CSCS cards: the twenty-one tasks you may not do without one

Safe Pass and CSCS are not two versions of the same card, and treating them as one is how a site ends up with a legally admitted worker doing an illegal task.

Safe Pass, under Schedule 4 to the Safety, Health and Welfare at Work (Construction) Regulations 2013, is general: craft and general construction workers need it to be on site at all. A construction skills registration card, under Schedule 5, is specific: you need it for a named task, and only for that task.

Regulation 25(1)(b) puts it on the contractor, in the same sentence structure as the Safe Pass duty: every contractor or other person under whose direct control persons work on a construction site must ensure that each of them "is in possession of an appropriate valid construction skills registration card referred to in Schedule 5 if the worker engages in any of the tasks specified in that Schedule".

The list

Schedule 5, paragraph 1(1) sets out the tasks for which a FETAC award under the Construction Skills Certification Scheme is required:

Twenty-one named tasks and an open clause. Note the structure of (c), (e) and (n): the narrower card is only needed where the person has not been trained for the wider one. A 360 degree excavator card covers the mini-digger; the reverse does not hold.

Paragraph 3 defines the scaffolding split. "Scaffolding — basic" is general scaffolding operations other than those covered by advanced; "Scaffolding — advanced" includes construction of special scaffolds as specified in a relevant code of practice, and scaffolds that may require design or calculation.

What counts as a valid card

Schedule 5, paragraph 2 requires successful completion of:

• "the relevant FETAC award under the Construction Skills Certification Scheme",
• "an equivalent FETAC award", or
• "an equivalent award approved by a body in another Member State of the European Union recognised … as equivalent to the FETAC award".

Regulation 2(4) of the Regulations, read with the Recognition of Professional Qualifications (Directive 2005/36/EC) Regulations 2008, S.I. No. 139 of 2008, makes the awarding body responsible for issuing valid construction skills registration cards with photographic identification under Schedule 5 and for maintaining a register of the cards issued. As with Safe Pass, the Regulations name FÁS; those functions are now exercised by SOLAS.

Trainees

Schedule 5, paragraph 1(2) is the provision that keeps apprenticeship possible. Where experience must be gained before undertaking the programme, a person may perform the listed task during the training period required by the programme if:

• "the person concerned is under the supervision of a competent person", and
• "the person concerned is in possession of an appropriate identification identifying the person as a trainee for the purpose of gaining experience and competence in the skill in the area in which the person is undergoing training".

Both conditions, together. Supervision without trainee identification does not satisfy the paragraph, and neither does identification without supervision.

The two places the Regulations name a card outside Schedule 5

Two operations elsewhere in the Regulations point back at Schedule 5 and set out staffing rules that are easy to breach without noticing.

Roadworks — regulation 97. Where any part of a road is opened, excavated, broken up or obstructed for construction work, the contractor must ensure that:

• the works are "supervised by a competent person who has been issued with a valid construction skills registration card … for the tasks specified in clause (r)" — signing, lighting and guarding on roads (reg. 97(1)(a)(ii)); and
• where that person is not on site, "there is on site at all times when the works are in progress and workers are on site, at least one person" holding a card for the clause (u) tasks — assisting in the implementation of health and safety at roadworks (reg. 97(1)(a)(iii)).

Regulation 97(1)(b) adds that where construction work obstructs a roadway, or diverts pedestrians or cyclists onto a roadway, a clause (r) card holder must be on site at all times while road signing, lighting and guarding is being installed, modified or removed. Under regulation 97(2) that person carries responsibility for implementing the signing, lighting and guarding, monitoring it and taking corrective action.

Shotfiring — regulation 74. Among the duties of the relevant contractor, regulation 74(h) requires that "the competent shotfirer is in possession of a valid constructions skills registration card for that task as referred to in Schedule 5".

Who checks, and when

Three duties, three different people:

• The contractor, regulation 25(2): on the worker's first day on site, ask to see the card and furnish written confirmation to the project supervisor for the construction stage.
• The PSCS, regulation 19(b): coordinate arrangements to ensure that those engaging in Schedule 5 tasks each hold an appropriate valid card.
• The worker, regulation 29(1)(g): show the relevant registration cards when requested by the employer or the PSCS.

And regulation 29(2) makes false applications, forgery, alteration and the possession of close imitations with intent to deceive separate offences.

A short checklist

1. Map machines to cards, not people to cards. The duty attaches to the task. A hired-in telehandler for one afternoon needs a (g) card holder that afternoon.
2. Check the specific card, not just that a card exists. A slinging card is not a mobile crane card, and a mini-digger card is not a 360 card.
3. For roadworks, plan the (r) and (u) cover before the job. Regulation 97 requires someone present at all times, and that is a rota question, not a site question.
4. Give trainees written trainee identification and name the supervising competent person. Paragraph 1(2) requires both.
5. Renew before the card lapses. Card renewals now run through SOLAS's online service, and a card that expires mid-project takes the machine off the job with it.

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Position as at 29 August 2026. This article describes the law and is not legal or safety advice. S.I. No. 291 of 2013 has been amended since it was made, and the awarding functions it assigns to FÁS are now exercised by SOLAS.

What Zirko does here: staff and their site assignments live in one plan, so who is scheduled onto which site is visible before the week starts. Zirko does not hold CSCS card numbers, does not track expiry dates and does not check any card register.