FEATURE CDM SIX MONTHS ON


Louise Hosking, Director at Hosking Associates Ltd, takes a look at the Construction Design & Management Regulations 2015 six months on from their introduction, exploring how easy the transition process has been for those in the industry.


Whilst working with a range of clients, including principal contractors, designers and principal designers, I have been impressed with how existing clients have adapted so quickly to CDM15 changes.


There have however been considerable challenges. Some organisations appear to be holding on tightly to the role of the CDM coordinator, CDM-C, in spite of the new requirements being clear: this role no longer exists.


“IF ORGANISATIONS ARE SEEKING TO APPOINT AN INDIVIDUAL OR


ORGANISATION TO OFFER SUPPORT, THEY ARE


RESPONSIBLE FOR VERIFYING THEY ALSO HAVE THE SKE AND ORGANISATIONAL


CAPABILITY FOR THE WORK.”


Individual duty holders must develop the necessary skills, knowledge and experience (SKE) to fulfil their defined responsibilities, and be able to make risk-based choices. The wealth of experience held by CDM-C's must be used differently.


They are well-placed to assist duty holders in achieving the SKE to meet the demands of their new roles. Duty holders must embrace their new roles fully and responsibilities cannot be sub-contracted.


The HSE issued guidance on this topic has largely gone unnoticed. This is very clear and states advisors should be used to guide, train and support.


If organisations are seeking to appoint an individual or organisation to offer support, they are responsible for verifying they also have the SKE and organisational capability for the work.


www.tomorrowshs.com


The Association of Project Safety gave their registered members until 6th October 2015 to sit an on-line examination to demonstrate their ability to give good advice. My advice is to look for someone who is now an incorporated member of APS . If general safety advice is being sought refer to the safety consultants register, OSCHR.


ROUTINE REPAIR


& MAINTENANCE There has been some confusion regarding the inclusion of "maintenance and repair" within the definition of “Construction Works.” However, this must be read in conjunction with the whole definition of construction work - which has not changed. Therefore, term planned maintenance work or work where individual components are removed and replaced, or lubrication and inspection undertaken, is not CDM work. If there is a project which involves construction, such as plant replacement, this probably will be CDM work.


For clients who are responsible for lots of property, my advice is to keep track of special projects and extraordinary expenditure as this is likely to be CDM construction work.


The HSE is promising a "proportionate" response to enforcement; when undertaking smaller works, clients will have to decide if CDM applies. If it does, a Construction Phase Plan must be created and the CDM process applied. The CITB have created an app for completing a plan, and a template can also be downloaded from their website, so there is no reason for this to become an obstacle to getting work done.


THE HEALTH & SAFETY FILE Whilst many organisations are used to issuing O&M manuals, it now has to be issued whenever a principal designer has been appointed. Homeowners are unlikely to realise information is missing unless it is specifically requested when they sell.


Everyone should expect “as built” drawings. Every design alters along the way, so this may mean tweaking drawings at the end of the project to align with what has actually been built. Generic electrical layout or drainage drawings will equally not be enough to satisfy the requirements, and drawings must show where new utilities have been installed.


Once developed, health and safety files can be updated rather than created from scratch and must be made available for those using, cleaning or maintaining the building.


TRANSITION DEADLINE The transition allowed for work to continue under the previous 2007 requirements was until 6th October 2015. By now all clients should have appointed a principal designer (PD) and principal contractor (PC) where applicable.


Some insurers have indicated an unwillingness to extend PI insurance to cover the PD’s role. Consequently, these clients have experienced unexpected difficulties in transition. In some cases they are reverting to assigning the PD duty to the previous CDM-C. Unless they are also a designer, this is not what the regulations intended.


There is more work involved in organising projects, but I have found clients are becoming more involved.


Clients must know whether sub- contractors are being used so they can determine if a PD is required. On the whole, informed project teams are definitely stepping up. Designers, in particular, will have to be better trained in respect of health and safety so they really do follow the hierarchy of risk control during the design process.


At the heart of this everyone needs to think of safety during design, before any action is taken.


www.hosking-associates.com 15


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