Codes referenced
HIRA, BBS, operational controls, audit, top-management review.
Registration, hours, safety committees, welfare cess (1% of construction cost).
Safety officers, accident reporting, health & welfare provisions.
Companion national codes for specific hazards (height, fire, electrical).
The five common construction-site hazards and the hierarchy of control
| Hazard | Severity | Hierarchy of control |
|---|---|---|
| Working at height (> 1.8 m fall) | Fatal | Edge protection & guard rails (engineering) + 100% tie-off (admin) + harness (PPE) |
| Lifting operations (crane / hoist) | Fatal | Lift plan (admin) + trained rigger + banksman (PPE) + exclusion zone (engineering) |
| Electrical contact (live wiring) | Fatal | Lockout/tagout (admin) + insulated tools + ELCB (engineering) + insulated PPE |
| Manual handling (rebar, cement bags) | Sprain, fracture | Mechanical aids (engineering) + team lift (admin) + back belt (PPE) |
| Chemical exposure (admixtures, cement) | Burns, dermatitis | Substitution (low-alkali cement) + PPE (gloves, goggles, mask) |
Reference: ISO 45001:2018 Cl 6.1.2 (HIRA) + Cl 6.1.4 (hierarchy of controls: elimination → substitution → engineering → administrative → PPE).
Worked example — HIRA score for working-at-height
| Activity | Severity (S) | Likelihood (L) | Exposure (E) | S × L × E |
|---|---|---|---|---|
| Edge unprotected, harness available | 5 | 3 | 5 (daily) | 75 |
| Edge protected, harness untied | 5 | 2 | 5 | 50 |
| Edge protected, 100% tie-off, BBS daily | 5 | 1 | 5 | 25 — residual risk |
| Edge protected, harness NOT provided | 5 | 4 | 5 | 100 — STOP-WORK |
Reading: Without engineering control (edge protection) the score is 75-100 — the activity must not proceed (STOP-WORK per ISO 45001 Cl 8.1.2). With edge protection + 100% tie-off + daily BBS, residual risk is 25 — administrative and PPE controls reduce severity/likelihood sufficiently for the activity to proceed under audit.
Common deviations seen on Indian sites
Without a HIRA record, no activity should start. ISO 45001 Cl 6.1.2 requires risk identification before work begins.
Any project with 10+ construction workers must register under BOCW Act and pay 1% cess. Audit finding if missing.
Daily BBS is the cheapest intervention. Skipping it removes the audit trail of safety communication.
ISO 45001 Cl 10.2 + Indian Factories Act require investigation of incidents. Forms filled and filed is not investigation.
Field-checklist blocks
A short questionnaire, an inspector's checklist, and three worked examples that show how a HIRA score is read at the pre-task briefing and what it takes to move an activity from stop-work to a residual risk the site can work under.
Questionnaire — ask at the pre-task briefing, before the activity starts
- Is there a HIRA record for this activity, per ISO 45001:2018 Cl 6.1.2, scored severity × likelihood × exposure with each factor on the 1-5 scale, dated before the work began rather than written up after it?
- What is the score with the controls that are actually in place this morning, not the score on the sheet from last month?
- Are the controls applied in hierarchy order: elimination, then substitution, then engineering, then administrative, then PPE? A PPE-only answer to a working-at-height hazard is not an answer.
- At height, is the edge protected, and is the tie-off 100% for everyone exposed above the 1.8 m fall height?
- Is the harness at the point of work for every exposed person, and not sitting in the store with two missing from the rack?
- Is the daily BBS card being filled for this crew today, with the date, the observations and the supervisor's signature on it?
- Is there a rescue plan for the work at height, with the rescue equipment on site and not on a vehicle three kilometres away?
- With 10 or more construction workers on site, is BOCW registration in place and is the 1% cess being paid?
Inspector's checklist — what to verify on site
- HIRA sheet for the activity: severity, likelihood and exposure each on 1-5, the product S × L × E written out, the control at each level of the hierarchy, and the residual score.
