Quick answer
On a new build the head contractor is the main PCBU running the site, and the kitchen installer comes on as a subcontractor who is also a PCBU. Both hold health and safety duties over the same work, so the Health and Safety at Work Act 2015 requires them to consult, co-operate and co-ordinate so far as is reasonably practicable. In practice the installer arrives with a site-specific safety plan and a task analysis, gets the crew inducted to the head contractor's site rules, and books the load-in, access and isolations with the site manager before a single cabinet moves.
Key points
- The head contractor runs the site as the main PCBU; the kitchen installer is a subcontractor PCBU with overlapping duties over the same install.
- Section 34 of the HSW Act 2015 makes both parties consult, co-operate and co-ordinate so far as is reasonably practicable, and neither can contract out of its duty.
- The installer brings a site-specific safety plan (SSSP) and a task analysis or JSA covering manual handling, work at height, power tools, dust and temporary loads, with current SDS where relevant.
- Coordination with the site manager covers delivery windows, crane or hiab load-in, access and lift paths, floor protection, isolations before connection, and fitting the install into the programme.
- Tōtika or Site Safe prequalification is the paperwork gate. It is not the same as a good SSSP and a briefed crew on the day.
- Near-misses and incidents are reported up to the head contractor; notifiable events go to WorkSafe. Records are kept on both sides.
The same sequence on every new build we subcontract into.
Two PCBUs on one site, sharing the same duty
A new build has one main PCBU running the site, and that is the head contractor. The kitchen and joinery installer arrives later in the programme as a subcontractor, and under the Health and Safety at Work Act 2015 the installer is a PCBU in its own right. Both are persons conducting a business or undertaking, both owe duties to their workers and to anyone the work could affect, and on the day those duties sit over the same benchtop and the same lift path. This is the ordinary shape of a construction site, and we set out the mechanics in two PCBUs on one site and how the duties overlap.
This article is about the new build case, where the site is a construction site under a head contractor. The duties look different again when the kitchen goes into a home that is still lived in, which is its own situation covered in health and safety working on an occupied site.
Every primary duty in the Act is qualified by the phrase so far as is reasonably practicable. It does not mean whatever is convenient, and it does not mean spare no expense. Section 22 sets the test: what is reasonably able to be done to ensure health and safety, weighing the likelihood of the hazard, the harm it could cause, what is known about the hazard, and the availability and cost of ways to eliminate or minimise it. For a kitchen install the known hazards are not exotic, so the bar for controlling them is not hard to meet. A crew lifting a stone top with no plan is not a close call.
Where more than one PCBU holds a duty over the same matter, section 34 requires each to consult, co-operate with, and co-ordinate activities with the others, again so far as is reasonably practicable. That is the clause that governs the relationship between the head contractor and the kitchen subcontractor. It is not paperwork for its own sake. It is the site manager knowing when the install crew is on site, the crew knowing which areas are live and which are barriered off, and both parties agreeing who isolates the power before the hob is connected.
What the kitchen subcontractor brings to site
A competent installer does not turn up with a van and a nail gun and ask where to start. The install is planned before it is booked, and the planning arrives on site as two documents the head contractor expects to see. The first is a site-specific safety plan, or SSSP, written for this site and this scope rather than a generic company policy. The second is a task analysis, often called a JSA or a safe work method statement, that breaks the install into its steps and names the hazard and the control for each.
- Manual handling: base and wall cabinets, and stone or laminate tops that can run well over a safe one-person weight, so two-person lifts, trolleys and lifting gear for stone are planned in.
- Working at height: overhead cabinets, bulkheads and rangehood runs done off platforms or trestles, not off a wobbling stool or an upturned crate.
- Power tools and dust: circular saws, routers, jigsaws and drills, with on-tool extraction and respiratory protection where cutting on site is unavoidable.
- Temporary loads: cabinets stacked before fixing, and heavy tops laid flat while joins cure, kept clear of walkways and off unpropped surfaces.
