📋 TL;DR - Businesses with fewer than 50 employees are subject to the Serious Disaster Safety Act from January 27, 2024. - The original company's evaluation of the subcontractor's safety and health focuses on 'execution records' (risk assessments, opinion gathering, semi-annual inspections), not just forms. - The order of preparation should be re-doing the risk assessment → opinion gathering records → semi-annual inspection checklist → budget & emergency manual.
Table of Contents 1. One evaluation form from the original company 2. The file was thick, but there were no records 3. What the law requires, what the original company asks 4. What I did for 3 weeks 5. Evaluation results and remaining tasks
I am an administrative agent based in Yeongu, Incheon. I would like to introduce one anecdote I encountered while working to my neighbors.
The first page of the file was 'Safety and Health Management Policy'. The representative's signature was neat, but the date next to it was 2 years ago. There was nothing else after that.
## 1. One evaluation form from the original company
The client was a woman in her 30s, managing operations at a metal processing factory in Incheon. It was a factory founded by her father, with 23 employees. Most of the revenue comes from a single primary client supplying parts.
The primary client requested a 'Cooperative Company Safety and Health Level Assessment.' The submission deadline was three weeks. It included a notice stating that failure to meet the score would result in suspension of the cooperative company registration renewal. In other words, the livelihoods of the 23 employees were at stake depending on that registration.
She initially prepared it herself. She filled out the management policy, organizational chart, and emergency contact information using forms she found online and submitted it for a preliminary inspection. The feedback she received was brief: "Documents are present, but verification of implementation is unavailable." It was then that she applied for a phone consultation and scheduled an appointment for the Thursday afternoon of that week.
## 2. The file was thick, but the records were missing
The binder you brought was thick. The problem was that most of it was blank forms.
- Risk Assessment: One result sheet from an external company two years ago. The two pieces of equipment have been changed, but it's not reflected.
- Employee Opinion Hearing: No record.
- Semi-Annual Inspection: No record.
- Safety Budget: There are receipts for gloves and safety glasses, but no document organized as a 'budget'.
This was the result of the prime contractor's representative scoring according to the manual. Most of the questions on the evaluation form were "Are you doing ~, and is there a record of it?". There were fewer items asking whether a document exists than I expected.
## 3. What the Law Requires, What the Prime Contractor Asks
First, I separated the legal obligations from the prime contractor's requests. Because if I mixed them, I wouldn't be able to finish it in 3 weeks.
Article 4 of the “Serious Accidents Punishment Act” imposes an obligation on business owners to establish and implement a safety and health management system. Simply put, it means that both 'making it' and 'actually running it' are required. The Enforcement Decree details this with procedures for identifying hazardous and dangerous factors, procedures for hearing employee opinions, budget allocation, emergency response manuals, and attaches semi-annual inspections or more to a considerable number of items.
Also, the risk assessment under Article 36 of the “Industrial Safety and Health Act” must be conducted with the participation of employees and the results must be recorded and preserved (for 3 years).
When I compared the prime contractor's evaluation form to this framework, 14 out of 20 questions were essentially the same. Did you find the risks? Did you ask the employees? Did you inspect? The things to prepare were not 20 types of documents, but reduced to 4 bundles of execution records.
## 4. What I Did for 3 Weeks
✅ Week 1 — Re-doing the Risk Assessment I started with the two changed pieces of equipment. The assessment itself was done by the factory manager and site staff, and I was in charge of organizing the results according to the form and recording who participated. I provided information on the Small Business Support System of the Korea Occupational Safety and Health Agency for parts requiring technical judgment. From the beginning, I clearly explained the boundaries of what an administrative agent can and cannot do.
✅ Week 2 — Opinion Gathering and Near-Miss Reporting We put a 'Near-Miss Memo Box' in the break room and decided to keep the monthly meetings as Opinion Gathering Meeting Minutes. The first memo was put in by the factory manager. The content was: "Slippery floor in front of the coffee machine, almost slipped twice." ☕ Everyone laughed, but that memo became Action Record No. 1. It took three days to lay down one mat.
✅ Week 3 — Mid-Year Checklist, Budget, and Emergency Manual I gathered scattered receipts and consolidated them into a single 'Safety and Health Budget Execution Record'. This was essentially making the already spent money appear as a budget document, so there was little need to spend any new funds. The fire and entanglement accident response manual was reduced to two sections, aligning with the actual emergency exit routes.
## 5. Evaluation Results and Remaining Tasks
The evaluation result was 'Conditionally Suitable'. The only remaining issue was the lack of emergency evacuation drill records. We conducted a drill a month later, supplemented the records with photos and an attendance list, and received a 'Suitable' rating. The cooperative company registration was also renewed.
Ironically, the points were awarded not for thick stacks of forms, but for a few thin meeting minutes. Mid-year checks are now firmly on the calendar. The plant manager takes care of them in March and September.
If you find yourself in this situation, check the following first 1. Has the risk assessment been updated after changes to equipment and processes? 2. Are there records of employee feedback dated by date? 3. Are there mid-year inspection records? 4. Have the safety expenses already spent been organized into a budget document?
If you received a similar evaluation request from small businesses in Incheon Yeongu and surrounding areas, I’ll help you organize the steps to take. Requirements vary depending on the case, so individual verification is necessary.
This article is reconstructed based on actual consultation cases, and the characters, names, place names, and figures appearing therein are not related to any specific individual or event.
We are an administrative agent office located in Songdo, Incheon (Posco Tower Songdo). We handle administrative litigation, licensing/reporting agency, foreign entry and residence (visas and stay), and regular administrative management. We also assist small businesses in the vicinity of Incheon Yeongu with organizing and submitting safety and health documents to government offices. Feel free to leave an inquiry if you are in a similar situation.
📍 165, Convencia-daero, Yeongu, Incheon, Posco Tower Songdo 2697 📞 010-3374-2687 🌐 www.hwangadmin.com
