Health & Safety Policy

1.0 Policy Statement

C Wray Ltd is committed to ensuring the health, safety and welfare of all individuals associated with our operations, including contractors, clients, and members of the public affected by our work.

As a labour supply agency operating within the UK construction industry, C Wray Ltd recognises its responsibilities under the Health and Safety at Work etc. Act 1974 and all relevant statutory provisions.

Our company provides access to skilled, self-employed tradespeople who are deployed to client worksites. Although the day-to-day control of site activities remains with the client or principal contractor, C Wray Ltd is committed to ensuring that workers introduced through our network are competent, qualified and aware of their health and safety responsibilities.

C Wray Ltd will:

  • Ensure all tradespeople supplied to clients hold appropriate qualifications and certifications such as CSCS, ECS, Gas Safe, or equivalent industry certification where applicable

  • Verify that contractors have appropriate insurance and legal registration (CIS where relevant)

  • Promote a culture of safety awareness across our workforce network

  • Ensure contractors understand their obligation to follow the site-specific health and safety rules of the client

  • Seek external professional advice where required to maintain compliance with evolving legislation

  • Periodically review this policy to ensure its continued effectiveness

Overall responsibility for this policy rests with the Director of C Wray Ltd.

This policy will be reviewed annually or following any significant operational change.

2.0 Organisation and Managerial Responsibilities

Company Director

The Director of C Wray Ltd has ultimate responsibility for health and safety policy implementation.

Responsibilities include:

  • Ensuring compliance with health and safety legislation

  • Implementing safety policies and procedures

  • Ensuring supplied contractors are appropriately vetted

  • Ensuring adequate insurance cover is maintained

  • Reviewing accident reports and safety incidents

  • Liaising with clients regarding safety requirements

Administrative / Operational Responsibility

The operational management of workforce allocation includes:

  • Confirming that contractors possess valid qualifications

  • Ensuring contractors understand client site rules

  • Maintaining records of contractor certifications

  • Responding to safety concerns raised by workers or clients

Client Responsibilities

Where C Wray Ltd supplies labour to construction sites:

  • The principal contractor or client retains responsibility for site safety

  • The client is responsible for:

    • Risk assessments

    • Method statements

    • Site supervision

    • Site-specific PPE requirements

    • Toolbox talks

    • Equipment safety

C Wray Ltd operates as a labour introduction agency, therefore day-to-day operational control remains with the site management team.

3.0 Contractor Responsibilities

All tradespeople introduced through C Wray Ltd must:

Take reasonable care for their own safety

Workers must ensure that their conduct does not endanger themselves or others.

Follow site safety procedures

Contractors must comply with all rules set by the client or principal contractor.

Use equipment correctly

Tools and equipment must be used safely and only for their intended purpose.

Wear appropriate PPE

Where required by site conditions.

Typical PPE may include:

  • Hard hats

  • High visibility clothing

  • Safety footwear

  • Gloves

  • Eye protection

  • Hearing protection

Maintain clean working areas

Contractors must ensure safe housekeeping standards are maintained.

Report incidents

Any accident, injury, near miss or unsafe condition must be reported to:

  • Site management

  • C Wray Ltd where appropriate

Participate in safety training

Workers must cooperate with site inductions, toolbox talks and training.

4.0 Staff Consultation

C Wray Ltd encourages open communication regarding health and safety.

Workers supplied through our network are encouraged to report:

  • Unsafe work conditions

  • Unsafe behaviour

  • Faulty equipment

  • Potential hazards

This feedback helps improve safety standards across projects.

Contractors may communicate concerns directly to:

  • Site management

  • C Wray Ltd management

5.0 Safety Functions and Responsible Persons

Risk Assessments

Site risk assessments are generally the responsibility of the principal contractor or client.

C Wray Ltd ensures contractors are capable of working safely within these environments.

Qualification Verification

C Wray Ltd verifies worker credentials including:

  • CSCS cards

  • ECS cards

  • Relevant NVQs

  • Insurance documentation

  • Relevant trade certifications

This process helps ensure only competent workers are supplied to sites.

Accident Reporting

Where accidents occur:

  1. Immediate reporting must be made to site management.

  2. The site accident reporting procedure must be followed.

  3. If relevant, C Wray Ltd will record the incident for internal monitoring.

First Aid

Provision of first aid equipment and trained personnel is the responsibility of the client site management team.

6.0 Arrangements for Carrying Out Duties

C Wray Ltd promotes safe working practices through the following arrangements.

Worker Vetting

Tradespeople must provide proof of:

  • Trade qualifications

  • Safety certification

  • Relevant insurance where applicable

Site Inductions

All workers must complete site induction procedures before commencing work.

Working at Height

Workers must comply with the Work at Height Regulations 2005 where applicable.

Manual Handling

Workers must follow safe lifting techniques and site guidance.

Electrical Work

Electrical work must only be carried out by qualified electricians with appropriate certification.

