Construction (Design and Management) Regulations 2015

Ok so lets start off with where you would find guidance on CDM. It’s under the ‘construction’ section of the HSE website- which was fine 10-15 years ago because that’s where the majority of uses of CDM would be used. But nowadays (since the introduction of the revised regs in 2015) CDM can be applied to so much more than just construction.

The revision to the regulations saw maintenance and engineering tasks grouped under CDM. This along with the emphasis on the ‘client’ role under CDM (particularly domestic clients) was the focal point to the revision.

So what is CDM? It’s the Construction (Design and Management) Regulations 2015. The clue is in the title really, it’s all about the management of H&S within design and management of ‘projects’. I say projects, but I really mean almost any type of work activity.

Some keys information, roles and responsibilities under CDM;

Client

Applies to domestic and commercial clients. The client must ensure that adequate resources (time, money, people) are set aside for the work. They must also ensure that adequate welfare facilities are provided for the workers on the job. This is why you may have seen portaloo’s more often on domestic jobs- basically if it’s a big job, then adequate welfare must be provided (toilet facilities, mess facilities, hot water etc)- this is all dependant on the type and length of job. Provide pre-construction information (or PCI) to the Principal Designer to include within their designers risk assessment and overall designs. Things like asbestos register, floor plans, local hazards etc. Before construction starts, they must ensure the contractor or Principal Contractor (if there are more than 1) prepares a suitable construction phase plan (or CPP). They must ensure the PD develops a health and safety file for the project (only required if there is more than 1 contractor). They must also appoint the PC and PD into their roles in writing. If they don’t appoint a PD or PC, they then must fulfil these roles (apart from domestic clients; the responsibility doesn’t defer back to the client in this instance).See why this role is so important?! The 2015 regs have certainly put more emphasis on this role- holding them accountable basically.

Principal Designer (PD)

Must ensure the client understands their responsibilities. Should use the principles of prevention to eliminate or minimise risks (based on the PCI provided by the client). Designs must comply with Workplace (Health, Safety and Welfare) Regulations 1992. Ensure that designs are fit for purpose, budgeted for, aesthetics, environmentally friendly etc. Have overall responsibility for the pre-construction phase. Responsible for other designers. Assist the PC where necessary in creating the CPP. Develop and maintain the health and safety file for use by contractors/PC when creating health and safety documentation for the project (again only required when using more than 1 contractor). They will then hand this ‘file’ over to the client when work finishes.

Principal Contractor

Responsible for creating the construction phase plan. Responsible for managing the construction phase of the project. Responsible for managing other contractors. Only required when there’s more than 1 contractor. Provide a suitable site induction. Responsible for the security of the ‘site’. Ensure that welfare is adequate for the workers.

Notification

A project becomes notifiable to the HSE, ORR (railway) or ONR (nuclear) if it is to;

(a) last longer than 30 working days and have more than 20 workers working simultaneously at any point in the project;

or (b) exceed 500 person days.

The client is responsible for this notification, however this responsibility can be passed to another party to undertake on behalf of the client. The notification is called an F10.

The reason the CDM regs are so important is that its not just construction work that it applies to. Think about all the other aspects of H&S that it can apply to;

  • Maintenance work (fit for purpose, can be maintained safely, decommissioned safely, operating/user guidance).
  • Temporary works (scaffolding, excavations, fences, site security etc).
  • Floods
  • Traffic management- emergency access
  • Fire detection
  • Lighting
  • Welfare facilities
  • Asbestos removal
  • All high risk work

Basically the options are endless. The regulations are there to keep people safe and ensure equipment/facilities can be safely managed, maintained and used.

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