[질의회시집] 250601 건설업 산업안전 보건관리비 해설 및 질의회시집

250601 건설업 산업안전 보건관리비 해설 및 질의회시집.pdf

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2024년 1월 해설집 발간 이후 여러 차례 「건설업 산업안전보건관리비
계상 및 사용기준」이 개정되어 최근 2025년 2월 12일 개정된 고시
까지 반영하여 해설집 및 질의 회시집을 새로이 발간하였습니다.
< 고시 주요 개정 내용 >
1. 공사종류 분류 전면개편(’24.7.1~) 및 요율 인상(’25.1.1~)
 「건설산업기본법」 등 건설 관련법령을 기초로 하여 △건축공사,
△토목공사, △중건설공사, △특수건설공사로 전면 재분류
 공사특성을 반영한 산업안전보건관리비 계상 요율 인상(평균19%)
2. 스마트 안전장비 구입·임대비 확대
 임대·구입비용 인정 : ’24년(40%) → ’25년(70%) → ’26년(100%)
 산안비 총액의 사용한도 : 종전 10% → 20%(’25.2.12~)
3. 모든 연간 단가계약 공사의 총계약금액이 2천만원 이상일 경우 산업안전보건관리비 의무계상(’25.1.1~)
4. 노·사 발굴항목 사용한도 확대
 산안비 총액의 사용한도 : 종전 10% → 15%(’25.2.12~)
5. 온열·한랭질환 예방을 위한 간이 휴게시설, 냉난방기 임대 등 품목 신설(’25.2.12~)
6. 자율안전 확인대상 보호구(안전모, 보안경, 보안면) 추가(’25.2.12~)
7. 산업재해 예방이 주된 목적인 교육에 소요되는 비용 인정(’25.2.12~)
8. 주요 질의회신 Q&A 개선
 기존 질의회신 현행화 및 신규(안전관리자 제도 추가 등) 질의회신 반영


CONTENTS
건설업 산업안전보건관리비
해설 및 질의회시집
01 해설집 ·········································································· 1
Ⅰ. 총 칙 ········································································································ 2
Ⅱ. 산업안전보건관리비의 계상 등 ································································· 5
Ⅲ. 산업안전보건관리비의 사용 ···································································· 25
Ⅳ. 산업안전보건관리비의 확인 ···································································· 36
Ⅴ. 산업안전보건관리비의 정산 ···································································· 38
Ⅵ. 목적 외 사용금액에 대한 감액 등 ························································· 41
Ⅶ. 위반 시의 조치 ······················································································ 42

02 산업안전보건관리비 고시문 ········································ 45
제1장 총칙 ··································································································· 46
제2장 산업산업안전보건관리비의 계상 및 사용 ··········································· 48
제3장 보칙 ··································································································· 53
부칙 ·············································································································· 54
[별표1] 공사종류 및 규모별 산업안전보건관리비 계상기준표 ····················· 55
[별표1의2] 관리감독자 안전보건업무 수행 시 수당지급 작업 ····················· 56
[별표1의3] 설계변경 시 산업안전보건관리비 조정·계상 방법 ·····················57
[별표2] 삭제 ································································································· 58
[별표3] 공사진척에 따른 산업안전보건관리비 사용기준 ···························· 58
[별표4] 삭제 ································································································· 59
[별표5] 건설공사의 종류 예시표 ·································································· 59
[별지1] 산업안전보건관리비 사용내역서 ···················································· 61
[별지2] 삭제 ······························································································· 71