- Stop-work record: any activity at 100 (edge protected, harness not provided) is stopped, with the score re-worked once the control is supplied and the resumption authorised by name.
- Daily BBS card: date, activity, crew, observations, corrective action and signature, filed for the month rather than for the day.
- PPE issue register: harness, lanyard, gloves, goggles and mask against the exposure identified in the HIRA, with the issue signed for.
- Height work check: edge protection and guard rails in place, 100% tie-off verified at the anchorage, rescue plan and rescue equipment on site.
- Controls for the other four hazards: lift plan, trained rigger, banksman and exclusion zone for lifting; lockout/tagout, insulated tools and ELCB for electrical; mechanical aids and team lift for manual handling; low-alkali cement substitution and PPE for chemical exposure.
- BOCW file: registration certificate, the current worker count against the 10+ threshold, and the cess paid at 1% of the construction cost.
- Incident file: an investigation record with cause and corrective action for every incident, not a filled form. Forms filled and filed is not investigation.
What happens if… three worked examples
What happens. The activity scores severity 5 × likelihood 3 × exposure 5 = 75. Severity stays at 5 because a fall from that height is fatal, and exposure stays at 5 because the work happens every day. Put in edge protection, 100% tie-off and a daily BBS and the same activity scores 5 × 1 × 5 = 25, the residual risk. The score has come down by two-thirds, and every point of that came out of the likelihood factor.
Likely outcome. At 75 the activity does not start until the edge is protected, and the harness is not the answer because PPE is the last rung of the hierarchy. At 25 the work proceeds under audit. Note what the arithmetic says: on a daily activity you cannot lower exposure, so the only lever you have is likelihood, and likelihood is moved by engineering control and administrative discipline, not by issuing a harness.
Preventive correction. Re-score the activity whenever a control changes or goes missing. A HIRA score written once and never revisited is a record of what was true on the day it was signed.
What happens. The activity scores severity 5 × likelihood 4 × exposure 5 = 100. That is a STOP-WORK score under ISO 45001 Cl 8.1.2, and the work stops. The uncomfortable part is the comparison with the previous example: at 75 the crew at least had a harness available, so removing the PPE has moved the score from 75 to 100, a 25-point increase, with no change at all to the edge protection.
Likely outcome. The harness is issued, the activity is re-scored with the control that is actually in place, and work resumes on the re-scored number. The HIRA record is not the obstacle here, it is the thing that caught it. A 100 sitting in a file that nobody re-read before the crew went up is not paperwork, it is an exposure.
Preventive correction. Tie the PPE issue register to the HIRA row for the activity, so a missing harness shows up as a missing control on the day it goes missing.
What happens. The residual score of 25 in the HIRA is earned by edge protection, 100% tie-off and daily BBS together. Stop the BBS and the likelihood of 1 is no longer earned, so the activity has drifted back towards the "edge protected, harness untied" row at 5 × 2 × 5 = 50, while the sheet on site still says 25. Skipping the daily BBS also removes the audit trail of safety communication, which is the record that the conversation happened.
Likely outcome. Nothing on the paperwork changes, and that is the problem. A paper score that the site has stopped earning is worse than no score, because the audit will read it as evidence. The corrective action is to restart the daily card, not to re-score the sheet to look better.
Preventive correction. The daily BBS is the cheapest single safety intervention on the site and the only record that safety communication actually took place. Protect it in the plan the way you protect the edge protection.
Frequently Asked Questions
What is HIRA in ISO 45001?
Does ISO 45001 replace India's BOCW Act?
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Amit Haridas
Founder & Proprietor, ConcreteInfo. 25+ years experience in construction QA/QC, concrete technology, RMC plant operations, consulting and technical training across India. ISO Lead Auditor. For an ISO 45001 readiness review or BOCW compliance check, contact amit@concreteinfo.in.
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