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Health and Safety Executive Health and Safety Executive CDM 2015: The regulator’s experience to date Simon Longbottom Head of Construction Sector, HSE
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CDM 2015: The regulator’s experience to date - … Regulator's experience... · Health and Safety Executive Health and Safety Executive CDM 2015: The regulator’s experience to

Aug 29, 2018

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Page 1: CDM 2015: The regulator’s experience to date - … Regulator's experience... · Health and Safety Executive Health and Safety Executive CDM 2015: The regulator’s experience to

Health and Safety Executive

Health and Safety Executive

CDM 2015: The regulator’s

experience to date

Simon Longbottom

Head of Construction Sector, HSE

Page 2: CDM 2015: The regulator’s experience to date - … Regulator's experience... · Health and Safety Executive Health and Safety Executive CDM 2015: The regulator’s experience to

What is CDM 2015(16) about?

CDM applies to all

construction work

• requirements for managing risk on

construction PROJECTS

• standards to be achieved BUT

NOT how to achieve them

• a flexible framework

• compliance strategies will vary

dependant on the project risk

profile

A project is more than a

construction site

Page 3: CDM 2015: The regulator’s experience to date - … Regulator's experience... · Health and Safety Executive Health and Safety Executive CDM 2015: The regulator’s experience to

Philosophy and objectives

• Integrate health and safety into project management

– Risk management not an after-thought or

bolt-on extra

– Improve communication and co-ordination

• Encourage all involved to work together to:

– Plan and manage from the outset, identify

hazards early on

– Target effort where it can do most good

– Discourage unnecessary bureaucracy

• Benefits:

– Reduced delays

– Improved reliability of costings and

completion targets

– Improved quality of the finished product

Page 4: CDM 2015: The regulator’s experience to date - … Regulator's experience... · Health and Safety Executive Health and Safety Executive CDM 2015: The regulator’s experience to

CDM 2015 – philosophy and objectives

• Effort on planning and management should be in proportion to project risk and complexity

• Associated paperwork should help communicate and manage the risk

• Paperwork which adds little is a WASTE OF EFFORT and a distraction from real risk management

Page 5: CDM 2015: The regulator’s experience to date - … Regulator's experience... · Health and Safety Executive Health and Safety Executive CDM 2015: The regulator’s experience to

CDM 2015

Pre construction phase Construction PhaseLiaison phase

Principal Designer

Principal Contractor

CDM

InformationH&S FileConstruction Phase Plan

Pre construction information

BIM

Common

Data

Environment

Concept

Stage

Options

Models

show mass

Site

evaluation

Risk

analysis

Design

3D Models

Methods of

construction

Liaison with

contractors

Site logistics

Define end

user needs

Detailed design

Clash detection

4D Models

Constructability

Using models to

communicate

Risk mitigation

Handover

H&S File

Maintenance info

Information to

inform ongoing

risk assessment

Construction

Information on

risk informs CPP

Visual method

statements

Page 6: CDM 2015: The regulator’s experience to date - … Regulator's experience... · Health and Safety Executive Health and Safety Executive CDM 2015: The regulator’s experience to

Application uncertainty

• Term maintenance activities:

– Tap washers

– Door handles

– Tree cutting/planting

– Power washing steps

– Painting an internal wall

– Light bulbs

• Definition has not changed

– FAQ and Q&A

• Part of wider project on site?

• Existing arrangements to plan, manage, monitor?

• Remember, be proportionate

Page 7: CDM 2015: The regulator’s experience to date - … Regulator's experience... · Health and Safety Executive Health and Safety Executive CDM 2015: The regulator’s experience to

The commercial client

• Decides what will be constructed

• Commissions the design

contractors

• Initiates the construction work

(or pulls the plug!)

