Changes To CDM Requirements Part 2: The Implications
These regulations came into force on 6th April 2015 but for most projects already underway these have been managed under interim measures with the existing parties being employed, however as of 6th October 2015 all projects both new and existing will have to be managed under the New Regulations.
There was, just before and for a while after, some speculation on the effect and actual practical management of the new Regulations, however, new guidance has been published and initial draft documents have been issued giving a clear picture:-
The Key changes are as follows:
All projects must have:-
a) A written contraction phase plan.
b) Workers should be able to demonstrate the right skills, knowledge, training and experience.
c) Contractors providing appropriate supervision, instruction and information.
Projects with more than one contractor must have in addition to the above:-
a) An appointed Principal Designer.
b) A Health and Safety file.
In addition to the above if the work is scheduled to:
a) Last longer than 30 working days and have more than 20 workers on site at any one time.
b) Exceeds 500 person days, the HSE need to be notified.
The role of CDM coordinator has now been removed and replaced by the ‘Principal Designer’. This change is designed to bring the responsibility for Health and Safety management within the existing design and management team and no longer be an independent appoint of a separate party.
The title should not be confused with that of Lead Designer, the role of coordinating the design of a project is both a different skill base and should be wholly separate.
The key issue is consistency from the early stages of project planning to the completion of the construction. Often with contractors’ roles now involving some design function, design parties change through the construction design and build process. The traditional designer therefore is not always the best solution and also not commonly trained to fulfil this role.
Project managers involved from the early concept stages are after best placed to take this overview and role, and like ourselves have trained and had significant experience in this function previously.
Domestic Construction Work
There are now requirements to comply with this legislation even if you are a Domestic client and in most cases this will for smaller projects be the appointment of the contractor as ‘Principal Contractor’ and ensuring they have a construction phase plan in place.
- Appoint the right people in accordance with the above depending on the period of construction and number of contractors/workers onsite.
Principal Designer – plan, manage and coordinate the planning and design work. Principal contractor – plan, manage and coordinate the construction work.
- Ensure there are arrangements in place for managing and arranging the project
- Allow adequate time to plan and build.
- Provide information to designers and contractors on existing sites, building and client requirements.
- Communicate with designers and contractors.
- Ensure adequate welfare facilities are provided on site.
- Ensure construction phase plan is in place.
- Keep the Health and Safety file.
- Protect others including the public and employees.
- Ensure any new workplaces are designed correctly in accordance with the Workplace Regulation 1992.