The UK construction and engineering sectors increasingly rely on an international supply chain. Major projects bring together clients, Principal Contractors, designers, specialist contractors and workforces from across Europe and further afield. That brings enormous experience, specialist knowledge and capability. But it also creates a challenge that is not always managed particularly well:
What happens when a contractor is technically competent to undertake the work, but does not fully understand UK health and safety expectations — while the UK organisation managing them does not fully understand the communication challenges facing that contractor?
At Arco Safety, we have encountered this situation on projects.
A technical issue needs discussing. There is a language barrier. A mobile phone appears and Google Translate or another translation application is used to explain a complicated instruction.
For everyday conversation, that can be extremely useful. But what if the conversation concerns an electrical isolation, lifting operation, temporary works arrangement, change to RAMS, working-at-height control or another safety-critical activity?
That's different. Frustration can then develop on both sides.
The UK organisation thinks:
"Why won't they just follow our requirements?"
The contractor thinks:
"Why are they making this so complicated?"
Neither position solves the problem. Neither party should be able to shrug its shoulders and decide the problem belongs entirely to somebody else. There are responsibilities on both sides of the coin and the objective should be straightforward: Set contractors up to succeed — not to fail.
Let's deal with one side first. If an organisation chooses to undertake work in the UK, it has a responsibility to understand the environment in which it will be operating. Being an overseas contractor does not provide an exemption from applicable UK health and safety legislation, relevant standards or the agreed requirements of the project.
Neither does:
"That's how we do it in our country."
"We've always done it this way."
"Our company procedure doesn't require that."
or
"We don't normally have to do this."
Different countries have different legislation, regulatory systems, industry practices and safety cultures. >A company entering the UK market needs to recognise those differences before its workforce arrives on site. Preparation starts before mobilisation
An international contractor should be asking:
And ultimately:
Are we genuinely ready to work safely in the UK?
That is part of contractor competence. A language barrier cannot become an excuse for disregarding requirements.
If somebody does not understand something safety-critical, the answer should be:
STOP. ASK. CLARIFY. THEN PROCEED.
Contractors need to create an environment where an operative or supervisor can say: "I don't understand." without embarrassment or fear of criticism.
What cannot become acceptable is recognising that something has not been understood and carrying on regardless.
Now turn the mirror around.
The UK organisation has responsibilities too.
If you appoint an international contractor, you cannot simply pretend foreseeable communication problems don't exist.
If you know a significant proportion of the workforce has limited English, that is foreseeable.
If you know the contractor's management has limited experience of the UK construction environment, that is foreseeable.
If you know safety-critical technical conversations are routinely taking place through mobile translation applications, that is foreseeable.
Simply responding:
"They're the contractor. They should know."
doesn't manage the risk.
Good contractor management means establishing expectations while also creating the conditions in which competent contractors can successfully achieve them.
That does not mean lowering standards.
It means communicating those standards effectively.
This is where the industry needs to challenge itself. We sometimes confuse documentation with communication. RAMS issued - TICK. Induction completed - TICK. Toolbox talk signed - TICK. Permit signed - TICK. Everything appears satisfactory.
But ask a different question:
Can the person actually explain what they have just agreed to?
An operative's signature proves that something was signed. It does not automatically prove that the information was understood. If somebody cannot explain the critical controls contained within their safe system of work, the communication process has not achieved its objective — regardless of how complete the paperwork appears.
SIGNATURE ≠ UNDERSTANDING
Translation technology can be extremely useful. There is nothing inherently wrong with using Google Translate or similar applications to assist communication. The problem begins when they become the primary method for communicating complex, safety-critical information.
Consider terminology routinely used on major projects:
Now combine those terms with technical abbreviations, trade terminology, drawings, different interpretations and complicated engineering discussions. A translation can appear linguistically correct while the technical meaning has still been misunderstood. For everyday conversation, that might be inconvenient. For an isolation, lifting operation or change to a working-at-height system, the consequences could be considerably more serious.
There is an important distinction that organisations need to recognise.
The person genuinely cannot comply because they have not understood what is required.
That is primarily a communication problem.
Fix it.
The person understands the requirement but deliberately chooses not to comply with it.
That is an accountability problem.
Deal with it.
This may be the most dangerous category.
The operative believes they have understood.
The supervisor believes the operative has understood.
