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Are you still unsure about your duties under CDM 2015 regulations? Hunter Safety Solutions can help.
More than two years ago, the Construction (Design and Management) Regulations 2015 came into effect, replacing the CDM coordinator (CDMC) role. This role previously managed the health and safety aspects of a project, whether in the design or construction phase, inputting advice and guidance throughout.
The responsibilities that formerly sat with the CDMC are now divided between three main duty holders:
The Client, who has taken on around 70% of the duties
The Principal Designer (PD), who assumes around 25%
The Principal Contractor (PC), who has inherited around 5%
The introduction of a PD role in CDM 2015 was a major change in the regulations.
Many designers/architects lack the skills or inclination to take on the health and safety duties of the PD, which is why the PD does not have to be a designer in the traditional sense, but must be a professional with the skills, knowledge and experience to control the design process and ensure safety and health compliance and or the ability to conduct gap analysis on their own competence and seek further advice where necessary.
The PD’s primary function is to control the pre-construction phase by collating and distributing the pre-construction information, identify and eliminate risk at the planning stage and prepare the safety file. The PD must also ensure that the architects/designers consider buildability, maintenance and use of the building after it has been handed over.
A Principal Contractor is appointed by the Client and has the overall control of the construction phase where it involves more than one contractor. This appointment is made to a contractor who has the capability to carryout the role, understanding the full range and nature of the health and safety requirements on the project as well as the skills, knowledge and experience to plan, manage and coordinate the complexity of the risks involved.
The CDM 2015 Regulations place several responsibilities onto the PC; one vital aspect is the production of the Construction Phase Plan (CPP) which is intended to ensure health and safety issues are properly considered during the development and sufficient arrangements and site rules are in place prior to construction works beginning.
Other responsibilities include:
The CDM 2015 regulations define a Client as anyone whom a construction project is carried out for. Commercial clients are not necessarily experts in construction therefore not required to take an active role in managing the works.
Much of the responsibility for assuring safety standards transferring to the Client reflects the fact that the Client holds the resources and drives the project, in terms of the cooperation and standards expected from other duty holders.
If the Client fails to formally appoint any of the main duty holders such as the PD and PC, then the role and the responsibilities for discharging those roles is retained by the Client.
When the Client is initially choosing a project team, a PD’s attributes should include construction knowledge, soft skills to liaise with the parties, and experience of the type and size of the planned works.
Once construction starts, the PC is then responsible for the site’s health and safety standards, but the Client retains the duty of ensuring that those standards are maintained throughout the project and should only allow construction to commence once they are satisfied the construction phase plan (CPP) is developed enough and communicated to all involved.
The new duties are a significant change for Clients carrying out construction projects, as they have a lot to lose if they do not choose the team carefully, ask the right questions, challenge the other duty holders at the right time, or do not have the skills, experience, knowledge and training to discharge their duties.
The answer is to become informed and surround themselves with people who are both knowledgeable and capable. The right training will provide clients and PDs with the knowledge to discharge their roles.
A new role has also emerged to answer the needs of clients faced with projects on a scale that exceeds their CDM competence and who do not have the time or inclination to take on training; the client CDM Adviser (CDMA) can undertake safety and health duties on the Client’s behalf during design and construction. The position is not a recognised duty holder role in CDM and appointing an adviser does not equate to Clients avoiding their duties, nor is it the same as employing a PD and including these duties under their scope of services. However, employing a suitably skilled CDMA can provide the safety and health overlay to a project, meaning the Client can be satisfied it is in control of the construction design and management process.
If the CDMA is appointed early enough in a project, they can advise the Client of their full duties under CDM 2015, and help to prepare the Client’s brief and the proposed management arrangements for the project. They can also help draw up the preconstruction information and ensure it is issued to designers and contractors. They can help ensure the project team has a balanced mix of skills, knowledge and experience to carry it through safely and that a competent PD is appointed and can accept the CPP on the Client’s behalf.
Other ways the CDMA can support the client in discharging their duties under CDM regulations include: accepting risk assessments and method statements from the PC on behalf of the Client, checking the PC and PD are carrying out their duties, carrying out regular site audits and inspections, checking the PD has prepared the safety and health file and advising on its suitability, and advising on arrangements for completion and handover.
A Client who decides to appoint a CDMA should choose someone familiar with CDM 2015 and how it differs from CDM 2007, as well as having knowledge and experience tailored to the project. The candidate should be a good communicator and have the natural authority to influence the other duty holders on the Client’s behalf.
If you’d like Hunter Safety Solutions to take on the CDMA, PD or PC role(s) for your next project, or feel you would benefit from training in this area, get in touch now on 01977 878389 or email info@huntersafetysolutions.com to discuss how we can help.