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Posted By Kenneth Patrick
Colleagues, is it normal practice in manufacturing/chemical industry to apply the CDM regulations to the variety of work done by contractors during the facility's annual shutdown.? Typically this will involve disparate work from machine maintenance, vessel cleaning, installation of new equipment to calibrations and painting. There would be about say five to ten different contracting companies in over the two weeks and each could have 2-10 people. The numbers involved can be caterered for within the facility's normal welfare arrangements.
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Posted By Crim
Kenneth,
You need to decide if the work is within the definitions of construction as per the CDM Regs.
I have been involved with manufacturing and shut downs and my view would be no it would not.
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Posted By Bob Youel
Thanks K for your input but I feel that all but the smallest of such jobs do come under CDM 2007
I advise a re-read of the regs to confirm & try to get an opinion from the HSE
The problem is that most civil / building construction experts have no knowledge re manufacturing nor electro / mechanical construction areas [inclusive of [reference removed]] -
Some CMIOSH people have noted to me that there is no such area as electro/mechanical construction areas!& the CDM regs were written with brickies etc in mind!
Irrespective of the comments above; all works require adequate management systems to be in place & CDM management systems can be used in all kinds of situations
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Posted By Andrew Brown
This comes down to the definition of 'construction' work (see definitions from regs and ACOP below).
If it is construction then part 2 and 4 of the regs will apply.
If you then get over the 30 construction days or 500 man days then part 3 will apply as well. In your case the numbers you give would not reach this, although you would need to count the plants own personnel involved in the shutdown as well.
CDM 2007 Reg 2
"construction work" means the carrying out of any building, civil engineering or engineering construction work and includes—
a) the construction, alteration, conversion, fitting out, commissioning, renovation, repair, upkeep, redecoration or other maintenance (including cleaning which involves the use of water or an abrasive at high pressure or the use of corrosive or toxic substances), de-commissioning, demolition or dismantling of a structure;
CDM 2007 ACOP Para 13
'Construction work is defined in the regulations. The following are NOT construction work as defined:
b) general maintenance of fixed plant, except where this is done as part of other construction work, or it involves substantial dismantling or alteration of fixed plant which is large enough to be a structure in its own right, for example structural alteration of a large silo complex chemical plant, power station generator or large boiler.
As you can see 'maintenance' is in in the Regs e.g. building maintenance. The ACOP clarifies maintenance with regard to fixed plant.
There is a change here from CDM 94 where maintenance of fixed plant wasn't construction. The caveat of 'fixed plant large enough to be a structure in its own right' is new to 2007.
I would expect major shutdowns on large plants to be 'construction' and usually cross the notifiable project threshold
However the case you describe sounds like something smaller in terms of plant maintenance. Any building maintenance work done at the same time would still be construction though and part 2 and 4 would apply.
Hope this helps
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