DRHS Explained: The Director's Role for Health and Safety

Most construction training is aimed at the people on site: operatives, supervisors and managers. The Director's Role for Health and Safety course, usually shortened to DRHS, points in the other direction. It is aimed at the people in the boardroom, because in the eyes of the law, health and safety failures are very often leadership failures.

This guide explains why directors carry personal legal exposure, what the DRHS course covers, and how to prepare for the end-of-course assessment.

Why Directors Cannot Delegate Their Way Out

A limited company is a separate legal person, and many directors assume that this shields them personally when something goes wrong. For health and safety, that assumption is dangerous. The legal framework is deliberately constructed so that organisations and the individuals who direct them can both be held to account, and the courts have shown consistent willingness to look up the chain of command when serious incidents occur.

Directors set budgets, appoint people, approve programmes and shape culture. Those decisions determine whether sites are adequately resourced, whether competent people are in post, and whether commercial pressure is allowed to override safe systems of work. The DRHS course exists because the law recognises this reality and holds leadership responsible for it.

Section 37 of the Health and Safety at Work etc. Act 1974

The provision at the centre of the course is section 37 of the Health and Safety at Work etc. Act 1974. Where an offence under the Act is committed by a body corporate, and it is proved to have been committed with the consent or connivance of, or to be attributable to any neglect on the part of, a director, manager, secretary or similar officer, that individual is guilty of the offence as well as the company.

Those three words are worth understanding precisely, because assessment questions turn on them:

• Consent means the director knew what was happening and agreed to it.
• Connivance means the director knew and turned a blind eye, allowing it to continue.
• Neglect means the director should have known and should have acted, but failed to do so. Ignorance is not a defence where the director had a duty to be informed.

Convicted individuals face fines and, for many offences, imprisonment. Directors can also be disqualified from holding directorships under the Company Directors Disqualification Act 1986. The message of section 37 is blunt: a director cannot outsource accountability to a safety adviser or a paper management system.

The Duties the Company Owes

Section 37 bites when the company itself commits an offence, so directors also need a working grasp of the underlying duties. Section 2 of the Act requires every employer to ensure, so far as is reasonably practicable, the health, safety and welfare at work of its employees. Section 3 extends a similar duty to people who are not employees but who may be affected by the way the business is conducted, which in construction means subcontractors, visitors, neighbours and members of the public.

The phrase so far as is reasonably practicable matters. It requires duty holders to weigh risk against the sacrifice needed to control it, and to control risks unless the cost, time and effort are grossly disproportionate to the benefit. Directors are the people who decide what resources are available, which is exactly why the law will not let them stand apart from the outcome. Practical guidance on these duties is published by the Health and Safety Executive.

The Corporate Manslaughter and Corporate Homicide Act 2007

The second pillar of the DRHS syllabus is the Corporate Manslaughter and Corporate Homicide Act 2007. This created an offence committed by organisations, not individuals: an organisation is guilty where the way its activities are managed or organised causes a person's death and amounts to a gross breach of a relevant duty of care owed to the deceased.

Two features of the Act deserve particular attention. First, the way activities are managed or organised by senior management must be a substantial element of the breach, which places boardroom behaviour directly in scope. Second, a gross breach means conduct falling far below what could reasonably be expected, and juries may consider the organisation's attitudes, policies, systems and accepted practices, in other words its culture.

Conviction carries an unlimited fine, and courts can impose remedial orders requiring failures to be fixed and publicity orders requiring the conviction to be publicised. Although individuals cannot be charged under this Act itself, directors gain no comfort from that: individual prosecution remains available under section 37 and, in the most serious cases, for gross negligence manslaughter under the common law.

Leading Health and Safety: Plan, Deliver, Monitor, Review

DRHS is not only about liability. The larger part of the course is about what good leadership actually looks like, and it draws on the joint guidance for directors published by the Health and Safety Executive and the Institute of Directors, which structures board-level responsibility around four activities:

1. Plan. The board sets the direction: a clear policy, ownership of health and safety at board level, and integration of safety into business decisions rather than treating it as an add-on.
2. Deliver. Plans are resourced and implemented: competent people, adequate budgets, sensible procurement, and management systems that reflect how work is really done.
3. Monitor. The board receives meaningful information: not just accident statistics after the event, but leading indicators such as inspection findings, training completion and the results of audits.
4. Review. Performance is formally reviewed and lessons genuinely change behaviour, so the system improves rather than merely existing.

Assessment questions frequently describe a board that has a written policy but no monitoring, or a director who signs off a system and never asks about it again, and invite you to identify what is missing. The plan, deliver, monitor, review cycle is the framework for answering them.

Who Should Take the DRHS Course?

The course, part of the CITB Site Safety Plus suite whose scheme rules are published by CITB, is designed for directors, partners, business owners and senior managers who shape company policy and resources. It is particularly valuable for directors of growing contractors, where informal arrangements that worked for a handful of employees no longer stand up to legal scrutiny, and for newly appointed board members inheriting responsibility for an existing management system they did not build.

Preparing for the DRHS Assessment

The DRHS assessment rewards candidates who can connect legal principles to boardroom scenarios. When you revise, anchor each principle to a question a director should be asking: Do I know what our significant risks are? Would our monitoring tell me if controls were failing? Could I evidence the resources and competence behind our arrangements?

Practice questions are the quickest way to test whether that understanding is genuine. Work through CITB-style mock tests under timed conditions and study the explanations for every answer, right or wrong. If you want a deeper look at how CITB-style multiple-choice questions are constructed, and the traps they set, our guide to SMSTS practice questions breaks down the question styles in detail, and the same patterns appear throughout Site Safety Plus assessments.

Final Thoughts

Health and safety leadership is not a compliance chore; it is one of the clearest tests of whether a board actually controls its business. Section 37 and the Corporate Manslaughter Act define the downside, but the plan, deliver, monitor, review cycle defines the job. The DRHS course gives directors the legal grounding and the practical framework in a single sitting, and with some focused mock test preparation beforehand, the assessment should confirm what the day has taught you rather than catch you out.