How to Check a Worker Holds the Right Ticket for the Task, Not Just a CSCS Card

2026-10-19

Check the task, not the person. Before anyone starts a piece of work, list what that specific task needs (for example a PASMA or IPAF certificate, an approved method statement and a site induction), then confirm the worker holds each one, in date, and reviewed, rather than relying on the CSCS card shown at the gate. A CSCS card tells you someone has the training for their occupation. It does not tell you they are competent for the task you are about to give them.

In short

• CSCS itself says holding a card is not a legal requirement, and that competence also includes experience and behaviours which employers and contractors must assess.
• The legal duty is task-based: under CDM 2015 a contractor must not appoint anyone to work on site unless they have the skills, knowledge, training and experience for the tasks allocated to them.
• Some tasks carry their own legal competence duty, such as work at height and the use of work equipment.
• The practical fix is a task requirement list: each type of work states the tickets and documents it needs, and the check runs when the work is allocated, not only when someone arrives.

Why isn't a CSCS card enough?

Because it answers a different question. The CSCS FAQ is direct about this. Holding a CSCS card is not a legal requirement, and it is the principal contractor's responsibility to control access to the site. A card shows that the holder has obtained the qualifications and training for their occupation. CSCS adds that competence also includes experience and behaviours, which must be assessed by employers and contractors.

So a valid card at the turnstile tells you the person is, say, a qualified labourer or a skilled operative in a trade. It does not tell you whether they can erect a mobile tower, drive a telehandler, use a disc cutter or work inside a confined space next week. Those are questions about the task.

What does the law actually require?

The core duty for construction is in the Construction (Design and Management) Regulations 2015. Regulation 15(7) says a contractor must not employ or appoint a person to work on a construction site unless that person has, or is in the process of obtaining, the necessary skills, knowledge, training and experience to carry out the tasks allocated to them in a manner that secures health and safety.

Three things in that sentence matter in practice:

• "Tasks allocated": the test is the work the person is given, so it changes when the work changes.
• "Skills, knowledge, training and experience": a training certificate covers only part of it.
• "In the process of obtaining": trainees can work, but only on that basis, which in practice means under suitable supervision.

Regulation 8 adds that anyone who appoints a contractor must take reasonable steps to satisfy themselves that the contractor has the skills, knowledge, experience and organisational capability to do the work. Regulation 15(9) also requires every worker to receive a suitable site induction.

Some activities have their own regulations on top:

• Work at height. Regulation 5 of the Work at Height Regulations 2005 says no person may engage in any activity in relation to work at height, including organising, planning and supervising it, unless they are competent to do so or are being trained under the supervision of a competent person.
• Work equipment. Regulation 9 of PUWER 1998 requires everyone who uses work equipment, and anyone who supervises or manages its use, to have received adequate training, including the methods to be used and the risks involved.

None of these says "hold a card". All of them say, in different words, "be competent for this job".

How do you check competence for a specific task?

A practical method that works on most sites is a task requirement list. You define it once per type of work, and then every allocation is checked against it.

1. List the types of work your sites actually do. For example: mobile tower erection, MEWP operation, hot work, excavation over 1.2 metres, temporary works installation, roof work, confined space entry, abrasive wheels, plant operation.
2. For each one, write down what a person must hold. A ticket or certificate, plus any documents such as an approved method statement or a specific induction.
3. Say where each requirement comes from. The law, an industry scheme, a client requirement or your own company policy. This tells your team which requirements can never be waived and which can be overridden with a reason.
4. Decide what happens if it's missing. Either it blocks the allocation outright, or it warns and needs a named person to accept it with a written reason.
5. Run the check when work is allocated, not only at the gate. The gate check confirms the person is cleared to be on site. The task check confirms they can do this job today.
6. Re-run it when anything expires or changes. A certificate that runs out next Tuesday should flag every task booked after that date, not wait until the day.
7. Keep the record. Who was allocated, what was checked, what was missing and who accepted any override, with the date.

An example task requirement list

The table below is an illustrative template, not a statement of what the law requires for each task. The "legal basis" column names the regulation that sets the competence duty. The specific card or course is usually an industry scheme or your own policy, and you should set those to match your contracts and risk assessments.

Where do most sites go wrong?

The gaps tend to sit between the gate check and the work itself:

• The card is checked once, at induction, and never again. By the time the person is moved onto a different activity, nobody looks at whether they hold the right ticket for it.
• Tickets are photographed but not reviewed. An image in a folder is not evidence that anyone looked at the expiry date or the category.
• Expiry is noticed on the day. A ticket that lapses mid-programme should flag the tasks booked after its expiry date well before they start.
• Supervisors aren't checked. The work at height and PUWER duties extend to people who plan and supervise, not just the operatives.
• Overrides aren't recorded. Sometimes a manager will accept a gap for good reason. Without a name and a reason written down, that decision can't be defended later.

Where DocCompliance fits

DocCompliance turns the task requirement list into a check that runs on its own:

• Each type of work lists the tickets it needs, each marked as law, industry scheme or your own policy, and set to warn or block.
• When a crew is booked on upcoming work, anyone who isn't cleared, or doesn't hold the ticket the work needs, is flagged before the day. A permit won't issue to a holder who isn't cleared, and the screen says why.
• Only documents a person has reviewed count towards a worker being cleared, and expiring documents are chased automatically.
• An override needs a name and a reason, and stays on the record.
• The check covers your own staff and your subcontractors' workers in the same way.

AI reads the uploaded certificates and proposes the details. The rules make the decision, and a person signs it off. The software doesn't judge competence for you: it makes sure nobody is put on a task without the evidence your rules require.

For the gate side of the same problem, see how to verify workers on a construction site. For method statements, see RAMS sign-off before work starts.

Frequently asked questions

Is a CSCS card a legal requirement on UK construction sites?

No. CSCS itself states that holding a card is not a legal requirement. Many principal contractors and clients make it a condition of site access, but that is a contractual or company rule.

What does CDM 2015 say about worker competence?

Regulation 15(7) says a contractor must not appoint a person to work on a site unless they have, or are in the process of obtaining, the skills, knowledge, training and experience to carry out the tasks allocated to them safely.

Can a trainee do a task they aren't yet qualified for?

The regulations allow for people who are in the process of obtaining competence. The Work at Height Regulations, for example, allow work at height by someone being trained under the supervision of a competent person.

Does the competence duty apply to supervisors as well?

Yes, for some activities. The Work at Height Regulations cover organising, planning and supervising work at height, and PUWER requires training for people who supervise or manage the use of work equipment.

How often should task competence be checked?

Every time work is allocated, and again whenever a ticket or document expires before the booked work. A single check at induction does not keep up with a changing programme.

Who is responsible for checking subcontractors' workers?

Each contractor has the regulation 15 duty for the people it appoints, and the principal contractor controls site access. In practice the main contractor sets the requirements and checks the evidence, and the subcontractor supplies it.

Next step

Write your task requirement list for the five highest-risk activities on your current sites, using the template above. If you want the check to run automatically on every booking and permit, you can start a 7-day trial (card required).