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Louise Hosking

How is the education sector faring with CDM15?

Louise Hosking looks at the challenges of implementing the new Construction Design and Management regulations

Posted by Stephanie Broad | November 05, 2015 | People, policy, politics, money

The Construction Design and Management (CDM15) regulations came into force on 6th April 2015. I have been impressed with how existing clients have adapted to changes, but there have definitely been challenges.

The CITB have some great guidance on their website for anyone looking for a refresh of the requirements.

Scope of the regulations

There has been confusion regarding the inclusion of 'maintenance and repair' within the definition of “Construction Works.” This must be read in conjunction with the definition of construction work - which has not changed. Planned, routine maintenance 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. Even where CDM15 is not relevant, the Health & Safety at Work Act 1974 most certainly still is, so contractors must still be warned of hazards, be inducted, and safe working practices agreed. Special projects and extraordinary expenditure is more likely to be CDM construction work.

Remember, construction work by employed staff can fall under the scope of the regulations. Where this is the case, the school may be the client, the (Principal) Contractor and the Principal Designer.

The HSE are promising a 'proportionate' response to enforcement; when undertaking smaller works, schools will have to decide if CDM applies. If it does, a Construction Phase Plan must be created and the CDM process applied.

An inspection visit to Heathcote School

Contractor abilities to comply

As “the client”, schools must assign the roles of Principal Designer (PD) & Principal Contractor in writing. Those they engage must have the skills, knowledge, experience (SKE) and organisational capability to perform the role.

Where schools have relied upon long standing relationships with local contractors, the changes are proving more challenging especially as many contractors were not aware of the changes. Schools who have worked alongside existing contractors, but stayed firm in expecting the process to be applied, have fared best.

Using CDM advisors

Some organisations are attempting to apply a new role of CDM advisor to every project. The new requirements are very clear – the CDM-C no longer exists. Individual duty holders must develop the necessary SKE to fulfil their defined responsibilities, and be able to make risk-based choices as part of what they do, and with each decision made. CDM-Cs are well placed to assist school clients, designers and contractors in achieving the SKE to meet the demands of their new roles as their competent person . Duty holders cannot sub-contract their responsibilities.

HSE guidance states advisors should be used to guide, train and support. Support may only be required for a short period of time whilst the necessary skills are acquired by the design team, client or contractor. Cooperation and effective coordination is key to ensuring there is a clear overview of all the safety issues resulting from the work and how risks are being controlled.

Organisations requiring support are responsible for verifying advisors have the SKE and organisational capability for the work. The Association of Project Safety expected members to sit an on-line examination to demonstrate their ability to give good advice. Anyone looking for advice should request evidence the individual passed this! General safety consultants should be listed on the consultants register known as OSCHR.

The Health & Safety file

Some project teams remain unsure as to what should be included, and school clients can help by clearly communicating how they would like the information provided. There has been a reluctance to provide 'as built' drawings, and files are still not being created during the work which is definitely the best way to collate it. School clients should be requesting regular updates to determine whether the file is progressing as expected.

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 & Safety files should be updated rather than created from scratch, and looked after. This is future pre-construction information, so it’s important and schools should be demanding high standards of information.

Students get involved at an inspection visit

Conclusion

I am finding school clients like the processes and feel more in control. Roles and responsibilities have greater clarity. School clients must be more aware of how sub-contractors are used so they can determine if a principal designer is required. On the whole, informed project teams are definitely stepping up.

Louise Hosking is a chartered safety and health practitioner and Director at Hosking Associates Ltd

www.hosking-associates.com

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