Why QCTO cares about Health & Safety
Every Skills Development Provider (SDP) accredited by the Quality Council for Trades and Occupations (QCTO) is audited against the QCTO Accreditation Policy (Reference 11/P/1, v2.0, June 2022) and the Programme Delivery Readiness site visit. One of the line items the QCTO evaluator marks against — and one of the most common reasons applications are delayed — is Occupational Health and Safety (OHS) adherence as per the programme criteria and requirements.
Get OHS wrong and the consequences are real:
- Accreditation is delayed or refused
- Existing accreditation can be withdrawn at any time if the SDP fails to meet its obligations
- Learner records may not be recognised, NQF credits may not be awarded, and training may need to be repeated
- You cannot legally advertise the qualifications you applied for until the formal outcome letter is issued
This article walks you through what the QCTO actually checks at the site visit, the legal stack behind it, and gives you a printable pre-audit checklist built directly from QCTO Form 5 and the OHS Act 85 of 1993.
What the QCTO actually audits at a site visit
The site visit is the second phase of accreditation, after the Desktop Evaluation. It is conducted either physically or virtually depending on resource availability, and only once the SDP appears on the approved site visit schedule.
Before the visit can proceed, the SDP must have completed and submitted all six site visit forms:
- Form 1 — Site Visit Confirmation
- Form 2 — QCTO COVID-19 / health protocol checklist
- Form 3 — Programme Implementation Plan
- Form 4 — Learning Material Matrix
- Form 5 — Evaluation Tool for Programme Delivery Readiness *(this is where OHS lives)*
- Form 6 — QCTO Accreditation Application Checklist
Form 5 is the one that walks the evaluator around the venue and checks that the building, equipment, records and people are ready to deliver training safely. Accreditation, once granted, is valid for five years.
The OHS Site Safety Report — non-negotiable
Every training venue you declare to the QCTO must have a current OHS site safety report on file. This applies to:
- Your primary training venue
- Any rented or temporary venues
- Client premises used for training (mobile delivery)
Two rules trip most providers up:
- It must be current — treat 12 months as the maximum age. An expired report is treated as no report.
- It must be signed by a competent person — typically a member of SAIOSH (Southern African Institute of Occupational Safety and Health), a SACPCMP-registered Construction Health & Safety Officer, or someone holding a recognised OHS qualification suitable to the task. A self-completed checklist signed by an unqualified administrator will not be accepted.
For mobile and client-site delivery, each client venue must be separately declared to the QCTO and have its own OHS report, and you should receive written acknowledgement from the QCTO before training begins at that site.
The legal stack behind the QCTO OHS line item
When the QCTO evaluator ticks the "OHS adherence" box, they are checking that you comply with the South African OHS framework as a whole:
- Occupational Health and Safety Act 85 of 1993 (the OHS Act)
- General Safety Regulations (first aid, PPE, intoxication)
- General Administrative Regulations (Section 16(2), 17, 24 reporting)
- Environmental Regulations for Workplaces (lighting, ventilation, ablutions, drinking water, fire precautions)
- Construction Regulations 2014 — where any practical/construction component is delivered
- SANS 10400-T — fire protection in buildings
- SANS 1475 — servicing of portable fire equipment
- COIDA — Compensation for Occupational Injuries and Diseases Act (Letter of Good Standing)
The QCTO does not re-audit each Act in detail — but their evaluator expects to see evidence that you have addressed every one of them in the documents and on the wall.
QCTO Self-Evaluation Checklist
Get the OHS Compliance Group checklist for your training venue, with space for evidence and corrective actions. This is a self-evaluation aid, not an official QCTO form or proof of compliance.
How to sequence the work in 14 days
You don't need months. A focused fortnight is enough for most SDPs:
- Day 1 — Scope: list every venue (own + client) and confirm what you must declare
- Days 2–3 — Walk-through gap audit using the downloadable checklist; photograph every finding
- Days 4–7 — Close out: service extinguishers, sign appointments, run the evacuation drill, restock first-aid
- Day 8 — SAIOSH-qualified person issues the OHS site safety report
- Days 9–11 — Compile Forms 1–6, attach evidence pack, internal QA review
- Days 12–13 — Mock site visit with a critical friend
- Day 14 — Submit and confirm site visit date
Common reasons SDPs fail the OHS line item on Form 5
In our experience auditing training centres, the same five issues come up over and over:
- Expired fire extinguishers (no SANS 1475 tag, or last service > 12 months)
- No signed Section 16(2) appointment, or the assignee never accepted in writing
- No record of an evacuation drill in the last year
- OHS site safety report written and signed by an unqualified person — the QCTO will reject it
- Mobile / client venues never declared — the SDP runs training at a client site without QCTO acknowledgement
Who can sign your OHS site safety report?
The QCTO does not publish a closed list, but evaluators consistently accept reports signed by:
- A SAIOSH-registered member (Tech, Grad or Chartered)
- A SACPCMP-registered Construction Health & Safety Officer (CHSO) or Manager (CHSM)
- A holder of a recognised OHS qualification (NEBOSH IGC/Diploma, NQF 5+ Safety Management) operating as the appointed competent person
What QCTO will not accept: a self-completed checklist signed by the SDP owner with no OHS credentials, or a generic facilities inspection report from a landlord that does not address the OHS Act.
How OHS Compliance Group helps Training Centres
We package everything above into a single Training Centre Compliance Pack built specifically for QCTO accreditation, SETA verification and Department of Employment and Labour (DEL) inspections. The pack includes the OHS audit, baseline HIRA, statutory appointments, evacuation plan, fire & first-aid registers, COIDA Letter of Good Standing assistance, and a signed OHS Compliance Certificate in the format QCTO evaluators expect.
Explore the OHS Audits & Compliance Certificates service and the Risk Assessment service, or contact us for a Training Centre Compliance Pack quote.
FAQ
Does the QCTO accept an OHS report I wrote myself?
Only if you are a competent person — i.e. a SAIOSH member, SACPCMP-registered CHSO, or someone with an appropriate recognised OHS qualification. A checklist signed by the SDP owner with no OHS credentials will be rejected.
Do I need an OHS report for an online-only programme?
Yes. According to QCTO Form 5, regardless of delivery mode, all QCTO-aligned providers are audited against at least one declared training site. Even fully online providers have had their administrative office audited as the declared venue, and an OHS report is expected.
How often must the OHS site safety report be renewed?
Treat 12 months as the maximum. Most evaluators expect a report dated within the last year, and a fresh report at every accreditation cycle or extension of scope.
What if I train at the client's premises?
Each client venue is treated as a training venue. It must be declared to the QCTO in advance, have its own valid OHS site safety report, and you must receive written acknowledgement from the QCTO before training begins there.
Is a fire compliance certificate the same as an OHS site safety report?
No. A municipal fire compliance certificate covers fire safety only. The OHS site safety report is broader — it covers the full OHS Act stack: appointments, HIRA, first aid, electrical, ergonomics, signage, emergency preparedness and fire.
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Need a QCTO-ready OHS site safety report or a full Training Centre Compliance Pack? Talk to OHS Compliance Group — we audit, we close the gaps, and we issue the signed report your QCTO evaluator is expecting.
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