03 주요 질의 회신 Q&A ················································ 73
제1장 총직(정의 및 적용범위) ···················································· 74
1) 단가 계약형태의 모든 공사는 산업안전보건관리비를 계상해야 하는지 ·· 75
2) 2개 현장의 산업안전보건관리비를 통합하여 사용 가능한지 ············· 76
3) 용역 계약도 산업안전보건관리비를 계상해야 하는지 ························ 77
4) 해외 건설공사도 산업안전보건관리비를 계상해야 하는지 ················· 78
제2장 계상의무 및 기준 ····························································· 79
1) 완제품에 해당하는 물품이 무엇인지 ·················································· 80
2) 발주자가 제공하는 관급자재비를 제외하고 계상하면 되는지 ············ 81
3) EPC 공사는 총공사금액으로 계상하는지 ··········································· 83
4) 공사내역이 구분되어 있지 않은 경우 계상방법은 ····························· 85
5) 차수분 계약도 ’25.1.1부터 적용하는 비율을 적용해도 되는지 ··········· 86
6) 5억원 이상 50억원 미만 구간에 기초액을 두는 사유 ······················ 87
7) 수의계약의 경우 산업안전보건관리비를 공지하는 방법은 ················· 88
8) 산업안전보건관리비에 낙찰률 적용이 가능한지 ································· 89
9) 산업안전보건관리비 계상 대상 건설공사의 종류 및 담당 기관은 ···· 90
10) 반도체공장 건설공사는 공사종류 중에 어디에 해당 되는지 ············· 91
11) 주된 공사와 부대하는 공사, 시간적·장소적으로 독립하는 공사의 기준이 무엇인지 ·················································································· 92
12) 설계변경시 당초 대상액(설계금액&낙찰금액) 기준이 무엇인지 ········ 93
13) 공사종류 개편(’24.7.1)이전 공사의 설계변경시 비율 적용은 ············94
14) 50억원 미만 공사가 설계변경으로 50억원 이상 공사로 변경된 경우 계상방법 ······························································································· 95
15) 공사금액이 800억원 이상으로 변경된 경우 설계당시 금액, 공정률도 고려해서 재계상 하는지 ······································································ 96
16) 토목공사는 설계변경으로 공사비가 1,000억원 이상 증액시 요율표를 참고하여 재계상 하면 되는지 ····························································· 97
17) 턴키공사에서 산업안전보건관리비가 과소 계상되었을 경우 추가계상이 가능한지 ·················································································· 98

제3장 사용기준 ··········································································· 99
1. 안전관리자·보건관리자 임금 등 ········································ 99
1) 안전관리자 임금 지급 기준일을 언제로 보면 되는지 ····················· 100
2) 안전관리자 임금에 포함되는 건강보험료 등도 안전·보건관리자 임금 항목으로 사용 가능한지 ···································································· 101
3) 안전관리자 퇴직금을 안전·보건관리자 임금 항목으로 사용가능한지
··········································································································· 102
4) 안전관리자 연차수당 정산은 근무한 현장에서 하는게 맞는지 ············ 103
5) 안전관리자를 공동 선임하였을 경우 현장별 임금 분담 비율은 ····· 104
6) 관계수급인(100억원 미만)이 안전관리자를 선임한 경우 임금을 안전·보건관리자 임금 항목으로 사용 가능한지 ······························ 105
7) 안전보조원 교육 출장시 임금 및 출장비를 안전‧보건관리자 임금 항목으로 사용 가능한지 ··························································· 106
8) 안전관리자 선임 의무가 없는 현장에서 화재감시자 등 임금을 안전·보건관리자 임금 항목으로 사용 가능한지 ······························ 107
9) 임금을 받고 있는 근로자가 산재예방업무를 일부 수행한 경우 해당 기간에 대한 임금을 안전·보건관리자 임금 항목으로 사용 가능한지 ··········· 108
10) 작업지휘자 임금을 발주자가 인정하는 작업내용에 대해서만 안전·보건관리자 임금 항목으로 사용 가능한지 ······································· 109
11) 관리감독자 업무수당 지급을 위한 기준이 있는지 ··························· 110

