REGULAR A NEW DAWN
Paul Bussey, Associate Technical Consultant at Scott Brownrigg, explains how to interpret the CDM Regulations 2015 and why all risks can’t be ‘designed out’.
On 6th April, the new Construction Design and Management (CDM) Regulations 2015 came into effect, following a lengthy five-year evaluation of the CDM 2007 Regulations, brought about by the Government’s early day motion. While the new regulations will have significant implications for all those involved in construction, the intention is simple: to prevent the ill health or death of construction and maintenance operatives, while allowing for the delivery of good design.
The outcome of the process is a re-focusing on the team approach, underpinned by the intentions of the overarching 1974 Health and Safety at Work Act, and aimed at proportionality, reasonable foreseeability and practicability. This, in conjunction with the 1999 Management of Health and Safety at Work Regulations where the concept of “suitable and sufficient assessment of risk” was reinforced, set the landscape within which the 1994 and 2007 CDM Regulations sat.
Originally intended for process industries, where absolute duties to eliminate and reduce risk could be applied, the application of these regulations to design tasks has been much more complex. This has, in some cases, led to confusion and unintentional misinterpretation by some duty holders lacking design training, who have expected designers to ‘design out’ all risk from their concept designs. The implementation of such expectations can stifle creative, innovative design and inhibit designers from establishing acceptable or tolerable levels of risk within the constraints of cost, time, quality, aesthetics, and contextual expectations of individual projects.
This disconnect has caused frustration within the industry, and has highlighted the need to balance and co-ordinate health and safety
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prevention principles and innovative design right from the start of the design stage. A return to the original intentions of the ‘planning supervisor’ has been necessary. The new principal designer role addresses these issues and, as required by the 1992 EU Directive, provides a “health and safety co-ordinator of the project preparation phase embedded within the existing design team and in control of preparing and modifying [actual] designs”.
“IT IS ESSENTIAL FOR THE PROJECT TEAM
TO WORK TOGETHER AS A COHESIVE
UNIT, WITHOUT THE FEAR OF BLAME OR PROSECUTION IN THE
EVENT OF A FAILURE OR ACCIDENT.”
The new principal designer function is thus intended to be a corporate one to integrate health and safety considerations into the design process in a proportionate and practicable manner that avoids and minimises risk. It also helps to provide a design which not only meets the client brief but sets and identifies a tolerable level of risk for the client to fund, the contractor to build, and the user to operate.
In order to facilitate such a position it is essential for the entire project team to work together as a cohesive unit, without the fear of blame or civil or criminal prosecution in the event of a failure or accident. Unfortunately history shows us that when carrying out complex and sophisticated tasks, it is almost inevitable that some accidents will occur, primarily due to human behaviour and unforeseeable
events. The fact that health and safety statistical evidence has reached a plateau across the world supports this claim.
In view of this, the aspiration to simply “design out” risk has arguably reached its effective limits. There is now a need to identify a more sophisticated and intuitive process of risk identification and analysis with the end result of reducing risk. This “Hazard Awareness Risk Management” (HARM) process sets a new agenda for health and safety and is at the heart of a worldwide “Safety Differently” approach, or “CDM Differently” in this case.
Design, and the communication of design, is a highly visual process requiring the production of visual images to assimilate the various contributions of team members into one cohesive entity. The integration of safety into design is no different. By identifying potential harm visually and directly on drawings, issues can be discussed in design and project team forums, managed to a tolerable level within the constraints of the design intent, and embedded in the normal design process.
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