Under CDM is fencing 'a structure'?
We are renewing fencing around several dozen estates. This will more than likely be over 500 man days and or 30 days.
The CDM regulations in the interpretation of "structure”, at least to me, is not clear.
I have to admit that any interpretation or definition of a word, that contains the original word is odd, here it is mentioned 5 times!

The regs apply whether it is reportable or not, it's just that you need to do a little more if it is reportable. The regs are wide ranging and apply to pretty much all building work and I would include permanent fencing in that

If, as ROn suggests, the whole project is divided into smaller 'non reportable' chunks then you don't need the CDM-C, PC etc. But, even then, the job needs to be done safely and that is what the CDM regs are there to provide

And a final word on the Health and Safety File. On a Project of that nature, I would expect the extent of relevant information to be gathered for the Structure* File to be conceivably..........nothing.
Going back to the original thread, a Local Authority could conceivably choose to determine that an entire Estate of domestic Housing is to be managed as a "Structure" for the purposes of the CDM Regs.
With just a little thought we can achieve exemplar compliance whilst entirely avoiding needless bureaucracy.

In most cases fencing does not constitute "structure" as the are not foundation based - more then often, they are held down by sand bags! and are mobile contructions - why is this conversation dealing with CDM-C for the erecting of "fencing" are we not being a bit OTT here PLEASE

If site clearance at the beginning of a project is considered "construction" work for the purposes of CDM then surely the erection of permanent fencing must also be considered "construction". It is surely considered as a permanent fixture.

To consider the work being carried out on several sites makes it notifiable is nonsense, presuming of course that the work at each site does not meet the notifiable requirement of 30 days or 500 man hours.

It does in my opinion fall under CDM, but not notifiable. Is it "reasonably practicable" to spend as much money on beauracracy as actually erecting the fencing?

Beauracry=The Cost
Fencing = The Risk

The cost being: CDM/C fees for each site, CPP for each site, TMP for each site etc.

The risk being: Injury from erection of fencing i.e Low providing CDM regs have been adhered to.

Notification is unecessary and not reasonably practicable.

I don't disagree with you about bureaucracy at all, although I am not sure if that was why cdm was revised or not. However, in fairness your previous post "Is it "reasonably practicable" to spend as much money on bureaucracy as actually erecting the fencing?" was clearly comparing cost with cost, NOT cost with risk.

I tend to agree that notification is probably not necessary in this case, although thereis fencing and there is fencing and none of us are really aware of all the facts so we can't be certain. But notification is just that; notification. IF a project meets the requirements for notification (I am not going to argue whether this example does or not) then it should be notified. While I accept that the notification requirements are probably a rather blunt instrument used to try and differentiate between the higher risk jobs, there is NOTHING in CDM that says that notification is determined by whether something is RP or not. The notification requirements are set out in very simple terms.

I wonder how you would even begin to construct a defence for not notifying a notifiable project by claiming that it wasn't RP? Surely RP has not part to play in the notification requirements of CDM as they stand? erent things.

Phil - see para 2

Why oh why do we always associate CDM with costs and bureaucracy? All that CDM requires is that the work isa properly planned and managed - what is the problem with that. There are many ways to deal with a large series of small projects and we are now seeing a sector trying desperately to reinvent those already established systems that had been used since 1994.

Management plans can be as small as a single sheet of A4 if well written

Bob

Well... there was some discussion here!

Many thanks for all your replies, it was interesting to read the back and forth discussion.

It was just the words 'structure' didn't seem, to me, to apply to a fence, but clearly it is considered within the profession to apply. (I also couldn't get my head round a definition that contained the word being defined 5 times).
I feel that we don't want to split up the job, so we have decided to take on the role of duty holder ourselves, as Ron says it is a big job but relatively low-risk and non-complex.