The Principal Contractor believes the supervisor has briefed the workforce.
Everyone believes the system is working.
But the technical meaning has actually been misunderstood.
Nobody is deliberately breaking a rule.
Nobody necessarily recognises that there is a problem.
Work continues.
That hidden misunderstanding can be considerably harder to identify than open non-compliance.
Good contractor management needs to distinguish between all three.
One simple change can make a significant difference.
Stop relying exclusively on:
"Do you understand?"
People frequently answer yes.
They may be embarrassed.
They may feel under pressure.
They may not want to appear difficult.
Or they may genuinely believe that they have understood.
Instead, verify understanding.
Ask:
"Show me where the exclusion zone needs to be."
"Talk me through the isolation procedure."
"What happens before you start this task?"
"Show me where your fall-protection equipment will be attached."
"What would make you stop this job?"
"Who do you speak to if the method needs to change?"
This is often described as teach-back.
At Arco Safety, we prefer a simpler principle:
VERIFY. DON'T ASSUME.
The objective isn't to catch somebody out.
It's to identify misunderstanding before the work begins.
Communication arrangements should be established before the contractor arrives.
The incoming contractor should:
The UK organisation should:
The important word is:
BEFORE.
The first time anybody discovers that there is a serious communication problem should not be halfway through a lifting operation.
Communication does not have to depend entirely on written English.
Use:
A complicated paragraph translated into another language may still be misunderstood.
Showing somebody the equipment, pointing to a drawing, demonstrating the expected arrangement and then asking them to show you how they will carry out the activity may be considerably more effective.
Setting contractors up to succeed does not mean tolerating unsafe behaviour.
There cannot be:
the project standard
and
the standard we tolerate because communication is difficult.
The required safety standard remains the required standard.
What may need to change is how that standard is communicated and achieved.
Support must not become tolerance.
But equally:
Accountability must not become an excuse for poor management.
Both sides have responsibilities.
When an incident or unsafe act involves an international contractor, one of the easiest conclusions is:
"They didn't follow the RAMS."
That may be true.
But it isn't an investigation.
Ask:
Why?
Did they understand the RAMS?
Was the briefing effective?
Was competent supervision available?
Were project expectations understood?
Was the contractor adequately prepared for the UK environment?
Were language problems identified before mobilisation?
Did somebody recognise the communication problem but allow work to continue?
Did the operative believe they understood when they actually didn't?
Or did they fully understand what was required and deliberately choose not to follow it?
Those questions can produce very different conclusions.
And considerably better corrective actions.
This is where communication problems can expose something deeper within an organisation.
Management may believe the system works like this:
RAMS issued → briefing completed → signatures obtained → workforce understands → work proceeds safely.
That is work as imagined.
But on site the reality may be:
RAMS issued → difficult technical English → supervisor attempts translation → workforce signs → work begins → misunderstanding develops → local workaround emerges.
That is work as done.
On paper, the organisation appears compliant.
On site, something completely different is happening.
The distance between those two realities is where organisational drift can develop.
Paperwork alone will rarely expose it.
You have to go and look.
You have to talk to people.
And you have to verify what is actually happening.
Good contractor management should begin with a simple principle:
SET PEOPLE UP TO SUCCEED.
For the contractor coming into the UK, that means arriving prepared: understanding the environment, bringing appropriate competence and supervision, communicating effectively with your workforce and taking responsibility for meeting the required standards.
For the UK client, Principal Contractor or organisation appointing them, it means recognising foreseeable barriers, clearly communicating expectations, providing appropriate information and verifying genuine understanding.
For both parties, it means having the confidence to stop and resolve uncertainty before somebody gets hurt.
Neither party gets to point across the table and say:
"That's their responsibility."
Shared responsibility does not mean diluted accountability.
The incoming contractor has a responsibility to arrive prepared to succeed.
The UK organisation has a responsibility to create the conditions in which success is possible.
Both have a responsibility to challenge unsafe work when those standards are not being achieved. Because the objective shouldn't be establishing who was responsible after an accident. It should be creating the conditions that prevent the accident happening in the first place.
Safety in The Right Hands
Arco Safety works with clients, Principal Contractors and contractors to improve CDM compliance, contractor management, construction health and safety, site assurance and organisational safety culture.
We don't just ask whether your procedures exist. We ask whether they actually work when they reach the people doing the job.