Equipment Safety

All plant, tools and equipment must be:

  • Suitable for the task

  • Properly maintained

  • Used by competent personnel

Serious and Imminent Danger

Workers must:

  • Stop work immediately if serious hazards are identified

  • Notify site supervisors

7.0 Specific Risk Areas

Construction Site Safety

Contractors must comply with the Construction (Design and Management) Regulations 2015 (CDM).

Young Workers

Where young workers are present:

  • Additional supervision may be required

  • Risk assessments must consider inexperience

Fire Safety

Workers must:

  • Follow site fire evacuation procedures

  • Maintain clear access to exits

  • Report fire hazards immediately

Transport Safety

Workers must follow safe vehicle and site traffic procedures.

8.0 Accident Investigation

Where incidents occur:

  • Site management will investigate the incident

  • Findings may be reviewed by C Wray Ltd

  • Lessons learned will be used to improve procedures

Where required, incidents will be reported in accordance with RIDDOR regulations.

9.0 Arrangements for Discharging Contractor Duties under CDM 2015

In accordance with Regulation 15 of the CDM 2015 Regulations, C Wray Ltd has established the following procedures to ensure all statutory duties as a Contractor are discharged effectively:

9.1 Verification of Capability and Resources

Before accepting any contract, the Director will ensure that C Wray Ltd has the necessary skills, knowledge, and experience to fulfil the role. We will only provide labour that has been vetted for:

  • Technical Competence: Valid CSCS/ECS/Gas Safe cards and trade-specific NVQs (pp. 1, 6).

  • Health and Safety Awareness: Ensuring workers have received basic health and safety training relevant to their trade (p. 1).

9.2 Cooperation and Coordination

C Wray Ltd is committed to proactive cooperation with the Principal Contractor (PC) and other contractors on-site (p. 3). Our procedures include:

  • Information Sharing: Providing the PC with all necessary worker compliance documentation before they arrive on-site.

  • Compliance with Site Rules: Mandatory requirement for all supplied workers to follow the PC’s Construction Phase Plan (CPP) and site-specific rules (p. 3).

  • Reporting: Ensuring a clear line of communication between our workers, the site management, and C Wray Ltd management regarding any site hazards (pp. 4-5).

9.3 Provision of Information and Inductions

We ensure that no worker begins work on-site until they have:

  • Received a full Site Induction from the Principal Contractor (p. 7).

  • Been briefed on the relevant Risk Assessments (RA) and Method Statements (RAMS) for their specific tasks (pp. 3, 5).

  • Been informed of the emergency procedures, including fire safety and first aid arrangements (pp. 6, 8).

9.4 Supervision and Monitoring

While day-to-day site supervision is provided by the client, C Wray Ltd maintains a monitoring role by:

  • Regularly checking that workers are following the agreed-upon safe systems of work (p. 2).

  • Reviewing any site-based accident or "near miss" reports involving our personnel to identify if additional training or a change in vetting procedures is required (pp. 2, 9).

9.5 Workforce Engagement

We promote a two-way dialogue where workers are encouraged to report any concerns regarding site safety or inadequate welfare facilities directly to C Wray Ltd, ensuring we can escalate these issues to the Principal Contractor for resolution (p. 5).

11.0 Alcohol and Drug Policy

11.1 Policy Statement

C Wray Ltd is committed to providing a safe and productive work environment. The use of alcohol and drugs can impair performance, increase the risk of accidents, and jeopardise the safety of contractors, clients, and the public. We maintain a zero-tolerance approach toward being under the influence of illegal drugs or alcohol while at work.

11.2 Prohibitions

All contractors introduced through C Wray Ltd are strictly prohibited from:

Reporting for work, or attempting to work, while unfit due to alcohol or drugs.

Possessing, using, or distributing illegal drugs or alcohol on any client worksite.

Consuming alcohol during working hours, including during breaks.

11.3 Prescription and Over-the-Counter Medication

Workers must notify the site management if they are taking any prescribed or over-the-counter medication that may cause side effects (such as drowsiness) affecting their ability to work safely. It is the worker’s responsibility to check with a pharmacist or doctor regarding potential side effects.

11.4 Testing and Compliance

As a labour supply agency, C Wray Ltd supports the testing policies of our clients and principal contractors.

Site Testing: Workers must cooperate with any "for cause," "random," or "post-incident" drug and alcohol testing conducted by the client or site management.

Consequences of Failure: Any worker who tests positive, refuses a test, or is found to be in breach of this policy will be immediately removed from the site. This may result in the termination of their engagement with C Wray Ltd.

11.5 Reporting Concerns

We encourage a culture of safety. If a worker suspects a colleague is under the influence of drugs or alcohol, they should report it immediately to site management or C Wray Ltd to prevent potential incidents.

