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CDM REGULATIONS 2015
MANAGING HEALTH AND SAFETY
IN CONSTRUCTION
NOVEMBER 2015
General overview & main changes in 2015 revision
• Matt Harrison BSc, IMaPS, TechIOSH, SIIRSM, ICIOB.
• Freelance PM, QS and (ex) CDM C – specialising in process industry
• Formed own company in 2011 having delivered CDM C services for 5
years on some of London's largest projects with Ove Arup and
Partners International.
• Contributor to the CIRIA publications “Work Sector Guidance” based
around the 2007 Regulations
• Much of CDM is an application of “common sense”.
Introduction
Objectives of today
• Understand from where CDM comes, its objectives and principles;
• The original duties & new 2015 duties
• Client, Designer, Principal Designer, Principal Contractor,
Contractor
• Key documents
• UK reflection of European Directive 92/57/EEC, and due for review
next year (so our CDM regulations may change again?)
• Construction (Design and Management) Regulations 1994, 2002,
2007 and now 2015;
• Places duties on key members of the project team.
What is CDM ?
• the construction, alteration, conversion, fitting out, commissioning, renovation, repair,
upkeep, redecoration or other maintenance (including cleaning which involves the use
of water or an abrasive at high pressure, or the use of corrosive or toxic substances),
de-commissioning, demolition or dismantling of a structure;
• the preparation for an intended structure, including site clearance, exploration,
investigation (but not site survey) and excavation (but not pre-construction
archaeological investigations), and the clearance or preparation of the site or
structure for use or occupation at its conclusion;
• the assembly on site of prefabricated elements to form a structure or the disassembly
on site of the prefabricated elements which, immediately before such disassembly,
formed a structure;
• the removal of a structure, or of any product or waste resulting from demolition or
dismantling of a structure, or from disassembly of prefabricated elements which
immediately before such disassembly formed such a structure;
• the installation, commissioning, maintenance, repair or removal of mechanical,
electrical, gas, compressed air, hydraulic, telecommunications, computer or similar
services which are normally fixed within or to a structure,.
What is construction?
Objectives of the Regulations are:
• To protect the health and safety of people in construction , and others
who may be affected by their activities.
• Requires a systematic management approach from concept to
completion: hazards must be identified and eliminated where possible
and the remaining risks reduced and controlled.
• Reduce risks through a safe by design process, during construction and
thought out the life cycle of the structure.
• Early identification of hazard and risk;
• Mitigate risk as far as practicable;
• Co-ordination of Health & Safety across design and construction;
• Improved documentation throughout the life of a project.
• CDM 2015 regulations now aimed at the small project (i.e<15) employees on site
• CDM 2015 – copy out of EU 92/57, much better regulation / easier to navigate / understand
Principles
Qu. HSE expected level of
compliance
CDM can add ‘value’ to a project by:
• Improving internal project management;
• Improving ‘buildability’;
• Reduces the cost of managing health and safety;
• Improves conditions on-site;
• Improves cost & programme certainty
Benefits
The following are legally required documents
• F10 – where notification required
• Construction Phase Plan
• Health and safety file
Documents with Legal Status
• Client;
• Principal Designer (was CDM Coordinator);
• Principal Contractor;
• Designer;
• Contractor.
Duty holder
• Notify HSE (20 operatives x 30 days – or – 500 man days threshold)
• Ensure suitable management arrangements; ( A project plan?)
• Allow sufficient time and resources for all stages;
• Ensure arrangements are maintained / reviewed throughout the project
• Provide Pre Construction Information;
• Ensure adequate welfare and Construction Plan is in place;
• If it is likely there will be 1+ contractors on site; And as soon as practicable
• Appoint Principal Designer (PD); client liable if not appointed
• Appoint Principal Contractor (PC); client liable if not appointed
• Take reasonable steps to ensure PC and PD comply with their duties
• Ensure the Principal Designer prepares and issues a health and safety file;
• Ensure appointees have skills, knowledge, experience and organisational capacity (PAS 91 / SSIP)
• Retain and provide access to the H&S file;
Roles and Duties – Client
Client duties pass to;
The contractor – where only 1 on site throughout the project
The principal contractor – where 1+ contractors / sub contractors on
site
The principal designer where there is a written agreement
Default position;
• Where NO appointment made, the designer in control of the pre
construction phase is deemed the Principal Designer
• Where NO appointment is made the contractor in control of the
construction phase is the Principal Contractor
Roles and Duties – Domestic client (..?..)
