John Ridley gives advice on how to comply with the Construction (Design and Management) Regulations when starting a new construction project
One of the best ways to ensure compliance with the latest CDM regulation is to plan every aspect of the project before construction work begins. The previous regulation stated that principal contractors had to provide a construction phase plan (CPP) before any work commenced, but the 2015 regulation stipulates much more clearly what contractors should consider in the initial stage of the project. The CPP should explain how health and safety is going to be managed throughout the project, taking into consideration the residual risks from previous projects on the same site.
The CDM client commissioning the project should include a list of site rules, along with welfare details. Emergency procedures should be in place, including a working supply of fire and/or gas alarms. All construction workers should have an on-site induction before work commences. This should also be outlined in the CPP.
If there are any specific health and safety risks related to the project, these should be explained in detail. For example, Boulting Technology carries out a lot of construction projects for the water industry, so we have to be aware of the risks of using chemicals employed to treat water facilities, as well as the risk from raw sewage and aeration lanes.
If there are any risks that cannot be eliminated, all parties need to be sure that they have been minimised as much as possible. This is why the CPP should be detailed and completely accurate. There should also be regular reviews carried out to ensure this.
The new regulation also puts additional responsibility onto the client. To ensure success, the first thing a client needs to do is create a brief for the construction project. This should outline the main functionality and give reasons as to why the project is being carried out. It should also explain what the client expects from all parties during the project, including health and safety aspects.
The client is now responsible for appointing two duty-holders; the principal designer and the principal contractor, where there will be more than one contractor working on the construction phase. The client should also check that these people are carrying out their duties correctly. This could be achieved by attending regular meetings, carrying out on-site audits, or appointing a third party to advise.
Clients also have to notify the HSE if projects will exceed 30 construction days with 20 or more workers, working simultaneously on the project, or if the project exceeds 500 person days. Clients will be required to complete an F10 notification of work, which informs the HSE that a construction project is taking place. The notification identifies the responsibilities and details of the work that is to be completed.
As a result of submitting this notification, the HSE may come and visit the project before any construction work takes place. It will check that health and safety is being properly planned and if there are any breaches identified, it will investigate these too.
Remember, the HSE makes a decision on whether to audit the site based on the F10 document, so any discrepancies may affect its decision.
During the project
While carrying out the construction work, contractors should be made aware of their responsibilities from the start. Ensure the workforce is aware of the risk assessments that will take place during the project and if the work is being carried out over a longer period of time, continually remind workers of their duties by way of pre task briefing, method statements briefings and tool box talks, to name a few.
Communication between the client and all project stakeholders is vital, so the client needs to listen to the team carrying out the work, paying particular attention to suggestions on how to improve health and safety on-site.
Until 2015, clients were required to produce an explicit competence document before any work commenced. This was an evidential document that proved everyone appointed had the appropriate information, instruction, training and supervision to carry out the project.
This document has been removed from the latest regulatory standard to reduce bureaucracy. Although the legal requirement for a competence document no longer exists, Boulting Technology has found that most clients still follow this procedure, as it is best practice. The explicit competence document allows clients to fully consider their options when employing contractors, thus ensuring the ‘organisational capability’ of all parties that are appointed.
John Ridley, programme manager at Boulting Technology.