Can You Legally Run Health and Safety Training Without Accreditation?

This is one of the most asked questions among independent OHS practitioners and consultants in South Africa, and the answer is more nuanced than the regulators or training bodies usually admit. The short version is that you can run health and safety training without QCTO accreditation - but only within specific limits, and crossing those limits without realising it can damage both your client and your professional standing.

The short answer

Yes, you can legally deliver health and safety training without QCTO or SETA accreditation. The OHSA does not require an accredited training provider for general workplace OHS training. What it does require is that the training is fit for purpose, delivered by a competent person, and documented.

What you cannot do

• Issue NQF-aligned certificates of competence
• Award credits towards a qualification
• Contribute towards BBBEE skills development scoring (which requires accredited delivery)
• Deliver Construction Regulations 7 mandatory training where the regulator specifies accredited material
• Run programmes whose content is reserved for HPCSA-registered practitioners (e.g. clinical procedures beyond first aid scope)

What you can do

Run general OHSA induction, toolbox talks, supervisor development, hazard awareness, and a wide range of internal training, issued as Certificates of Attendance or Certificates of Completion. These are perfectly legal and widely used. The market for non-accredited training is large and underserved - many companies need exactly this kind of training and have no requirement for an NQF certificate.

Specific examples of legitimate non-accredited training:

• OHSA induction for new employees
• Site-specific safety briefings
• Hazard identification and risk assessment basics for non-OHS staff
• Supervisor competency development
• Contractor compliance briefings
• Behaviour-based safety programmes
• Topic-specific awareness sessions (ergonomics, mental health at work, fatigue management)

When accreditation actually matters

The moment your client requires an NQF-registered outcome, BBBEE scorecard credit, or a registered occupational qualification, the conversation changes. Without accreditation, you cannot serve those needs. Some sectors - mining, construction, hazardous chemical handling - also have explicit regulatory requirements for accredited training under specific legal frameworks.

Certificate templates and what to put on them

A Certificate of Attendance is not a Certificate of Competence. The distinction must be visible on the document. Best practice for non-accredited certificates:

• Heading clearly states "Certificate of Attendance" or "Certificate of Completion" - never "Certificate of Competence"
• Date, duration and topic of the training
• Trainer name, signature and credentials
• Learner full name and ID number
• Disclaimer noting the training is not NQF-aligned
• No SAQA logo, no NQF level, no credit value

Misuse of NQF terminology, SAQA logos or accreditation marks on a non-accredited certificate is a SAQA Act offence and a fast route to professional disciplinary action.

Competency requirements for the trainer

"Competent person" under the OHSA is a defined term. The trainer must have the relevant knowledge, training and experience, and where regulations specify a particular qualification, the trainer must hold it. For most general OHS training, registration with a recognised body such as Saiosh, IOSH or the SACPCMP demonstrates competency. Where the training touches on regulated specialty areas, the regulator's specific competency requirements apply.

Documentation and record-keeping

The training itself satisfies the OHSA duty only if it is documented. Records must include:

• Attendance register signed by every learner
• Date, duration and topic
• Trainer credentials
• Lesson plan or summary of content covered
• Assessment if any was used (even informal post-training quizzes)
• Copy of the certificate issued

The DEL inspector will ask for these records during any post-incident inspection or compliance audit. Missing records mean the training effectively did not happen, regardless of the trainer's quality or the learner's recall.

Professional indemnity

Non-accredited trainers should still carry professional indemnity insurance. The advice you give in a training session is professional advice, and an incident later linked to that advice can generate a claim. Cover is inexpensive relative to the exposure - typically R6 000 to R15 000 a year for a sole-practitioner consultant.

Building a hybrid practice

The most common successful model is a hybrid: a non-accredited training arm for daily compliance and consultancy work, paired with a partnership or referral relationship with an accredited SDP for the qualification work. The non-accredited side moves quickly and serves the daily client need; the accredited partner handles the formal NQF outcomes when they are required. This keeps overhead low while still capturing the full revenue opportunity.

For the underlying legal references, a clear breakdown of the OHSA training duty, and a sample compliant certificate template, Intrasafe explains the framework in detail.