OSH Coordinator on Site: When It Is Required

On one site your bricklaying crew is working, next to them an electrical firm, and on the other side roofers from another subcontractor. Three firms, three employers, one site. Someone leaves an open hole in the floor slab, someone else falls into it - and now the question is: who is responsible for this and who was supposed to coordinate it? This is exactly the situation in which the regulations require an OSH coordinator (occupational safety and health). Many site managers do not know such an obligation even exists until the inspector asks who the coordinator is. In this article I explain when a coordinator is required, who can be one and what they have to do. If you need a template for the appointment and the cooperation agreement, BudoReady gives you ready-made OSH coordination documents to fill in with the firms' data.

Key points in brief

• When workers of different employers work in one place, an OSH coordinator must be appointed - this follows from Article 208 of the Labour Code (KP).
• This is a separate obligation from that of the site manager - the coordinator looks after OSH between firms, not after the construction work as such.
• Appointing a coordinator does not remove each individual employer's responsibility for their own workers.
• On larger sites the BIOZ plan (health and safety plan) and the obligations of the investor and site manager under the Construction Law come into play as well.
• The full set: a written appointment of the coordinator, a cooperation agreement, and a BIOZ plan where required.

Where the coordinator obligation comes from in the first place

The basis is Article 208 of the Labour Code. It states plainly: when workers employed by different employers carry out work in the same place, those employers are obliged to:

• cooperate with one another,
• appoint a coordinator to supervise OSH for all workers employed in the same place,
• establish rules of cooperation covering how to act in the event of hazards,
• inform one another and their workers about measures to prevent hazards.

A construction site is the textbook example of such a situation. Rarely is a site a single firm - most often there is a general contractor and subcontractors, or several independent crews of the investor. As soon as several employers are mixed on one site, Article 208 comes into play.

The OSH coordinator is not the site manager

This is the most common misunderstanding. People confuse the OSH coordinator with the site manager or with the investor's supervisory inspector. These are three different roles from three different laws.

Role	Legal basis	What they do
OSH coordinator	Article 208 of the Labour Code	Supervises OSH between workers of different employers on one site
Site manager	Construction Law	Runs the site, including drawing up/ensuring the BIOZ plan, and the safety of the works
Investor's supervisory inspector	Construction Law	Supervises delivery on the investor's behalf (compliance, quality)

In practice, the role of OSH coordinator is often held by the site manager or a person they appoint - and that is fine, provided they have the competence. But these are two different obligations: one from the Labour Code, the other from the Construction Law. Appointing a site manager does not automatically release you from appointing a coordinator when different employers work there.

Who can be the coordinator

The regulation does not set a rigid list of qualifications, but the coordinator must have real OSH knowledge and competence to carry out the tasks. In practice this is:

• the site manager or works manager,
• a person with OSH qualifications/education (e.g. an OSH specialist),
• a worker with suitable experience appointed by the employers.

Important: the appointment of the coordinator must be in writing - not a "handshake" arrangement over coffee. The inspector asks for the appointment document and who specifically holds the role.

What the coordinator actually does

The coordinator is not a title to hang on a noticeboard - it is a role with tasks. It includes, among others:

1. Supervising OSH compliance by everyone on site - regardless of which firm employs them.
2. Coordinating work that could put people at mutual risk - e.g. when some work at height above others.
3. Reacting to hazards - the coordinator has the right to raise concerns and see a hazard removed.
4. Organising shared areas - traffic routes, storage, welfare facilities, reducing conflicts.
5. Information flow between firms about hazards and planned work.

A crucial note: appointing a coordinator does not remove employers' responsibility. Each employer still answers for the OSH of their own workers - their training, examinations, risk assessment, protective measures. The coordinator adds a layer of coordination between firms, but does not take over the obligations each one has individually.

And where do the BIOZ plan and the investor's obligations fit in

On larger sites, obligations from the Construction Law come into play, independent of Article 208. The site manager draws up or ensures the drawing up of the health and safety plan (BIOZ) where the regulations require it - among others, for particularly hazardous work, a large scope of work, or where the work lasts longer and involves a larger number of workers.

The BIOZ plan and OSH coordination are related but separate topics. We set out exactly when the BIOZ plan is mandatory and how it differs from the BIOZ information in the article BIOZ plan vs BIOZ information. And when you come in as a subcontractor onto a general contractor's large site, coordination is built into their procedures - see the article on entering the site of Skanska, Budimex, Strabag.

Coordination documents you must have

The full set when different employers work on your site:

• Written appointment of the OSH coordinator - who, from when, what scope.
• Cooperation agreement between the employers on OSH (rules of cooperation, conduct in the event of hazards).
• BIOZ plan - where required by the Construction Law.
• Occupational risk assessment from each employer for their own workstations.
• Coordination records - meetings, arrangements concerning conflicting works.

From 8 July 2026, the PIP reform (Polish Labour Inspectorate) tightens penalties, and the absence of an appointed coordinator when different firms work together is a breach the inspector catches. Details of the changes are in the article PIP reform 2026 - what is changing.

Frequently asked questions

When exactly do I have to appoint an OSH coordinator?

When workers employed by different employers carry out work in the same place - as Article 208 of the Labour Code provides. On a construction site this is a typical situation: a general contractor and subcontractors, or several independent crews of the investor on one site. The employers then appoint a coordinator to supervise OSH for all the workers.

Can the site manager be the OSH coordinator?

Yes, and in practice it often is the case. The role of OSH coordinator may be held by the site manager or another person with the appropriate OSH competence appointed by the employers. What matters is that the appointment is in writing and that the person has real knowledge to supervise. These are, however, two different obligations - one from the Labour Code and one from the Construction Law.

Does appointing a coordinator remove my responsibility?

No. Each employer still answers for the OSH of their own workers - their training, examinations, risk assessment and protective measures. The coordinator adds a layer of coordination between firms on a shared site, but does not take over the obligations each employer has individually.

Is a coordinator also needed for two small crews?

If they are workers of two different employers working in the same place - yes, the obligation under Article 208 of the Labour Code applies to small crews too. The scale of the work affects the requirement for a BIOZ plan under the Construction Law, but the OSH coordination obligation between different employers does not depend on the size of the firms.

Ready-made coordination documents - the STANDARD package

The coordinator appointment, the cooperation agreement, the coordination records - you can draft it yourself or take the ready-made templates and enter the firms' data.

The STANDARD package (449 zł, 27 files) contains organisational OSH documents for a construction micro-business under PKD 43 (Polish business activity code), in Polish and Ukrainian. Do you go onto large sites and need the full coordination documentation, BIOZ plan and IBWR (safe work procedures)? Take FULL (749 zł, 45 files). To get started, there is STARTER (299 zł, 10 files).

The promotion runs until 7 July 2026 - just before the PIP reform. See BudoReady packages and have the coordinator appointment ready before three crews meet on your site.

This article is for information only and does not replace advice from an OSH specialist or the current legal position. Document templates require individual adaptation to the reality of your company and specific workstations, and the current legal position should be verified as at the date of use.