risk
Pre-screening – request certified copies of both qualifications
Experience verification – request reliable documentation; together reaching 3 years
Written appointment – set out scope of authority, attendance level and responsibilities
Project induction – provide design documentation, permits and known risk information
Ongoing documentation – ensure on-site inspections are recorded in the Construction Log
A coordinator appointment is not a one-off administrative act. It is the responsibility of the client organisation to ensure the coordinator can genuinely perform the role.
Summary – Three Questions to Ask
Does the candidate hold a state-recognised occupational safety qualification (OHS Act, Section 82)?
Do they hold at least a secondary-level technical or construction industry qualification?
Can they demonstrate 3 years of verified, documented on-site construction industry experience?
If the answer to any of these is no, the appointment does not comply with Decree 4/2002. The solution is not supplementary paperwork – it is finding the right person.
Statutory references
Decree 4/2002. (II.20.) SzCsM-EüM · Act XCIII of 1993 (OHS Act), Section 82 · Directive 92/57/EEC · Government Decree 191/2009. · Government Decree 320/2014.