- Substances: current safety data sheets for adhesives, silicones, solvents and cleaners, carried where the product is actually used.
None of that works if the crew is a set of unknown day-hires. The people on site are vetted, they know the SSSP because they were briefed on it, and each one is inducted to the head contractor's site rules before starting work. Being Tōtika prequalified as a health and safety competent installer is the evidence a head contractor checks first, and it is the baseline we work to.
Coordinating the install with the site manager
The install is a short, intense phase near the end of the build, and it lands in the middle of other trades finishing off. The coordination runs through the site manager, and most of it is booked before the crew arrives. Getting it wrong does not only cost a day. A stone top that turns up with no hiab window and no clear lift path either sits out in the weather or blocks the only access for everyone else on site.
- Delivery windows: booking the load-in slot, and whether tops come in by crane, hiab or by hand, so the lift does not clash with a concrete pour or another trade's delivery.
- Access and lift paths: the route from the truck to the kitchen, kept clear and protected, with finished floors covered and corners guarded.
- Isolations: power and water isolated at the right points before any connection work, confirmed with the site manager rather than assumed.
- Hazard reporting and toolbox talks: a start-of-day talk with the crew, and hazards logged into the site's system as they are found.
- Programme fit: slotting the install so it follows the trades it depends on and does not block the ones that come after it.
That last point is where health and safety and the build programme meet. An install crammed into a slot before the floor is down, or run at the same time as the painters in the same room, creates clashes that are a safety problem before they are a scheduling one. We plan the sequence deliberately, which is the subject of coordinating the kitchen install with the other trades, and we hold to real lead times so the booking means something, covered in kitchen lead times and the construction programme.
| Head contractor (main PCBU) | Kitchen subcontractor |
|---|---|
| Runs the site, sets the site rules and the overall health and safety plan | Writes the SSSP and JSA for the kitchen install and works to the site rules |
| Inducts every worker and subcontractor onto the site | Sends inducted, vetted crew and keeps their training records current |
| Controls the programme and grants access, isolations and permits | Books delivery, load-in, lift paths and isolations through the site manager |
| Maintains the site hazard register and incident system | Reports hazards, near-misses and incidents into that system |
| Notifies WorkSafe of notifiable events on the site | Tells the head contractor at once so the notification can be made |
| Coordinates all trades so their work does not endanger each other | Fits the install to the sequence and flags clashes early |
Prequalification is the gate, not the job
Prequalification systems such as Tōtika and Site Safe exist so a head contractor does not have to audit every subcontractor's health and safety system from scratch. They check that the company has the policies, the procedures, the insurances and the training records a competent PCBU should have, and they issue a status the head contractor can rely on at the tender stage. It is a real check and it is worth holding. It is also, on its own, a filing cabinet.
A clean status still needs a plan for the job and a briefed crew.
The honest position is that prequalification tells you a company is capable of working safely, not that it did on your site last Tuesday. The gap between the two is closed by a site-specific plan written for the actual job, a crew that was briefed on it, and a site manager who sees the controls in use. A firm can hold a clean Tōtika status and still send an unbriefed crew to freehand a stone lift. The paperwork and the practice are different things, and a good developer checks both.
Reporting incidents and near-misses up the chain
On a shared site the reporting runs up to the head contractor, who holds the master hazard register and the incident system. The kitchen crew logs the hazards it finds and reports near-misses and incidents into that system, not into a private notebook that never leaves the van. The point of a near-miss report is that the next crew does not have the accident, so a dropped tool that happened to hit nobody still gets recorded and still gets a control.
Serious events are treated differently. A notifiable event, which the Act defines as a death, a notifiable injury or illness, or a notifiable incident such as a load falling from a height, must be reported to WorkSafe as soon as possible and the scene preserved. On a construction site the main contractor usually makes that notification, so the installer's job is to tell the head contractor at once. Both parties keep records: the SSSP and JSA, induction and training records, toolbox talk sign-ins, hazard reports and any incident paperwork. Those records are what a working system looks like after the fact.
