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Is a CPCS A78 or NPORS N021 card a legal requirement?

Health and Safety at Work etc. Act 1974, section 2, places a duty on employers to ensure, so far as is reasonably practicable, the health and safety of employees at work. That duty is about competence, not paperwork, and it falls on whoever puts an operator in charge of a vacuum excavator working near a buried service.

No statute names CPCS A78 (Construction Plant Competence Scheme card for vacuum excavation) or NPORS N021 (National Plant Operators Registration Scheme card for vacuum excavation) as a condition of operating the machine. Neither card is a licence in the sense that a driving licence is. Both exist because the industry needed a shared way to demonstrate competence without every principal contractor running its own assessment, and that is the gap they were built to fill.

What the card stands in for

A card shows that an operator was tested against a defined scope on a particular date. It does not show that the same operator is competent on the asset in front of you, in that ground, on that day. The card is evidence towards the section 2 duty, not a substitute for it, and the duty still sits with whoever is putting the operator to work.

Where a scope of works sets a required card level for the operator, that requirement can be written down and checked before the machine arrives. See the clause wording on Specifying It in a Scope of Works for how that line is usually drafted.

What a CPCS A78 or NPORS N021 card actually tests

CPCS A78 (Construction Plant Competence Scheme card for vacuum excavation) and NPORS N021 (National Plant Operators Registration Scheme card for vacuum excavation) are the two scheme cards issued for this work. Both follow a theory and practical assessment of the operator's control of the machine and safe working around excavations.

What the card proves

A card in date shows the holder passed that assessment on the date it was issued. It confirms the operator was tested on running the equipment safely and on the general principles of working near buried services.

What it does not prove

  • That the operator has read the asset owner's specification governing this particular dig.
  • That the operator's competence has been reassessed since the card was issued.
  • That the operator is familiar with the ground conditions or the asset type in front of them today.

Why the card is not the whole answer

CPA SAVESIG GPG1 v3 (January 2025), section 4.6, states that scheme cards should not be accepted at face value. The card confirms a test was passed once. It does not confirm the assessment still holds, or that it covered the asset being dug near on this job. That gap is why the card is a starting point for a competence check.

On-site checks

What to check before the operator starts work

A card tells you a test was passed at some point. These checks are for finding out whether the person in front of you is right for this ground, this asset and this job.

  • Ask for the operator's own current card

    CPCS A78 and NPORS N021 are dated and named to the individual on site. A card issued to someone else, or one that has lapsed, does not stand in for the person in front of you.

  • Check what the card's test actually covered

    Both schemes list what the assessment covered and what it did not. A card is not proof of competence on ground conditions, asset types or techniques outside that scope.

  • Verify the card against the scheme's own register

    CPA SAVESIG GPG1 v3 (January 2025) section 4.6 states that scheme cards should not be accepted at face value. Both schemes offer a way to check a card's status against the register, and that check is separate from reading the card itself.

  • Ask what asset-specific training the operator holds

    A vacuum excavator operator working near live gas, electricity or water assets needs induction or training specific to that asset owner's plant-protection specification, which a general excavation card does not cover.

  • Ask the operator to state where their experience runs out

    Where the ground, service depth or technique falls outside what the operator has done before, ask them to say so before work starts.

  • Keep a record that the check was made

    The legal duty under the Health and Safety at Work etc. Act 1974 section 2 sits with the employer, and a card held by the operator does not discharge the buyer's own responsibility to have made this check.

See the earlier section on this page for what CPCS A78 and NPORS N021 actually test before treating either card as settled.