Major maintenance events, shutdowns and turnarounds create a question that regularly causes confusion: who is responsible for rescue arrangements, the client or the contractor? 

The short answer is that both parties have responsibilities, but they are not necessarily the same responsibilities. UK health and safety legislation does not allow duty holders to simply transfer all responsibility to another organisation through a contract. Instead, clients and contractors must work together to ensure that suitable emergency and rescue arrangements are planned, resourced and coordinated before work begins. 

This becomes especially important on power stations, energy-from-waste facilities, petrochemical sites and other high-hazard environments where confined spaces, work at height, hazardous atmospheres and complex access arrangements are common. During a shutdown, multiple contractors may be working simultaneously across dozens of work fronts, making rescue planning considerably more complex than during routine operations. 

Poorly defined rescue responsibilities can create dangerous gaps in capability. Equally, duplicated arrangements can waste resources and introduce confusion during an emergency. 

What Does UK Law Actually Require? 

Several pieces of UK legislation influence rescue responsibilities. 

The Health and Safety at Work etc. Act 1974 places general duties on employers to protect employees and others who may be affected by their work. 

The Management of Health and Safety at Work Regulations 1999 require employers to assess risks and establish appropriate procedures for serious and imminent danger. 

For high-risk activities, more specific regulations apply: 

• Confined Spaces Regulations 1997 require adequate emergency arrangements before entry takes place. 

• Work at Height Regulations 2005 require rescue arrangements where workers could fall and be suspended or otherwise unable to self-rescue. 

• CDM Regulations 2015 require cooperation, coordination and the sharing of information between duty holders. 

A key point often overlooked is that rescue arrangements must be planned before work starts, not after an incident occurs. 

The HSE is also clear that organisations should not assume the emergency services can provide the primary rescue capability. In many situations, particularly confined spaces, rescue must be available immediately and be capable of reaching the casualty without delay. 

Can the Client Transfer Rescue Responsibility to a Contractor? 

Not entirely. 

A client may appoint a specialist contractor to provide rescue teams, rescue equipment or emergency response services, but this does not eliminate the client's responsibility to ensure suitable arrangements exist. 

A simple way to view it is: 

• The client remains responsible for ensuring the site has appropriate emergency arrangements and coordination. 

• The contractor remains responsible for ensuring their work can be carried out safely and that the rescue arrangements supporting their activities are suitable. 

Neither party can rely solely on contractual wording to remove their legal duties. 

If an incident occurs and rescue arrangements are proven inadequate, regulators will often examine the actions of both organisations. 

What Rescue Responsibilities Normally Sit With the Client? 

At shutdown sites, the client typically controls the location, infrastructure, permit systems and overall emergency management framework. Typical client responsibilities include: 

Defining Site Emergency Expectations 

The client should identify: 

• Site emergency procedures 

• Muster arrangements 

• Communication methods 

• Medical response arrangements 

• Access and egress routes 

• Site-specific hazards 

Contractors need this information before developing their own rescue plans. 

Coordinating Multiple Contractors 

One contractor's rescue operation may affect several others. For example, a rescue from a boiler, absorber, tank or flue may require: 

• Area isolation 

• Traffic management 

• Lifting restrictions 

• Emergency access routes 

• Temporary suspension of nearby work 

Only the client typically has the authority to coordinate these interfaces across the entire project. 

Reviewing Proposed Rescue Arrangements 

Clients should be able to demonstrate that they have reviewed proposed rescue arrangements and determined whether they are compatible with the site's hazards and emergency response framework. 

This does not necessarily mean checking every technical detail, but it does mean ensuring that appropriate competence and capability exist. 

What Rescue Responsibilities Normally Sit With the Contractor? 

Contractors typically understand their work activities better than anyone else. As a result, they are usually responsible for demonstrating how casualties will be rescued from the hazards they create or control. 

