CDM 2015 seeks to remove the barriers to improvements in the construction industry set up at the beginning of projects.
For example, H&S policies, pre-qualification questionnaires and competence schemes can all provide an illusion of safety but in fact burden designers, construction managers and site operatives with increased paperwork in an attempt to demonstrate compliance without necessarily bringing improvements.
CDM 2015 seeks to remove the bureaucracy and promote a ‘proportional approach’ with a requirement for appropriate skill, knowledge and experience. The objectives of CDM 2007 have been generally retained but made less complicated and more accessible.
The most significant change is the removal of the CDM-C role and the introduction of the Principal Designer. This is to give responsibility for CDM during the design phase to an individual who has the ability to influence the design. CDM Advisors are no longer required under CDM 2015.
The Principal Designer must be a designer on the project and must be appointed in writing by the Client. The Principal Designer must be in a position where they can influence and control the design and planning stages. If the Client does not appoint a Principal Designer or Principal Contractor then the Client assumes the role. In addition:
- Principal Designers must have a thorough understanding and knowledge of the management of both the technical and H&S requirements through the design process. Their role is to plan, manage and monitor the coordination of the pre-construction phase, including any preparatory work carried out for the project.
- The Principal Designer must advise Client of their CDM duties & to manage their expectations.
- The Principal Designer must help and advise the client in bringing together pre-construction information and provide the information designers and contractors need to carry out their duties;
- If the Principal Designer’s appointment takes them to a certain stage (e.g. planning only), it is important to advise the Client in writing of termination of their CDM responsibilities up to that stage & to make them aware of any continuing responsibilities they may have.
- It is the Clients duty to raise the F10. Where client’s are unable to do so, the Principal Designer can issue the F10 on their behalf.
- The Principal Designer must focus on getting right information to the right people at the right time. They must ensure that everyone involved in the pre-construction phase communicates and cooperates, coordinating their work wherever required and ensure that designers comply with their duties;
- Principal Designer must plan, manage, monitor and coordinate H&S in the preconstruction phase;
- As far as is reasonably practicable, the Principal Designer must identify, eliminate or control foreseeable risk through collaborative work with any other designers on the project.
- Once identified, the Principal Designer must manage the risks and ensure that the design team eliminate the risks associated with design elements wherever practicable. If this is not practicable (e.g. planning restrictions, specific actions, disproportionate costs or aesthetics) efforts must be made to reduce any remaining risks; or control them, to an acceptable level. This relies on exercising professional judgement in considering how the risks can be managed.
- The Principal Designer must liaise with the Principal Contractor in keeping them informed of any risks that need to be controlled during the construction phase.
CDM 2007 exempted domestic clients from most CDM obligations. The CDM 2015 removes this exemption and transfers the client’s obligations to the contractor or principal contractor. Domestic clients can choose to have a written agreement with the PD to carry out the clients’ duties.
Where ‘significant risks’ are identified – keep brief and to the point. Best way to get a message across on site is to annotate the drawings with any H&S-related items. Operators on site aren’t always going to keep returning to the files.
Pre Construction H&S Phase Plan
The plan should not be cluttered with documents (e.g. generic risk assessments, records of how decisions were reached, detailed safety method statements) that get in the way of a clear understanding of what is needed to manage the construction phase. Ask the PC what their Emergency Procedures are – not always thought through.
Keep simple. The Principal Designer is required to manage the process. The Principal Contractor can compile the File as they would normally with reference made to O&M manuals. They are primarily for the purpose of planning future construction from a H&S perspective (e.g. identifying residual risks).
It is not the Principal Designer’s responsibility to: (but may wish to offer any of the following as additional services)
- Submit the F10 notification to the HSE or check that the client has done so;
- Check the skills and experience of the designers or contractors unless the Principal Designer is appointing them directly;
- Advise the client on their appointment of designers and contractor, including their skills and experience;
- Advise the client on their H&S arrangements for the project, including welfare facilities;
- Review or approve the construction phase plan or check that it has been implemented;
- Review or approve H&S arrangements on site, including method statements;
- Take on overall responsibility for the project – the Principal Designer’s role is only to manage H&S during the pre-construction phase;
- Supervise or monitor H&S on site – this is the responsibility of the Principal Contractor;
- Check or approve designers other than when reviewing H&S risks.