CCNZ made a submission on the Health and Safety at Work Amendment Bill, following input from members.

The submission was followed by a verbal presentation to Parliamentary Select Committee on 25 March, presented by CCNZ Communications and Advocacy Manager Fraser May, alongside Hugh Goddard of CCNZ member Pipeline & Civil. Watch the presentation>>

CCNZ submitted on the following points:
1. Clarity and Workability: The Bill’s proposed definitions, new thresholds (“critical risk”), and small business carve-outs introduce ambiguity, particularly for multi-PCBU (Person Conducting a Business or Undertaking) sites and fluctuating workforces. We are concerned about these ambiguities, and request the points raised in our detailed submission below be noted and addressed.

2. Critical Risk Focus: Sharpening the system’s focus on genuinely life-threatening risks is welcome, but in refocussing the system, we must not dilute broader duties or create perverse incentives to under-address chronic, cumulative, or psychosocial risks, all of which can be debilitating for people working in the industry.

3. Multi-PCBU Sites: The Bill must provide practical frameworks for managing overlapping duties, avoiding excessive risk transfer down the supply chain (to subcontractors and SMEs), and ensuring clients (upstream PCBUs) are held accountable for safety environments. This is a key submission point.

4. Regulatory Consistency and Guidance: Amendments must be accompanied by robust, industry-developed Approved Codes of Practice (ACOPs) and clear, accessible WorkSafe guidance tailored to horizontal construction.

5. Role of WorkSafe and other regulators: CCNZ supports the shift in role for WorkSafe, to better connect with industry best practice and support good health and safety practices rather than take a prosecution-first approach where clear standards are not in place. However, adequate resourcing will be needed if WorkSafe is to fulfil its expected functions under the new legislation and foster better understanding of what is ‘reasonably practicable’.

6. Compliance Burden: Further measures are required to address prequalification (which is used in procurement by clients to ensure contractors have effectivesystems in place for managing health and safety risk on construction work sites), duplication, administrative inefficiency, and the risk of compliance burden shifting down the supply chain, from project initiators to large contractors to SMEs.

7. Transition and Implementation: Practical, well-resourced sector guidance and transition periods are essential to manage legislative change, particularly to avoid project delays or confusion on urgent and safety-sensitive projects.

Read the full submission>>