12.0 Occupational Health and Wellbeing

12.1 Policy Statement

C Wray Ltd recognizes that occupational health is as important as safety. We are committed to identifying and minimizing health risks associated with our operations, including physical health, mental wellbeing, and the management of fatigue.

12.2 Physical Occupational Health

We ensure that workers are matched to roles they are physically capable of performing. Our vetting process includes:

  • Health Surveillance: Clients and Principal Contractors (PCs) are responsible for site-specific health surveillance (e.g., hearing tests, lung function). C Wray Ltd will cooperate with PCs to ensure workers participate in these programmes where required.

  • Manual Handling: All workers must follow safe lifting techniques. We encourage the use of mechanical aids to reduce the risk of musculoskeletal disorders (MSDs).

  • Hazardous Substances (COSHH): Workers must follow all site-specific COSHH assessments and wear appropriate PPE (e.g., respiratory protection) provided or mandated by the client.

12.3 Fatigue Management

Fatigue is a significant risk in the construction industry. C Wray Ltd manages this by:

  • Monitoring Working Hours: We monitor the hours worked by our contractors to ensure they do not exceed legal limits (Working Time Regulations) and have adequate rest periods between shifts.

  • Commuting Safety: We encourage workers to consider their travel time to and from sites to ensure they are not arriving at work already fatigued.

  • Reporting: Workers are instructed to report to site management or C Wray Ltd if they feel their performance is impaired by fatigue, allowing for a temporary reassignment or rest period.

12.4 Mental Health and Wellbeing

C Wray Ltd is committed to reducing the stigma around mental health in construction. We promote a supportive culture by:

  • Open Communication: Encouraging workers to discuss any mental health concerns with management in confidence.

  • Work-Related Stress: We aim to identify and reduce work-related stress by ensuring workers are not given unrealistic deadlines or tasks beyond their competency.

  • Support Resources: We signpost our workforce to industry-specific support services, such as the Lighthouse Construction Industry Charity, for professional mental health support.

12.5 Fitness for Work

All contractors have a personal responsibility to ensure they are fit for work. If a worker’s health (physical or mental) changes in a way that could affect their safety or the safety of others, they must notify C Wray Ltd immediately so that a review of their placement can be conducted.

13.0 Behavioural Safety Management Programme

13.1 Policy Statement

C Wray Ltd believes that most site incidents are preventable and are often linked to individual behaviour and safety culture. Our "Safe Conduct" programme focuses on ensuring that all tradespeople introduced through our network adopt a proactive, "safety-first" mindset, regardless of the specific site they are working on.

13.2 Core Safety Behaviours

All contractors supplied by C Wray Ltd are expected to adhere to the following behavioural standards:

  • The Right to Stop Work: Every worker has the absolute authority and responsibility to stop work if they believe a task is unsafe or if they lack the correct equipment/training.

  • Intervention: Workers are encouraged to politely intervene if they see a colleague acting unsafely, regardless of that person's rank or trade.

  • Compliance over Convenience: We strictly prohibit "shortcuts." Safety procedures must be followed even if they take longer than an unsafe alternative.

13.3 Monitoring and Observation

As a labour provider, C Wray Ltd monitors behavioural safety through:

  • Client Feedback Loops: We regularly request feedback from Site Managers specifically regarding the safety attitude and "housekeeping" habits of our supplied workers.

  • Site Visit Observations: During any periodic site visits by C Wray Ltd management, we observe worker behaviour (e.g., correct use of PPE, exclusion zone compliance) to ensure it aligns with our standards.

  • Reporting "Near Misses": We treat "near misses" as a positive learning tool. Workers are encouraged to report these without fear of blame, as they provide vital data to prevent future accidents.

13.4 Incentive and Disciplinary Arrangements

  • Positive Reinforcement: Workers who consistently demonstrate high safety standards and proactive reporting will be prioritised for future high-profile or long-term contracts.

  • Behavioural Correction: If a worker is found to be acting unsafely (e.g., failing to wear PPE, ignoring site rules), C Wray Ltd will implement a "Refresher Briefing."

  • Zero Tolerance: Serious or repeated behavioural breaches, such as bypassing safety interlocks or working under the influence, will result in immediate removal from the site and a permanent review of their engagement with C Wray Ltd.

13.5 Continuous Improvement

C Wray Ltd reviews all safety incidents and feedback to identify "behavioural trends." If a specific trade or group shows a recurring safety issue, we will update our vetting and induction briefings to address that specific behaviour before future deployments.

14.0 Conclusion

C Wray Ltd is committed to maintaining high health and safety standards across all projects and partnerships.

By supplying competent tradespeople and promoting responsible safety practices, we aim to contribute positively to safe construction environments.

Health and safety is a shared responsibility between:

  • C Wray Ltd

  • The client or principal contractor

  • Individual contractors

This policy will be reviewed regularly to ensure it remains effective and compliant with UK legislation.

Signed

Director
C Wray Ltd

Date: 13/3/26