COMMUNICATING AND CO-OPERATING
PRE-CONSTRUCTION INFORMATION
(PRE TENDER HEALTH AND SAFETY PLAN)
CONSTRUCTION STAGE
HEALTH AND SAFETY PLAN
HEALTH AND SAFETY FILE
PRE CONSTRUCTION INFORMATION
• Description of project;
• Clients Considerations and Management Requirements for Health and Safety Risks;
• Environmental Restrictions and Existing on Site Risks;
• Significant Design and Construction Hazards;
• Key information from existing Health and Safety Files.
• How new H&S File will be managed
• Must be satisfied they have skill, knowledge, experience and organisational capacity to undertake appointment
• Those making appointments must take reasonable steps to check competence (i.e - s,k,e,c)
• All appointees must cooperate with the team / adjoining site
• Report all matters that may effect their health and safety – or that of others.
• Provide information (when required) clearly, comprehensible and in a timely fashion.
Qu. Whose Roles and Duties ?
• Must be satisfied they have skill, knowledge, experience and organisational capacity to undertake appointment
PAS 91 – but what happens if they / you don’t ?? …….
Qu. Whose Roles and Duties ?
• Check client is aware of their own duties
• Take into account the Preconstruction Information
• Take account of the principles of prevention to ,so far as reasonably practical,
(SFARP) eliminate any foreseeable risk to the health and safety of any person.
• carrying out /affected by construction work
• Maintaining / cleaning a structure
• Using a structure as a workplace
• If elimination is not possible to control the risk through the subsequent design
process and
• Reduce risk / control risk
• Provide information
• Add information to the H&S file
Roles and Duties – Designer
• Provide information about risks to the Principal Designer
• Ensure appropriate information is included in the H&S file
• Take all reasonable steps to provide, with the design, sufficient information
about the design, construction or maintenance of the structure to adequately
assist the client, designers and contractors to comply with their duties.
Roles and Duties – Designer
(a) avoiding risks;
(b) evaluating the risks which cannot be avoided;
(c) combating the risks at source;
(d) adapting the work to the individual, especially as regards the design of workplaces, the choice of work equipment
and the choice of working and production methods, with a view, in particular, to alleviating monotonous work and work
at a predetermined work-rate and to reducing their effect on health;
(e) adapting to technical progress;
(f) replacing the dangerous by the non-dangerous or the less dangerous;
(g) developing a coherent overall prevention policy which covers technology, organisation of work, working conditions,
social relationships and the influence of factors relating to the working environment;
(h) giving collective protective measures priority over individual protective measures; and
(i) giving appropriate instructions to employees
The general principles of prevention
E. R. I. C.
Brainstorm ideas
Talk to fellow design team members
Previous Projects
Record
Then evaluate them:
what can be eliminated, reduced or controlled
Review your decisions
Roles and Duties – Designer
Integrated Approach – not “just” health & safety, and we can also consider
health and safety
cost
fitness for purpose
aesthetics
buildability
environmental
And ……
And ……
And ..….
Roles and Duties – Designer,
So far as reasonably practicable ?
• Must PLAN, MANAGE and MONITOR the pre construction phase and
coordinate matters relating to Health and Safety during the pre
construction phase to ensure that sfarp, the project is carried out without
risks to health or safety.
• Take account of principles of prevention during design, technical and
organisational aspects of the decision process and when estimating the
period of time for such work
• Identify and eliminate, or control, sfarp, foreseeable risk to any person
• Carrying out or liable to be effected by construction work
• Maintaining or cleaning a structure
• Using a structure designed as a workplace
Roles and Duties – Principal Designer
• The PD must (sfarp?) ensure all designers comply with the designers duties
• The PD must ensure all persons working on the pre-construction phase
cooperate with the client, PD and each other
• Assist with collation of pre construction information (PCI) and provide it
promptly in a convenient for to all designers and contractors
• Liaise with the PC for the duration of the PD appointment and share with the
PC information about planning, management and monitoring of the
construction phase and coordination of health and safety maters during the
construction phase
• No requirement to provide H&S advice to the client
• Can be individual or company provided they have the skills, knowledge,
experience and organizational capacity
Roles and Duties – Principal Designer
• Must PLAN, MANAGE and MONITOR the construction phase and coordinate
matters relating to Health and Safety during the construction phase to ensure
that, sfarp, the project is carried out without risks to health or safety.
• Take account of principles of prevention during design, technical and
organisational aspects of the decision process and when estimating the
period of time for such work
• Organize cooperation between contractors, including successive contractors
• Coordinate implementation by the contractors of applicable legal
requirements for health and safety
• Ensure that employers / self employed apply the principles of prevention and
when required follow the construction phase plan.
