Hi,

One of my clients will be starting work on site shortly where they will responsible for their own first aid provision as the Principal Contractor is not providing a first aid facility for sub-contractors.

The CDM Regs do not state that a PC has to but realistically how can every sub-contractor provide their own first aid facilities on site bearing in mind the requirements of the First Aid Regs. I have spoken to the PC who is adamant that my client has to make his own arrangements.

I have never encountered this before and want to know if anyone else has and how it was dealt with effectively. Or am I missing something in any Regulation which I could kick back to the PC?

Thanks

That is certainly a side issue to consider but ultimately my client is actually responsible for the first aid provision for the people in his employ as per regulations. It's not logistically possible for all the sub-contractors on site to provide appropriate first aid facilities.

Is the PC providing first aid cover for his employees? If so why does he not cover your client?

If not who is going to provide first aid for the PC's employees?

What if a visitor to site i.e. the Client has an accident - who will provide first aid ?

IMHO this PC is not fulfilling his obligations as a PC, Ray is correct when he says the CPP should contain arrangements for emergencies including first aid.

What does the CDM-C say about it? Has the CPP been approved? Does it include emergency arrangements?

Aside from all that your client as an employer should be risk assessing his first aid requirements anyway and probably should have at least one first aider if not two just in case the appointed first aider on site goes off site.

JohnW - That is exactly where I am coming from

ChrisBurns - Most of what you say is correct but ultimately my concern is for my client. What legal obligation is the PC not fulfilling though? (Other than a moral one) The CDM Regs do not state that the PC has to provide first aid equipment or first aiders for sub-contractors so realistically it doesn't have to be addressed in the construction phase plan.

If your client is in his own office he should supply the first aid needed therein so why is it different when he is on a site?

This area should be an item sorted at tender stage but F-aid is usually not considered properly in my personal view on any but the largest sites and the PC does not need to provide all things for all areas but should ensure that their subbies [or the clients subbies in many cases] F-aid is managed properly and that is what they appear to be doing in this case


CDMC: The PC's or the *Clients [*Client as defined in the CDM regs] R7 person should be looking at the detail of this area not a CDMC [at this rate CDMC's will take all the R7 persons work off them!!]. All the CDMC should do is to comment on the PCs management plan/system to the Client. Its not their place to evaluate, manage nor check F-Aid facilities & what happens when its not a 'Notifiable' site as the F-aid regs still apply but CDMC's are not present

Your client is responsible for his own people. At tender stage the PC may have/have not included the provision of F-Aid as part of their role on site; if they have not said that they will cover this area then your client must manage the area for their own staff and those that may be effected by their work

***CDM Regs should state that it is the PC's responsibility****

CPP should be reviewed by CDM-C who then recommends acceptance by the Client.

If the PC refuses to provide first aid for the site then dont provide it yourself and report the matter to HSE and see what they say.

http://www.hse.gov.uk/co...ruction/faq-firstaid.htm

The Health and Safety (First Aid) Regulations 1981 require all construction sites to have:
a first aid box with enough equipment to cope with the number of workers on site;
an appointed person to take charge of first-aid arrangements; and
information telling workers the name of the appointed person or first aider and where to find them. A notice in the site hut is a good way of doing this.


If this does not make it clear then what does?

Also see Ray's post above.

What is a PC if not responsible for the whole site and project.

Forget the CPP for the moment and go back to your contract and see if the first aid provision was identified there as being your responsibility - if it is there you are deemed to have priced this for your employees so it must be done. If it is not therethen present the PC with the additional figure for provision.

Whatever the PC states he should have planned provision for his own staff and all site visitors who are not employees of any contractor on site. I know that many multinational PCs do go this route

Bob

John

Sorry to disagree the CPP has to match the subcontract with the individual sub/trade contractors if the contract makes no mention of the specific first aid requirements then the CPP is mere words to impress the client and has no legal enforceability. If F/A is placed on the individual sub/trade contractor in the contract with the PC then they are responsible.

James

Without reference to F/A in some way in the contract any reference in th CPP that the subcontractor provides is all Hot Air. Far too many PCs do try this on - the shared welfare arrangements form under the old regulations was the best solution but sadly is now defunct. PCs need to learn to be clear and fair to all tendering subcontractors. If they want F/A provision priced then they should make this clear.

The alternative is for all subcontractors to price in F/A whatever is said and drive all prices up. Let us remember though that your risk assessment should identify the level of provision NOT the PCs ideas of what will be done - unless specifically contracted. At the end of the day this is also a commercial decision

Bob

I believe that the Client and or CDM-C should have ensured first aid was organised by the PC prior to allowing the project to start.

CDMM Regs do not require first aid at all.

See post #15 above. This is where IMO the PC has responsibility for ensuring.

Not necessarily providing but would be in neglect of PC duties if no first aid is arranged.

Bob and all, I currently work for a large retail organisation auditing their shop fit programmes, some 30 or so every year.

My audit "tick list" has questions re first aider and kit etc. If there is no such first aider nominated on site this is mentioned in the report.

During the past three years all PCs - six in total - have introduced their own first aiders.

This from pressure from me supported by the Client.

It's not rocket science and isn't very expensive to have a couple of workers trained in first aid.

I believe the HSE Inspector would have a very dim view if any PC does not have first aid cover on any site they visit.