We are now 4 months into CDM15 – so how is it faring, and how are companies adapting to change?
We work with a range of businesses and schools who may be clients, contractors or designers in respect of the new regs. I have been extremely impressed with how they have adapted so quickly to the changes, and I can honestly say all our existing clients are able to confidentially answer most questions posed before, during and after construction work is undertaken.
At Hosking Associates, we have worked hard to ensure the advice we offer meets the spirit of the new legislation; this has involved extensive work and research to determine how best to implement the new requirements within the wide range of sectors we operate. However, some organisations appear to be holding tightly to the role of the CDM coordinator – where the new requirements are very clear that this role no longer exists. Individual duty holders must develop the necessary skills and knowledge to take on their roles fully, and be able to make risk-based choices as part of what they do. The wealth of experience held by CDM-C’s must be used differently and these individuals are well placed to assist clients, designers and contractors in achieving the skills, knowledge and experience to meet the demands of their new roles as their competent person for this area – which is very much at the heart of work we undertake for our clients. But duty holders must eventually take this role fully.
There has also been some confusion in respect to the reference of “maintenance and repair” within the definitions. However, this must be read in conjunction with the definition of construction work – which has not changed. Therefore, term PPM work or work where individual components are removed and replaced, or lubrication and inspection – is not CDM work. If there is a project which involves construction, such as a boiler replacement, this probably will be CDM work.
I didn’t expect the development of the Health & Safety File to be the sticking point it is proving to be. Whilst many organisations are used to issuing O&M manuals, and certainly the creation of a H&S file is a normal part of larger projects, it now has to be issued whenever there is a principal designer appointed – whenever there has been more than one contractor involved in the work. Some project teams are unsure as to what should be included, and many clients are not clearly communicating how they would like the information provided. In some circumstances, there is a reluctance to provide “as built” drawings; product assessments are not being included, and files are still not being created during the work which is definitely the best way to ensure everything is provided.
The HSE are promising a “proportionate” response to enforcement; when you carry out smaller works you have to decide as an organisation where CDM applies which means creation of a Construction Phase Plan and following the CDM process.
There is more work involved in organising projects, but I am finding clients are a bit more involved and project teams are definitely stepping up. I do believe designers, in particular, will have to be better trained in respect of H&S so they really do follow the hierarchy of risk control during the design process. At the heart of the regs is the goal of making sure everyone thinks safety before a spade is put into the ground, or before bringing down a wall of unknown construction.
The HSE have also issued guidance (Q&A Briefing on CDM15) which is very helpful and may cut through some of the misnomers. This can be accessed via this link http://chilp.it/3cf3a90.
We are extremely well placed to provide advice, guidance and training on CDM15, and can offer a contractor management review for your organisation to assist with helping you to understand where you are now, where you need to be, and how you might get there. We would like to work with you whatever the size of your organisation – just contact us!