Role and Duties; Principal Contractor
• Provide a suitable site induction, exclude unauthorized persons, provide
welfare
• Liaise with the PD for the duration of the PC appointment and share with
the PD information about planning, management and monitoring of the
construction phase and coordination of health and safety maters during
the construction phase
• Consult and engage with workers
Role and Duties; Principal Contractor
• Check client awareness of duties
• Must PLAN, MANAGE and MONITOR construction work carried out by the
contractor or by workers under his control to ensure, sfarp, it is carried out
with out risks to health or safety.
• Check skills, knowledge, training and experience of appointments
• Provide each worker under their control appropriate supervision,
instruction and information so that work can be carried out without risk to
health and safety (induction, emergency plan, information regarding H&S
form their, or others activities, information for statutory compliance)
Role and Duties; Contractor
• Where there is more than 1 contractor comply with directions from PD or
PC, and/or the applicable elements of the construction phase plan
• Take account of principles of prevention during design, technical and
organisational aspects of the decision process and when estimating the
period of time for such work
• If the only contractor on site – prepare a construction phase plan
• Exclude unauthorized access
• Provide suitable welfare
Role and Duties; Contractor
Upon appointment (or before) the Principal Contractor / Contractor
will prepare a plan that identifies HOW he will manage or address the
requirements and hazards associated with the project as identified in
the Pre Construction Information.
Construction Phase Plan
Description of works and who has been engaged;
The Management of the work including;
• Health and safety aims for the project
• Site Rules;
• Arrangements to ensure cooperation and coordination within the team
• Arrangements for liaison with workforce;
• Site induction
• Welfare;
• Fire and Emergency Procedure.
• Control of specific risks (schedule 3)
Whilst no longer within the guidance the following are also recommended for inclusion;
• Contractors team, structure, responsibilities;
• Permit arrangements;
• Extent and location of records / plans;
• Design and H&S Information exchange;
• Design change information;
• Selection of Sub Contractors;
• Site Security and Induction;
• Training;
• Reporting and investigation of accidents;
• Production and approval of Risk Assessments;
• H&S File
Construction Phase Plan – Content
• Work which puts workers at risk of burial under earth fall, engulfment in swampland, falling from height
• Work which puts workers at risk from chemical or biological substances constituting a particular danger to H&S or a legal requirement for health monitoring
• Work with ionizing radiation
• Work near HV power lines
• Work exposing workers to drowning
• Work on wells, underground earthwork and tunnels
• Work requiring divers and a system of air supply
• Work in caissons with a compressed air atmosphere
• Work involving explosives
• Work involving the assemble/dismantling of heavy prefabricated components
Construction Phase Plan – Schedule 3 work with particular risks
• Required for all projects with 1+ contractors
• Prepared by the PD and passed to the PC on completion of PD appointment
• Kept available by client for anybody subsequently working on the structure
• Prepared by the principal designer during pre construction phase, reviewed updated and maintained.
• If PD role finishes before end of project the file passes to the PC to complete
Health and safety file – Requirements
• Description of the works
• Hazards not eliminated by design or construction process & how addressed
• Key structural principles (bracing, stored energy, working loads for roofs/floors)
• Hazardous materials used (lead paint / specialist coatings)
• Information about removing / dismantling plant & equipment
• Health and safety information about equipment provided for cleaning or maintaining a structure
• The nature, location and markings of significant services (gas / fire fighting etc)
• Information and as built drawings its plant and equipment
Health and safety file – Contents
CDM 2015 – Löfstedt
Further careful analysis and consultation with the industry
will be required to decide the best approach. For example,
whether amending the regulation, perhaps to amend the
requirement ‘to take reasonable steps to demonstrate
competence’ is necessary or if it is possible to achieve the
desired outcome by amending the ACoP.
It is vital that any changes do not result in a diminution of
current standards which may have unintended
consequences for effective health and safety regulation of
the construction industry
Review of today
• Understand from where CDM comes, its objectives and principles;
• The original duties & new 2015 duties
• Client, Designer, Principal Designer, Principal Contractor,
Contractor
• Key documents
• Preparing / advising on CDM management arrangements for client / designers / contractors
• Preparing / assisting with clients briefing documentation
• Gathering and providing PCI reports
• Construction phase plan review and recommendations for acceptance
• Audits of both Principal Designer and Principal Contractor activity
• Principal Designer design reviews and design risk management
• Checking skills, knowledge, experience and training (all appointments)
• Drafting / reviewing / updating construction phase plans
• Preparation / and or approval of Health and Safety Files
• CDM training and mentoring
• Undertaking the Principal Designer role
MHPSS Ltd
CDM Consultancy – Services
MHPSS LTDMatt Harrison Project Support Services Ltd
104 Royal Crescent
South Ruislip
Middlesex
HA4 0PR
020 8845 0915
07540 827170