2. 안전시설비 등(스마트안전 장비 구입·임대등) ················ 111
1) 추락안전매트 설치비용을 안전시설비 항목으로 사용 가능한지 ··········· 112
2) 전산볼트용 추락방지대 구입비를 안전시설비 항목으로 사용 가능한지 ····························································································· 113
3) PHC 말뚝 상부 덮개 구입비를 안전시설비 항목으로 사용가능한지 · 114
4) 텅스텐 논슬립 구입비를 안전시설비 항목으로 사용 가능한지 ··········· 115
5) 전기, 정보통신 등의 공사에서 교통안전표지판 설치비용을 안전시설비 항목으로 사용 가능한지 ···································································· 116
6) 지게차 방호장치 설치비를 안전시설비 항목으로 사용 가능한지 ··········· 117
7) 경보·유도시설 설치비용을 안전시설비 항목으로 사용 가능한지 ···· 118
8) 안전용역팀 투입시 용역비를 안전시설비 항목으로 사용 가능한지 ··· 119
9) 안전시설물을 설치할 때 용역으로 하는 경우와 안전보조원이 하는 경우 비용처리 항목은 ················································································ 120
10) 안전시설물 설치‧해체 용역시 이윤 등 기타비용도 인정 가능 한지 ·· 121
11) 에어백 조끼 구입비를 안전시설비 항목으로 사용 가능한지 ··········· 122
12) 안전관리 솔루션(Web/App)을 안전시설비 항목으로 사용 가능한지 ····· 123
13) 근로자 안전사고 예방플랫폼 구축 비용을 안전시설비 항목으로 사용 가능한지 ··················································································· 124
14) 유해가스 모니터링시스템 구축비용을 안전시설비 항목으로 사용 가능한지 ····················································································· 125
15) 소화기 구입·임대비용을 안전시설비 항목으로 사용 가능한지 ··········· 126

3. 보호구 등(안전인증보호구, 안전·보건관리자 피복 등) ··········· 127
1) 차광보안경 구입비용을 보호구 항목으로 사용 가능한지 ··················· 128
2) 방안화 구입비용을 보호구 항목으로 사용 가능한지 ·························· 129
3) 개인소유 안전순찰차량 유지비를 보호구 항목으로 사용 가능한지 ···· 130
4) 방염복 구입비용을 보호구 항목으로 사용 가능한지 ·························· 131

4. 안전보건진단비 등 ···························································· 132
1) 위험성평가 컨설팅 비용을 안전보건진단비 항목으로 사용 가능한지 · 133
2) 타워크레인 안전검사 비용을 안전보건진단비 항목으로 사용 가능한지
··········································································································· 134
3) 전기시설 정밀안전진단 비용을 안전보건진단비 항목으로 사용 가능한지
··········································································································· 135

5. 안전보건교육비 등 ···························································· 136
1) 산업재해 예방을 위한 다른 법령상 의무교육만 안전보건교육비 항목으로 사용 가능 한지 ··································································· 137
2) 안전관리자 선임 대상 현장이 아니어도 안전보건 관련 도서 구입 비용을 안전보건교육비 항목으로 사용 가능한지 ································ 138
3) 안전기원제 행사 기념품 비용을 안전보건교육비 항목으로 사용 가능한지 ······························································································ 139

6. 근로자 건강장해예방비 등 ··············································· 140
1) 배치전 건강진단 비용을 건강장해예방비 항목으로 사용 가능한지 ··· 141
2) 산소캔 구입비를 건강장해예방비 항목으로 사용 가능한지 ············· 142
3) 작업용 우의 구입비용을 건강장해예방비 항목으로 사용 가능한지 143
4) 안전화 건조기 구입비용을 건강장해예방비 항목으로 사용 가능한지 ··· 144
5) 작업장 방역 비용을 건강장해예방비 항목으로 사용 가능한지 ·········· 145
6) 건강장해예방비 항목으로 구입 가능한 약품의 종류는 ···················· 146
7) 건강관리실 설치비용을 건강장해예방비 항목으로 사용 가능한지 ·· 147
8) KF94 마스크 구입비용을 건강장해예방비 항목으로 사용 가능한지 ··· 148

7. 본사 전담조직 근로자 임금 등 ······································· 149
1) 시공능력 200위 이내일 경우 토목건축공사업 외 다른 업종은 본사 전담조직 근로자 임금 항목 사용이 가능한지 ·································· 150
2) 본사 전담조직 임금을 현장별로 나누어 사용 가능한지 ·················· 151

