CSCS Responds to ‘Unexpected’ CISRS Notice to Withdraw from Card Scheme

In a statement, the Construction Skills Certification Scheme (CSCS) confirms it has received an “unexpected” formal notice from the Construction Industry Scaffolders Record Scheme (CISRS) to end its use of the CSCS logo on cards issued to its members.

The CSCS logo allows scaffolders to gain access to construction sites that use the cards to check the identities and qualifications of cardholders and restrict access to only those competent and qualified to be on site.

The CISRS cardholders will no longer be issued with a CSCS logoed card from 31 May 2027.

It follows CISRS’s objection to Clause 4 of the Construction Leadership Council’s (CLC) Industry Card Schemes rules (issued in March 2024), which states: “Cards will not be issued for non-construction related occupations or those visiting sites.”

Negotiating Move

National Access & Scaffolding Confederation (NASC) President, Sarah Klieve, says CISRS served notice on CSCS in order to seek a resolution “from a stronger negotiation position.”

Klieve said the Clause 4 wording “is incompatible with the issuing of cards for the non-construction work that makes up so much of the scaffolding and access industry.”

“Construction is only one of the sectors to which scaffolding and access are essential: the industry needs a certification scheme that is applicable to all the projects on which scaffolders work and all the places in which they work,” she said.

CISRS has said it would withdraw the notice if Clause 4 is reworded.

Wrong Interpretation

Yet CSCS says it “does not share that interpretation and, importantly, neither do a number of key organisations across the industry.”

“We have sought clarification from the Construction Leadership Council, employers, trade unions and scaffolding contractors. The consistent assurance we have received is that Clause 4 does not prevent CISRS from continuing to operate under its existing CSCS licence, nor does it change the industry’s expectation that appropriately qualified workers undertaking scaffolding activities in construction should hold CSCS-logoed cards.”

This position has also been reinforced by Build UK. In a letter to NASC, Build UK’s Chair has confirmed that there is no intention to prevent scaffolding occupations from working in sectors outside construction.

Build UK says it will continue to support the CLC recommendation following clarification of the intent behind Clause 4.

Unite the Union has also reaffirmed its support for the recommendation.

The CSCS statement continues: “Scaffolding is an occupation undertaken extensively within construction. The fact that scaffolding skills are also required in other sectors does not mean that scaffolders working in construction should no longer have access to a CSCS-logoed card.”

“Other CSCS Alliance schemes successfully accommodate occupations that operate across several industries by providing CSCS-logoed cards for construction and, where appropriate, alternative non-logoed cards for work outside construction.

“We therefore do not believe Clause 4 prevents CISRS from continuing within the existing licensing arrangements.

“It is also important to recognise that the underlying principle is not new. Equivalent wording relating to non-construction occupations has featured in CLC requirements published in 2017, 2020 and 2024. CISRS has operated as a CSCS Alliance scheme throughout that period and had not previously identified this as creating a conflict with its licence – we can’t see what has changed since 2017, CISRS need to explain.”

Legal Advice

CISRS has advised CSCS that it has taken legal advice which reaches a different conclusion, but has not shared the advice with CSCS.

CSCS comments: “Without understanding the basis of that interpretation, it is difficult for us to assess the issue properly or explore whether any practical solution is required.

“If there is a genuine conflict, we want to understand it. CSCS remains willing to work constructively with CISRS to examine the issue and, where necessary, identify a solution. No one wants to be in this position, particularly given the potential consequences for cardholders, employers and the wider scaffolding sector.

Supporting Cardholders

“CSCS’s immediate priority is to support the thousands of existing cardholders, apprentices, employers, training providers and others who rely on established carding arrangements. Any transition must therefore be controlled, orderly and properly communicated.

“It would be premature to speculate about future arrangements until CISRS has provided its proposed withdrawal and transition plan. Wider communications to industry will follow once that has been received and considered by CSCS in its capacity as Licensor.

“Whatever future carding arrangements emerge, employers and contractors will continue to have responsibilities under the Construction (Design and Management) Regulations and other applicable requirements to ensure that people working on construction sites are appropriately trained, qualified and competent.”

CISRS and NASC are consulting its members on the subject in a webinar at 10am on Thursday 8 October. Registration is on the NASC website.

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