RISK MANAGEMENT TCDM 2015
The HSE has finally unveiled proposals to revise the Construction (Design and Management) Regulations 2007 (CDM 2007) and replace the Approved Code of Practice (ACoP) with targeted guidance.
SPECIFICS
Within the wind energy industry, the two proposals likely to have most ramifications are: the replacement of the CDM co- ordinator (CDM-c) with a new principal designer (PD) role and the introduction of a general duty on information, instruction, training and supervision to replace explicit competence requirements in CDM 2007.
JUSTIFICATION
The HSE’s justification for replacing the CDM-c function is that it has been ineffective: CDM-cs are often appointed too late, with insufficient resources and are poorly embedded into pre-construction project teams. The new PD role, the HSE says, will rest with ‘an individual or business in control of the pre-construction phase’; the ‘default position’ being that this responsibility lies within the existing project team.
INTEGRATING SAFETY ISSUES Though the new PD role should in theory integrate safety issues earlier into project design, the question remains: How do organisations appointing a PD ensure their competence?
“The problem with the CDM-c in our experience is that the transition from the 1994 planning supervisor role to CDM-c has been poorly executed.
“Current CDM-c’s have not benefitted from development in co-ordinating pre- construction activities,” explains Rakesh Maharaj of ARMSA Consulting. “And if that competence gap is not addressed, why should designers be any more effective in the co-ordinating role?” He continues: “This creates a more distinct separation between traditional design and design of work activities, the latter being the function fo the principal contractor.”
IME TO TRANSITION
LOGICAL RESPONSE “Given that
competence is at the core of improving safety performance, dropping the explicit 2007 requirements is a short-sighted response to a problem created not by the principle enshrined in the Regulations, but through over-prescription in the ACoP,” adds Rakesh. “A more logical response would be to encourage companies to operate competence management systems and assurance frameworks.”
TIMETABLE
Under the current timetable and subject to the HSE’s consultation findings, the revised Regulations should take effect in April 2015. “Tender submissions put together now could well fall under CDM 2015 when the project goes live,” notes Rakesh, “so contract negotiators and procurement teams need to be up-to-date with the proposals.” Prospective clients and principal contractors need to look at the PD’s duties, and when they should appear in project teams. “Simply re-badging a CDM-c as a PD will not meet the requirements.”
Rakesh Maharaj, MBA. B(Tech) (Hons). NDip. DMS. MIBC. CMIOSH Managing Director ARMSA Consulting
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www.windenergynetwork.co.uk
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