8. 위험성평가 등을 통해 사용 가능한 비용 ······················· 152
1) 위험성평가 등을 통해 사용할 수 있는 품목이 무엇인지 ················ 153
2) 위험성 평가 및 노사협의 등을 통해 산업안전보건관리비 사용을 결정하는 절차는 ················································································ 154
3) 미인증 보호구 구입비용을 위험성 평가 등을 통해 사용 가능한지 ·········· 155
4) 방한용품 구입비용을 위험성평가 등을 통해 사용 가능한지 ··········· 156
5) 휴게시설 의자 구입비용을 위험성평가 등을 통해 사용 가능한지 ·· 157

9. 사용불가 항목 ·································································· 158
1) 오후에만 신호수 업무를 한 경우 임금을 안전·보건관리자 임금 항목으로 사용 가능한지 ···································································· 159
2) 비계에 설치하는 안전난간의 설치비용을 안전시설비 항목으로 사용 가능한지 ····························································································· 160
3) 승강기 작업용 작업발판 설치비용을 안전시설비 항목으로 사용 가능한지 ····························································································· 161
4) 방화포 구입비용을 안전시설비 항목으로 사용 가능한지 ················ 162
5) 도로공사시 교통안전시설물 설치비용을 안전시설비 항목으로 사용 가능한지 ····························································································· 163
6) 안전관리자 사무실 설치비용을 안전보건교육비 항목으로 사용 가능한지 ····························································································· 164
7) 교육시 점심식사 비용을 안전보건교육비 항목으로 사용 가능한지 ··· 165
8) 간호사 보수교육 비용을 안전보건교육비 항목으로 사용 가능한지 ··········· 166
9) 휴게시설 설치비용을 건강장해예방비 항목으로 사용 가능한지 ··········· 167
10) 사다리 구입비용을 노사협의체 등에서 결정시 산업안전보건관리비 사용이 가능한지 ················································································ 168

10. 공사진척에 사용기준 및 관계수급인 사용 ···················· 169
1) 공정률에 따라 사용기준을 의무적으로 준수해야 하는지 ················ 170
2) 관계수급인도 산업안전보건관리비 사용이 가능한지 ························ 171

제4장 사용금액의 감액·반환 등 ··············································· 172
1) 공동도급 현장의 산업안전보건관리비 정산 방법은 ························· 173
2) 산업안전보건관리비를 초과 사용시 정산이 가능한지 ······················ 174

제5장 사용내역 작성 및 확인 ················································ 175
1) 사용내역 확인시 공사시작 시점을 언제로 보아야 하는지 ·············· 176
2) 안전용품을 사용전에 반드시 감리자 검수를 받아야 하는지 ··········· 177

제6장 안전관리자 제도 관련 ·················································· 178
1) 차수공사에 대한 안전관리자 선임 기준은 ······································· 179
2) 공사기간 특례 적용시 안전관리자 선임 수는 ·································· 180
3) 공사기간 중 전·후 15에 해당하는 기간은 ······································ 181
4) 도급인이 대신하여 관계수급인의 안전관리자 선임이 가능한지 ······ 182
5) 안전관리자를 공동으로 선임이 가능한지 ········································· 183
6) 여러개 현장이 동일지역에 있는 경우 하나의 사업장으로 보고
안전관리자를 선임해도 되는지 ························································· 184
7) ’21년 착공 공사의 경우 종전 규정을 적용하여 안전관리자 선임
면제 가능한지 ···················································································· 185
8) 동절기 휴식기간 안전관리자 선임을 해지할 수 있는지 ·················· 186
9) 시운전 시 안전관리자를 선임하고 해야 하는지 ······························ 187
10) 안전관리자가 소방안전관리자 업무 겸직이 가능한지 ······················ 188
11) 전담 안전관리자가 보건관리자 업무 겸직이 가능한지 ···················· 189