Activity-Specific Rescue Planning 

A contractor carrying out: 

• Vessel entry 

• Tank inspection 

• Scaffold erection 

• Structural maintenance 

• Rope access work 

• Boiler repairs 

must consider how rescue would be achieved for those tasks. The rescue plan should address realistic emergency scenarios rather than generic statements. For example, “call the emergency services” is rarely an adequate confined space rescue plan. 

Providing Competent Resources 

Where the contractor is responsible for rescue delivery, they should provide: 

• Competent personnel 

• Appropriate rescue equipment 

• Suitable training 

• Adequate supervision 

Capability should match the identified risk. A simple vertical entry into a shallow tank may require a different rescue capability than work taking place deep within a large boiler structure requiring breathing apparatus. 

Verifying Arrangements Remain Suitable 

Shutdowns change rapidly. Scaffolding changes, routes become blocked, work scopes expand and access arrangements evolve. Contractors should regularly verify that rescue plans remain valid as conditions develop. 

What Happens When a Specialist Rescue Provider Is Used? 

Many shutdowns now involve specialist rescue providers supporting multiple contractors across a site. This model can offer significant advantages because it centralises rescue competence and reduces duplication. However, it can also create confusion if responsibilities are not clearly documented. 

The most effective arrangements typically define: 

• Who develops rescue plans 

• Who approves them 

• Who supplies equipment 

• Who provides rescue personnel 

• Who maintains rescue readiness 

• Who coordinates response during an incident 

The rescue provider may supply the capability, but both client and contractor still retain responsibilities relating to planning, cooperation and communication. 

Why Shutdowns Create Additional Rescue Challenges 

A rescue arrangement that works perfectly during normal operations may be completely unsuitable during a turnaround. Consider a large energy-from-waste outage. 

During routine operations, there may be: 

• Limited confined space entries 

• Stable plant access routes 

• Known occupancy levels 

• Fixed emergency arrangements 

During a shutdown there may be: 

• Hundreds of additional workers 

• Multiple simultaneous confined space entries 

• Temporary access structures 

• Additional hazards 

• Restricted vehicle access 

• Rapidly changing work fronts 

As workload increases, rescue demand can increase faster than many organisations expect. The key question becomes not simply whether rescue exists, but whether sufficient rescue coverage exists to support all the planned activities happening at the same time. 

What Does Good Practice Look Like? 

Successful shutdown projects usually address rescue responsibilities during the planning phase rather than mobilisation. A practical approach is to: 

1. Identify all rescue-relevant activities. 
2. Determine foreseeable rescue scenarios. 
3. Define client and contractor responsibilities. 
4. Establish rescue capability requirements. 
5. Confirm equipment and personnel resources. 
6. Validate communication arrangements. 
7. Review interfaces between work fronts. 
8. Exercise or rehearse critical rescue scenarios. 
9. Reassess arrangements as the outage evolves. 

Most importantly, responsibilities should be documented rather than assumed. If two parties both believe the other is responsible, the project may effectively have no rescue provision at all. 

Conclusion 

The question is not whether rescue responsibility belongs to the client or the contractor. On high-hazard shutdowns, both have duties that must be fulfilled. 

The client is responsible for ensuring appropriate site-wide emergency arrangements, coordination and oversight. The contractor is responsible for ensuring their activities can be carried out safely and that suitable rescue arrangements exist for the work being undertaken. Where specialist rescue providers are involved, responsibilities must still be clearly defined and actively managed. 

For maintenance managers, site managers and HSE leaders, the most important principle is simple: rescue arrangements should be planned as an operational requirement, not treated as a permit box to tick. When responsibilities are agreed early, properly resourced and coordinated across the project, rescue capability becomes an enabler of safe and efficient execution rather than a last-minute challenge. 

Suggested CTA 

Planning a shutdown, turnaround or major maintenance event? Review rescue responsibilities before mobilisation begins. A structured rescue strategy that clearly defines client, contractor and specialist provider responsibilities can reduce risk, improve coordination and help keep the project on programme. Contact Breathe to discuss rescue planning, confined space management and integrated safety support for high-hazard maintenance projects.