• Is at the head of the

procurement chain

• Makes appointments, eg

Principal Designer and Principal

Contractor

• Greatest influence as standard-setter

Page 8: CDM 2015: The regulator’s experience to date - … Regulator's experience... · Health and Safety Executive Health and Safety Executive CDM 2015: The regulator’s experience to

The Client role – strengthened in CDM 2015(16)

• Make suitable arrangements for managing

a project including the

allocation of sufficient time

and other resources to:

1) ensure H&S and

2) welfare facilities

provided

• Maintain and review these

arrangements

Page 9: CDM 2015: The regulator’s experience to date - … Regulator's experience... · Health and Safety Executive Health and Safety Executive CDM 2015: The regulator’s experience to

Domestic clients

• Duties deemed to

contractor or PC

• Duties can be taken

on by designer or

PD where the client

wishes

• No PC? – enforce

against duty holder

creating risk

Page 10: CDM 2015: The regulator’s experience to date - … Regulator's experience... · Health and Safety Executive Health and Safety Executive CDM 2015: The regulator’s experience to
Page 11: CDM 2015: The regulator’s experience to date - … Regulator's experience... · Health and Safety Executive Health and Safety Executive CDM 2015: The regulator’s experience to

The Principal Designer

• Born out of necessity

• CDM-C role was not

working

• The PD Should– Strengthen design risk

management and co-operation

– Mirror the PC role in achieving

co-ordination

– Ensure information flow

Page 12: CDM 2015: The regulator’s experience to date - … Regulator's experience... · Health and Safety Executive Health and Safety Executive CDM 2015: The regulator’s experience to

PD role – what do we want industry to achieve?

• Designers taking responsibility for coordination and information flows, and health and safety

– Mirror role to the Principal Contractor

– Ability to influence the Client and PC

– More strategic approach on a project

– Proctively eliminating and mitigating risks

– An integral part of design – not separate

• Added value

– Reduced number of dutyholders

• Change accountability

– No delegation of H&S to consultant

– Remove the non-notifiable behaviours

Page 13: CDM 2015: The regulator’s experience to date - … Regulator's experience... · Health and Safety Executive Health and Safety Executive CDM 2015: The regulator’s experience to

Where we don’t want to be – some early behaviours

• Reluctance to take on the PD role when appropriate

• Additional fees for unnecessary work in the integrated design process

• Perception CDM stifles creativity

• Disproportionate and ineffective risk controls; increased bureaucracy

• Limited understanding of risk management/control hierarchy

• Unnecessary use/creation of third party ‘industry’ – no statutory ‘CDM advisor’ role

Page 14: CDM 2015: The regulator’s experience to date - … Regulator's experience... · Health and Safety Executive Health and Safety Executive CDM 2015: The regulator’s experience to

PD role – what has been the impact

so far?• Designer definition in CDM is wide

ranging

• Design community unsure of the role

(ex-CDM-C’s & Insurance)

• Active vs Non-Active Designers (ex-

CDM-C’s) – same criteria as PC role

Page 15: CDM 2015: The regulator’s experience to date - … Regulator's experience... · Health and Safety Executive Health and Safety Executive CDM 2015: The regulator’s experience to

PD role – industry needs to focus on?

Encourage & Build

Confidence

Case Studies

Skills, Knowledge & Training

Guidance

Support

None currently

Training

started i.e.

Consultants

Forum, RIBA,

ICEIndustry

guidance

Ex-CDMC’s

supporting

rather than

taking on PD

Page 16: CDM 2015: The regulator’s experience to date - … Regulator's experience... · Health and Safety Executive Health and Safety Executive CDM 2015: The regulator’s experience to

Who can be a PD?

• Must be a designer with

relevant SKE

• In control of pre-

construction phase

• Organisation or individual

– often a team

• ‘Designer’ includes

anyone who

prepares/modifies

designs or

arranges/instructs others

to do so

Page 17: CDM 2015: The regulator’s experience to date - … Regulator's experience... · Health and Safety Executive Health and Safety Executive CDM 2015: The regulator’s experience to

CDM 2015 – Corporate competence

• Selection of supply chain

with relevant experience

and organisational

capability – due diligence

• Ongoing industry reform

of PAS 91 to provide a

risk-based assurance

system

• Remove non-value

adding activities

Page 18: CDM 2015: The regulator’s experience to date - … Regulator's experience... · Health and Safety Executive Health and Safety Executive CDM 2015: The regulator’s experience to

CDM 2015 – competence

Individual competence

• Ensuring appropriate skills, knowledge training, experience have been or are being obtained.

• Ongoing information, instruction and training to ensure site risks are controlled,

• Supplemented by appropriate supervision

• Professional bodies and role of CPD

Page 19: CDM 2015: The regulator’s experience to date - … Regulator's experience... · Health and Safety Executive Health and Safety Executive CDM 2015: The regulator’s experience to

The End

Thank you for

listening

Any questions?