Here are the answers to some of the more frequently asked questions relating to construction and maintenance safety for the Housing Authority in Hong Kong.

1. What is the HA policy on subletting and subcontracting?

The HA has restrictions on subletting in new works contracts (as stipulated in Special Conditions of Contract). Contractors must ensure, and are responsible for, compliance with the limitation on the number of tiers of subletting. Contractors must also ensure that all their sub-contractors also comply with these limitations.

On all new works contracts, including demolition, piling, civil engineering, geotechnical engineering, building and associated building services nominated sub-contracts, contractors are prohibited from the following activities:

  • Subletting management/site supervision teams
  • Subletting to a single sub-contractor for the provision of labour and materials or labour only

Ground investigation and piling works must be executed by specialist subcontractors.

In the case of building contracts, subletting of specified trades is restricted to a maximum of two tiers* of sub-contractors for works, and subcontractors, as detailed in the categories below, must be registered under their respective trades in the Primary Register of the Voluntary Subcontractor Registration Scheme.

  • Scaffolding
  • Mechanical handling and lifting (tower cranes only)
  • Mechanical plant and equipment (tower cranes only)
  • Concreting and concreting formwork (large panel formwork and small panel metal formwork only)
  • Painting (external walls only)
  • Plumbing and drainage work (external walls only)

In the case of nominated subcontracts (refer to NS16 for details), no more than two tiers of subletting are permitted.

In the case of demolition contracts, only one tier of subcontracting is permitted, and not more than two tiers of sub-contracting are specified for any works involving scaffolding, mechanical handling and lifting (for tower cranes only) and mechanical plant and equipment.

In the case of civil and geotechnical engineering contracts, no more than two tiers of sub-letting are specified for any works involving scaffolding, demolition, mechanical handling and lifting and/or mechanical plant and equipment (for tower cranes only).

* Notes

  • For contracts other than nominated subcontracts, the first tier of subletting refers to the subcontract between the contractor and their subcontractor. The second tier of subletting refers to the subcontract between the first tier subcontractor and their subcontractor.
  • For nominated sub-contracts, the first tier of subletting refers to the subcontract between the subcontractor and his subcontractor. The second tier of subletting refers to the subcontract between the first tier subcontractor and their subcontractor.
2. What is the Silver Card Scheme?

The Silver Card Scheme is an accreditation system for workers of specific high risk trades who have satisfactorily completed advanced training courses on safety—geared to those specific high risk trade practices including:

  • Painters and decorators
  • Carpenters
  • Demolition workers (building)
  • Plumbers
  • Bar benders and fixers
  • Plasterers and tilers
  • Bamboo scaffolders and metal scaffolders
  • Construction material riggers
  • Curtain wall installers
  • Tower crane workers (erecting, dismantling, telescoping and climbing)
  • Lift mechanics and lift installation workers (installation and maintenance)
3. What is meant by ‘Pay for Safety’?

The amount of ‘Pay for Safety’ in new works contracts is calculated on a sliding scale with reference to the amount of the contract sum and a split ratio of 60:40 pertaining to safety and environment/hygiene aspects, respectively.

The ‘Pay for Safety’ scheme covers the following:

A. Resources

  • Safety officers

B. Management

  • Safety plans
  • Site safety committee
  • Safe Working Cycle

C. Key Performance Indicators

  • Regulatory compliance indicator
  • Safety audit performance indicator
  • Accident indicator

D. Awareness & Promotion

  • Induction training & toolbox talks
  • Silver Card compliance
  • Contribution to safety campaigns

E. Safety Innovations

  • Recognition of innovative and functional safety measures
  • Applicatino of BIM for safety
  • Application of RFID for safety

F. Surprise Safety Inspection performance indicator

G. Timely reporting accident indicator

4. Why has ‘Pay for Safety’ been extended to cover NSCs?

The ‘Pay for Safety’ scheme in HA new works building contracts has been extended to cover nominated subcontracts (NSCs) to help enhance site safety practices, promote site safety awareness, and provide an incentive to contractors who demonstrate good safety performance.

