If more than one contractor works on a construction site, the law requires three things before the first spade goes in: an appointed occupational safety and health coordinator, a prepared OSH plan, and written notification of the site to the State Labour Inspectorate. The obligations do not fall on the contractor alone — most of them rest with the developer and the project supervisor. This article explains who owes what, at what moment, and what they risk by omitting it.
Which regulation governs construction site safety
The basic framework is the Occupational Safety and Health Act (Official Gazette of RM no. 92/07 as subsequently amended; the latest amendment is published in Official Gazette of RNM no. 74/25, which moved competences to the Ministry of Economy and Labour).
The detail for construction sites is in the Rulebook on minimum occupational safety and health requirements at temporary and mobile construction sites (Official Gazette of RM no. 105/08). It applies to every site where construction works are carried out — and the list in Annex 1 is broad: excavation, earth filling, construction, assembly and dismantling of prefabricated heavy elements, renovation, repairs, demolition, work on installations, and even maintenance, painting and cleaning. Many companies assume "this is just a renovation, not a construction site". Under the rulebook — it is.
When the OSH plan is mandatory
The rule is set the opposite way round from what is expected: it is not the contractor but the client or the project supervisor who must verify, before any construction activity begins, that the health and safety plan exists (Article 4).
An exemption from this obligation is possible, but only after consulting employer and employee representatives — and never where the works involve the particular risks listed in Annex 2 of the rulebook. Those ten categories are:
- risk of burial, sinking in mud or falling from height, where the risk is increased by the nature of the work or the environment
- exposure to chemical or biological substances with a particular hazard or with a statutory requirement for health surveillance
- work with ionising radiation with designated controlled or supervised areas
- work in the vicinity of high-voltage power lines
- work with a risk of drowning
- work in wells, underground workings and tunnels
- work by divers with an air supply system
- work in caissons in a compressed air atmosphere
- work with explosives
- assembly and dismantling of heavy prefabricated structural elements
In practice, at most construction sites in Macedonia at least one of these applies — most often work at height. That means the plan is mandatory without exception.
The plan sets out the rules applicable to the specific site and must contain specific measures for each Annex 2 category present on the project. It is not a generic document: it is written for that location, that scope and those contractors, based on the data from the risk assessment.
Coordinator in the design phase and in the execution phase
The rulebook recognises two distinct roles, both appointed by the client or the project supervisor. Appointment is mandatory for every site where more than one contractor is present (Article 4).
Coordinator during the preparatory phase (design)
Under Article 6, they:
- coordinate the application of the general principles of prevention while architectural, technical and organisational matters are still being decided and while the duration of the phases is being planned
- prepare the health and safety plan or entrust its preparation
- produce technical documentation containing the safety and health elements that will be needed for any later work on the building — maintenance, reconstruction, dismantling
The last point is most often neglected. It is the reason why, five years later, someone will know where the high-voltage cable runs behind the façade.
Coordinator during execution
Under Article 7, they:
- coordinate the application of the general principles of prevention in technical and organisational decisions and in planning the duration of the phases
- ensure that the employers implement the OSH plan
- produce amendments to the plan and to the technical documentation as the works progress
- organise cooperation between the employers, including those joining later, and the exchange of information between them, including self-employed persons
- coordinate the checking of whether work procedures are being carried out correctly
- take steps to ensure that only authorised persons are present on site
Who is liable when several contractors work on one site
This is the question that most often ends up in dispute after an accident. The law's answer is that liability is layered, not transferred.
Article 8 of the rulebook is unambiguous: appointing a coordinator does not release the client or the project supervisor from their responsibilities for occupational safety and health. Nor does the application of Articles 6 and 7 release the employer from its obligations under the OSH Act.
In addition, Article 15 of the OSH Act requires: where two or more employers work at the same location simultaneously, they must agree in writing on joint safety and preventive measures and appoint a safety professional to implement those measures. A verbal agreement on site does not exist as a legal construct.
Self-employed persons (subcontractors who are natural persons) are not exempt: Article 11 obliges them to comply with specifically listed articles of the OSH Act and Annex 3 of the rulebook, and to take account of the coordinator's instructions.
Notifying a site — who, to whom and on which form
The OSH Act recognises two distinct notifications to the State Labour Inspectorate:
| Notification | Who submits it | When | Legal basis |
|---|---|---|---|
| Of commencement of an activity | The employer | 8 days before starting | Article 23(1) of the OSH Act |
| Of the location where construction works will be carried out | The contractor on construction projects | Before construction works begin | Article 23(2) of the OSH Act |
Since 2025 the form is new. The Rulebook on the form and content of the notification of commencement of an activity and of the notification of the location where construction works will be carried out is published in Official Gazette of RNM no. 184/25 (adopted 27 August 2025, published 4 September 2025, entering into force on the eighth day after publication). The activity notification is Annex 1 and the site notification is Annex 2; both are printed on white A4 paper. On the entry into force of this rulebook, the earlier form from Official Gazette of RM no. 136/07 ceased to apply.
One further detail regularly missed: under Article 4 of the Construction Sites Rulebook, the notification must be displayed in a visible place on the site and updated regularly as required. A copy in a folder in the office does not discharge the obligation.
What you risk by omitting it
Failure to notify is a category II offence under Article 57 of the OSH Act:
| Entity | Fine (in denar equivalent) |
|---|---|
| Micro and small employer — legal entity | EUR 300 – 400 |
| Medium employer — legal entity | EUR 600 – 800 |
| Large employer — legal entity | EUR 800 – 1,000 |
| Responsible person at micro/small, medium, large | EUR 200 / 350 / 450 |
| Employer — natural person | EUR 250 |
The same article also covers failing to appoint a person responsible for occupational safety and failing to adopt an evacuation and rescue plan. And if the employer repeats the offence within one year of committing it, having previously been subject to an inspection decision under Article 49(1), the labour inspector will prohibit work in the work premises or workspace by decision for 15 days.
The fine, however, is the smallest cost. After a serious injury on an unnotified site with no plan and no coordinator, liability is examined against the developer, the supervisor and the contractor simultaneously — and the absence of documentation is then the principal evidence against all three.
A practical sequence before opening a site
- The developer or supervisor appoints a coordinator for the design phase (if there is more than one contractor).
- The OSH plan is prepared with measures for each Annex 2 particular-risk category.
- The developer or supervisor appoints a coordinator for the execution phase.
- The employers on site conclude a written agreement on joint measures and appoint a safety professional (Article 15 of the OSH Act).
- The contractor submits the site notification on the form from Official Gazette of RNM no. 184/25 and displays it in a visible place.
- The site is set up to the minimum requirements of Annex 3 — emergency routes and exits, fire equipment, sanitary facilities, first aid, marking and fencing of the zone.
How we can help
RI-Opusproekt prepares construction site health and safety plans, covers the coordinator role in both phases, and prepares the documentation for notification to the State Labour Inspectorate. We work with both developers and contractors, including on projects with multiple subcontractors. See the construction site safety service or request a quote with a brief description of the project and the number of contractors.
This article is informational and does not replace professional advice. Regulations change — last updated: August 2026.
This article is informational and does not replace professional advice.
