A written safety policy is only part of what the Occupational Health and Safety Act expects from an employer. The Act also expects specific people to be formally appointed to specific safety roles — not just "whoever's available," but named individuals, appointed in writing, who carry real responsibility.
An appointment under the OHS Act isn't the same as someone informally taking on safety duties alongside their normal job. It needs to be a deliberate, documented decision — typically a signed appointment letter naming the person, the role, and the scope of their responsibility. Without that paper trail, you don't have a legally recognised appointee, even if someone has been doing the work.
Missing or lapsed appointments are one of the most common findings in an OHS audit — not because the work isn't being done, but because there's no valid appointee on record covering it. Beyond the audit finding itself, it leaves a real accountability gap: if something goes wrong and there's no properly appointed person responsible for that area, the exposure sits with the employer directly.
Appointments lapse quietly. A first aid certificate expires, someone appointed as a fire warden leaves the company, a safety officer's designation was never formally renewed after a restructure. None of these show up until someone checks — usually an auditor, or an inspector after an incident.
The practical challenge isn't knowing that appointments are required — it's keeping track of who holds which appointment, whether any certification behind it (like a first aid certificate) is still valid, and whether you have enough appointees to meet the minimum your workplace needs as your team changes.
ZeroLapse tracks legal appointments against the minimum your business needs, alerts you before a certificate behind an appointment lapses, and flags any role left unfilled — so gaps get caught before an audit does.
Start Your Free 30-Day TrialNew to the concept? See What Are OHS Act Legal Appointments? for a plain-English introduction.
This article is general information for South African employers and isn't legal advice. Requirements vary by industry and workplace — consult the Department of Employment and Labour or a qualified HSE professional for guidance specific to your business.