A SHE rep is the person your workplace elects to watch its health and safety from the inside. The law calls the role something else, which is where most of the confusion starts. Here is what the role is, who has to appoint one, and what the Act actually asks of them.
SHE stands for safety, health and environment. A SHE rep is an ordinary employee, designated by the employer, who keeps an eye on health and safety in their own part of the workplace and raises what they find.
The first thing worth knowing is that the Act does not use the term. The Occupational Health and Safety Act 85 of 1993 calls the role a health and safety representative. “SHE rep” is the name that stuck on South African sites, and the two mean the same thing. If an inspector or an auditor asks for your health and safety representatives, they are asking for your SHE reps.
The role is part-time and it is internal. A SHE rep carries on doing their normal job, and takes on the representative duties alongside it. They are not a safety department, not a contractor, and not the person who becomes liable when something goes wrong.
The trigger is headcount. Under section 17, an employer with more than 20 employees at a workplace must designate health and safety representatives for that workplace. Below that number the Act does not require them, though nothing stops an employer appointing one anyway.
Three conditions come with the designation, and each of them is a common audit finding when it is missed.
| Type of workplace | Representatives required |
|---|---|
| Shops and offices | At least one for every 100 employees or part thereof |
| Every other workplace — mines, construction sites, factories, yards, depots | At least one for every 50 employees or part thereof |
“Or part thereof” does the work in both rows. A construction site with 60 people needs two representatives, not one. For the employer’s wider duties, see the Occupational Health and Safety Act page.
Section 18 sets out what a health and safety representative may do. It is a list of powers rather than a job description, and it is worth reading before you appoint someone, because it is what the role is measured against.
Two of these are routinely forgotten. The right to accompany an inspector matters, because an inspection without the representative present is a weaker record. And the right to escalate to an inspector when the employer does not act is the part that gives the role teeth.
Section 18(3) puts a duty on the employer in return: provide the facilities, assistance and training the representative reasonably needs to carry the functions out. A designated rep who has had no training is the gap an auditor looks for.
This is the part worth saying to the person before they accept the role. A SHE rep does not take on the employer’s legal duty, and does not become personally liable for the state of the workplace.
Section 18(4) is explicit: a representative does not incur civil liability by reason only of failing to do something the Act allows or requires them to do. The duty to provide a safe workplace stays with the employer under section 8, and the chief executive officer carries the duty to see that it is discharged under section 16.
Nor is a SHE rep there to fix things personally. The role is to look, record, raise and follow up. Repairing the hazard is the employer’s job.
These two get used interchangeably on site and they are not the same thing. The difference matters when a client asks who is responsible for safety on your job.
| SHE representative | Safety officer | |
|---|---|---|
| Where it comes from | Section 17 of the Occupational Health and Safety Act | Not a role the Act names; it is a job an employer creates |
| Who holds it | A full-time employee doing their normal job as well | Usually a dedicated appointment, often a full-time post |
| How they are put in place | Designated in writing for a specified period | Employed or contracted into the position |
| What they do | Inspect, identify hazards, investigate complaints, make representations | Runs the safety system: files, risk assessments, inductions, audits |
| Can one replace the other? | No — a workplace over 20 employees needs designated representatives regardless of who else it employs | No — employing one does not discharge the section 17 duty |
The short version: a safety officer is staff, a SHE representative is a statutory appointment. Most sites of any size end up with both, and a safety officer who also happens to be a designated representative does not count twice.
Representatives do not operate alone once there is more than one of them. Section 19 requires the employer to establish a health and safety committee as soon as two or more representatives have been designated at a workplace.
Every designated representative sits on a committee. Where a workplace has several committees, each representative must be a member of at least one. The committee has to meet at least once every three months, and as often as necessary beyond that, at a time and place it sets itself.
Under section 20 the committee may make recommendations to the employer, or to an inspector where the employer does not act, and it must discuss any incident in which someone was injured, became ill or died. Those minutes are among the first documents an auditor asks to see, which is why they belong in the health and safety file.
The Act does not prescribe a syllabus, but section 18(3) requires the employer to provide the training the representative reasonably needs for the functions in section 18. In practice that means a representative who can read the Act, run an inspection and identify a hazard properly — not one who has been handed a clipboard.
SHE representative training at Fundza is a two-day course at R1 100 per person, assessed by written test. It covers the principles of the Occupational Health and Safety Act and its regulations, the minimum compliance the Act requires, how to run a workplace inspection and identify hazards, and the requirements of the National Environmental Management Act and the Environment Conservation Act.
Most employers train the representatives alongside the other appointments the same workplace needs: first aid, fire fighting and, where people work above ground level, working at heights. Where a committee is being trained together, group bookings and pricing covers how that is quoted, and training on your own premises means the inspection practical runs in the workplace they will actually be inspecting.
Yes. “SHE rep” is the everyday South African name for the role the Occupational Health and Safety Act calls a health and safety representative. SHE stands for safety, health and environment. If a document, an inspector or a client asks for one, they are asking for the other.
It depends on the kind of workplace. In shops and offices it is at least one for every 100 employees or part thereof; in every other workplace, including construction sites, factories and mines, it is at least one for every 50 or part thereof. The duty starts once you have more than 20 employees at that workplace. “Part thereof” rounds up, so 60 people on a site means two representatives.
Not by reason only of having failed to do something the Act lets or requires them to do — section 18(4) says so directly. The duty to provide a safe workplace stays with the employer under section 8, and the chief executive officer carries the duty to see it is discharged under section 16. That is worth telling anyone who is nervous about accepting the designation.
The Act does not name a course, but section 18(3) requires the employer to provide the training the representative reasonably needs to carry out the functions in section 18. A designated representative who has had no training is one of the easier findings for an auditor or an inspector to make, because the designation letter exists and the training record does not.
For the period specified in the designation, because section 17 requires it to be made in writing for a specified period. There is no period fixed by the Act, so the employer sets it. Diarise the end date: a lapsed designation leaves the workplace short of the number section 17 requires, which is a finding even if the same person is still doing the job.
The designation goes with the job, because section 17 requires representatives to be full-time employees of that workplace. When one leaves you are a representative short and have to designate and train a replacement to stay at the required number. Employers who train in batches tend to keep one or two spare certificated people for exactly this reason.
Two days, R1 100 per person, at our Mokopane centre or on your own site anywhere in South Africa. For a whole committee, tell us the headcount and where they are based.
SHE Rep course details · Group bookings · All safety courses