We treat the head contractor's site rules as the floor, not the ceiling. Our crew is inducted, the SSSP has the site's address on it, and the load-in is booked before the truck leaves East Tamaki. If a stone lift has no clear path, it does not happen that day.
Readiness checklist a developer can expect before we arrive
A site manager should not have to chase a kitchen subcontractor for the basics. Here is what a competent installer has ready before the crew books in, and what a developer is entitled to ask for.
- Current Tōtika or Site Safe prequalification status, provided on request.
- An SSSP written for this site, with the address and scope, not a generic template.
- A task analysis or JSA for the install, naming the hazards and controls for manual handling, height, tools and dust.
- Proof the crew is inducted to the site rules, with training records available.
- Current safety data sheets for any adhesives, silicones and solvents coming to site.
- A booked delivery and load-in plan, including how stone tops arrive and the lift path they take.
- Confirmed isolation points for power and water before connection work starts.
- A named contact who reports hazards and near-misses into the site system.
How MTN runs health and safety as a subcontractor
MTN Kitchens works as a subcontractor on new builds across Auckland from our East Tamaki base, and the setup above is how we operate on every one. We are Tōtika prequalified, which is why head contractors put kitchen work through us without re-auditing our system each time. Our crews are our own and vetted, not day-hires picked up at the gate, and they are inducted to each site's rules before they lift a thing. The install is coordinated with the main contractor's site manager, from the delivery window to the isolations, so it fits the programme instead of fighting it.
Health and safety on a construction site is not a document you hand over at the start and forget. It is the plan matching the job, the crew knowing the plan, and the coordination holding on the day. That is the part prequalification cannot do for you, and it is the part we take seriously as a subcontractor. If you are running a new build and want to know how the kitchen phase will sit inside your site's health and safety system, send the scope and the programme and we will tell you exactly how we would run it.
Frequently asked questions
Is the kitchen installer a PCBU or just a worker on someone else's site?
The kitchen installer is a PCBU in its own right, a person conducting a business or undertaking, even while working as a subcontractor under the head contractor. Both companies hold health and safety duties over the same work, and section 34 requires them to consult, co-operate and co-ordinate so far as is reasonably practicable.
Can the head contractor's site plan cover the kitchen crew instead of a separate SSSP?
No. The head contractor's overall plan sets the site rules the crew must follow, but the installer still needs its own site-specific safety plan and task analysis for the install work. Duties cannot be contracted out under the Act, so both documents are expected on site, working together rather than one replacing the other.
What does so far as is reasonably practicable mean for a kitchen install?
It is the test in section 22: what can reasonably be done to control a hazard, weighing how likely harm is, how serious it could be, and the cost and availability of the controls. For known install hazards like lifting a stone top, the bar for having a proper plan and enough people is easily met.
Who reports an accident on site, the installer or the head contractor?
The installer reports hazards, near-misses and incidents into the head contractor's site system and tells the site manager straight away. For a notifiable event under the Act, the main contractor usually makes the formal notification to WorkSafe, and the scene is preserved until an inspector or the contractor says otherwise.
Does prequalification mean the crew will actually be safe on the day?
Not by itself. Tōtika or Site Safe prequalification shows the company has the systems, insurances and training records of a competent PCBU. It does not guarantee a site-specific plan was written or that the crew was briefed on it, which is why a developer should check both the paperwork and the practice on site.
Does a kitchen installer need to be a Licensed Building Practitioner to work on the site?
Installing the joinery itself is generally not restricted building work, so an LBP is not usually required for that part, though connected trades like plumbing and electrical are separately regulated. We cover the detail in whether you need an LBP to install a kitchen. Health and safety duties apply regardless of licensing.