5. What are the high-risk items specified under the Housing Authority Safety Auditing System (HASAS)?

A detailed checklist of high-risk activities, introduced under the 2018 HASAS (can be downloaded here)

6. What is a ‘Critical Pass Alert’?

The ‘Critical Pass’ system was introduced Housing Authority Safety Auditing System (HASAS) for HA new works contracts in 2009 and stipulates minimum safety standards that contractors must meet when engaging in specified hazardous work scenarios. Critical Passes apply to: safety inspections; job hazard analysis; and high-risk sections including working at height, housekeeping, falling objects and lifting using tower crane. With effect from 1 January 2009, for all new and on-going contracts, if contractors fail to meet any Critical Pass, this will trigger a Critical Pass Alert to the respective Contract Manager. Likewise, failure to obtain any Critical Pass on a contract on two consecutive quarters will also trigger an alert to the respective Contractors Review Committee for review of concerned contractor’s safety performance.

7. What is the difference between safety audits and safety assessments under PASS?

For new works contracts, safety audits have to be conducted by appointed independent auditors every three months, under the management of the Occupational Safety and Health Council (OSHC). The scope of such audits includes both safety management systems as well as physical implementation. The audit concludes with a performance score which is linked to the Department’s ‘Pay for Safety’ Scheme (Integrated Pay for Safety, Environment and Hygiene Scheme) and the regulatory system of tendering.

To provide an effective and objective means of monitoring and benchmarking contractors’ performance in various aspects of site safety aside from safety audits, several site safety assessments have been implemented—under Performance Assessment Scoring System (PASS). These include: Performance Assessment Scoring System Building (PASS), Maintenance Assessment Scoring System (MASS), Property Services Performance Assessment System (PSPAS), Building Services Performance Assessment Scoring System (BSPASS) and Piling Performance Assessment Scoring System (Piling PASS) and Demolition Performance Assessment Scoring System (Demolition PASS).

After selecting suitable contractors or service providers for HA works contracts, their performance is monitored under the PASS framework to generate data that can be analysed and used to more effectively manage both HA contractors and service providers. Using this data, tender opportunities are allocated commensurate with the performance and ability of respective contractors and service providers.

All PASS assessments provide an objective basis to assess and monitor performance in areas ranging from project management, quality to safety. The PASS systems have proven highly effective in motivating our business partners climb the learning curve and enhance their overall work quality—especially with regard to site safety.

8. What is the Safe Working Cycle?

Safe Working Cycle (SWC) recognises the importance of frontline leaders ranging from project managers to gangers, who—via their leadership and communication—can effectively convey safety measures to frontline staff.

The SWC involves site personnel following a series of practical steps on daily, weekly and monthly cycles aimed at instilling habitual safety checks and raising safety awareness.

  • Daily cycle activities include morning assembly and exercise, risk identification activities, safety inspections, safety reviews, cleaning and tidying up after work.
  • Weekly cycle activities include safety inspections, training and safety meetings.
  • Monthly cycle activities include safety inspections, safety reviews and monthly cleaning.
9. What is 5S Housekeeping?

5S refers to a set of techniques providing a standard approach to housekeeping. It originated from Japan and the elements of 5S are all Japanese words beginning with the letter S. The system is founded upon the principle of promoting cleanliness and tidiness in the working environment to help enhance productivity. Cultivating the habit of maintaining a clean, tidy and well-organised workplace among employees also helps enhance the safety and healthiness of the working environment.

The 5 Ss are:

  1. Sort (Seiri): efficiency begins from the organisation of things.
  2. Set (Seiton): neat and well-organised storage systems help avoid wasting time in searching for items.
  3. Shine (Seiso): a cleaning culture helps ensure the workplace is kept in a clean, tidy and safe condition.
  4. Standardisation (Seiketsu): clean, and standardised working environments help employees to work safely and healthily.
  5. Sustain (Shitsuke): discipline is a precondition for cultivating an effective safety culture.
10. What is SSIP?

Surprise Safety Inspection Programme (SSIP) aims to raise vigilance and further enhance safety management through surprise site visits by independent Safety Inspectors, which is separated from surveillance safety audits under HASAS. SSI is conducted strictly WITHOUT prior notice to all parties. SSI would focus on high risk activities of sites to match the physical “Critical Pass” items in Part B of HASAS Version 1.5.1 or pertinent version, namely –
(a) Working at Height;
(b) Protection against Falling Objects;
(c) Housekeeping;
(d) Lifting Operation; and
(e) Electrical Supply System.