Withdrawal of archaeologists from the need for CSCS certification: statement and FAQs

CIfA has been notified that CSCS are making changes to the criteria governing the requirement to hold a valid CSCS card and that the AQP and PQP cards will not be issued to archaeologists after 30 April. We are working with FAME to understand the implications of this change and we understand that the removal of archaeologists, alongside other non-construction occupations, from the CSCS scheme is being communicated to construction companies.

CIfA is disappointed that we were not consulted by CSCS before the decision was made. FAME and CIfA continue to believe that inclusion in the scheme is in the interests of archaeology and construction, and CSCS’ current decision will create a health and safety vacuum and cause confusion on construction sites. As outlined in the CIRIA good practice guide C799 Archaeology and Construction, archaeological work is an integral part of the construction process. As a construction-related occupation, archaeological teams are subject to the same health and safety risks and management procedures as the construction teams they work alongside on site, and construction-related archaeological work is covered by CDM regulations. Archaeologists work alongside and in parallel with construction teams for periods of time so should not be classed as site visitors.

Although not CSCS’ intention, we are concerned that this change may result in access problems for archaeologists in the short term. We recommend that Registered Organisations contact their clients well in advance of the cut-off date to notify them of the changes. We encourage RO’s experiencing problems gaining access to construction sites as a result of the withdrawal of the AQP and PQP cards to notify CIfA as well as getting in touch directly with CSCS. CSCS have provided the following links as further information:

This is an evolving resource, if you have a question which is not answered, please get in touch with us.

 

Frequently Asked Questions (FAQs)

Does this mean that archaeology is no longer considered a construction-related occupation?

Archaeology remains a construction-related occupation in every meaningful sense. CSCS’ decision to remove archaeology from the scheme is based upon 2015 CDM regulations which define archaeology as a construction-related occupation only when it takes place 'during’ construction, and not when it takes place ‘before’ construction. Although CSCS’ decision sends an unfortunate signal, it does not change the fact that archaeology is an integral part of the construction process which is required in the planning process and delivers positive public benefits as part of a development process.

Many other specialist sub-contractors are also not currently part of the CSCS scheme - https://www.cscs.uk.com/applying-for-cards/non-construction-related-occupations/.

 

What is the date when a CSCS card is no longer needed for working as an archaeologist on a construction project that is part of the CSCS scheme?

1 May 2024

My CSCS card will expire shortly before the official withdrawal date.  Do I still need to get a new one and, if I do, will I get a partial refund?

CSCS have said that there will be no partial refunds for cards that will shortly be withdrawn, nor are they able to offer pro-rata payments.  Check with your line manager or project leader to see if the site you will be working on requires archaeologists to hold a CSCS card until 30 April. 

 

I have just started working and have been told that I need a CSCS card, what should I do?

We recommend that you discuss with your employer on the best course of action. CSCS cards are not a legal requirement. It is up to the principal contractor or client operating the site as to whether workers are required to hold a card. It may be possible for your employer to negotiate access to site close to the deadline rather than begin the CSCS application process now.

 

If I apply for a CSCS card up until the 30 April how long will it be valid for?

If you apply for the card in the withdrawal notice period ending on 30 April 2024 the card will be valid for 5 years until noted expiry date.

 

What do I do if I am refused entry to a site after 1 May because I don’t have a card?

We understand from CSCS that construction companies should have been informed of the forthcoming changes.

CSCS is aware some sites insist everyone must hold a card and is working with the construction industry to tackle the issue. In the short term, your employer should be having prior conversations with principal contractors to attempt to anticipate and minimise confusion from 1 May.

Please contact CSCS for more information.

How can I ensure that archaeologists at my organisation will not be challenged on arrival at construction sites?

The onus should not be on you to prove to your clients that archaeologists will not need cards to be on site from 1 May.  CSCS will be issuing a press release stating that archaeologists do not now need CSCS cards unless they are undertaking a specifically core construction related activity - such as acting as a banks person, shoring excavations or driving plant where the client requires construction workers to hold a card.  If this is the case you should consult the CSCS website to see what the most appropriate card is https://www.cscs.uk.com/types-of-cscs-cards/

CSCS is aware some sites insist everyone must hold a card and is working with the construction industry to address this. In the short term, archaeological companies may wish to discuss with principle contractors to attempt to anticipate and minimise confusion from 1 May.

Please contact CSCS if you have any questions.

 

I’ve just spent a lot of money on tests and cards for my workforce and now they don’t need them.  How do I get a refund?

CSCS have said that there will be no partial refunds for cards that will shortly be withdrawn, nor are they able to offer pro-rata payments.

 

I employ archaeologists whose cards will expire before 30 April. Will my staff still need new CSCS cards even though it has already been announced that archaeologists won’t need them?

If you have staff whose cards are about to expire it would be worth contacting your client to explore the possibility of site access without cards.  CSCS cards are not a legal requirement. It is up to the principal contractor or client  operating the site as to whether workers are required to hold a card.