colleagues; what are your thoughts as this is another opptunity not to be lost so get your 2 pence in re CDM My thought is that the MHSW reg 7 person should be included in the regs as a reference point if nothing else as its only they who have the all round view

Bob, In the past we could have expected those poorly performing areas of these regulations to be strengthened and the ACOP re-drafted, however in the current political environment my hunch is that we are looking at a complete re-drafting along the strict lines of the Directive. I suspect that the final version of these new Regulations will be very thin, ambiguous and it would not surprise me if there were no ACOP. As a Senior CDM-C this does leaves me wondering our future role!

The one thing that definitley needs sorting out is the numerous PQQs that we get asked to complete. I think that the government & the HSE need to take a stance on this area and throw their weight behind one or more of the better schemes out there such as safety schemes in procurement with more inter-recognition across such schemes. When i was working for a specialist sub contractor (not that long ago) we held CHAS, Achilles, Construction line (to name but a few) but we were still expected to complete company specific PQQS and even some site specific ones (on larger projects).

I second this, its a joke, and different contractors using different PQQ's but still have the same information, its time consuming. And then themain contractors have different requirements such as having to have CHAS, or Achilles, or BSI etc etc etc....Its also a money racked, and paper trail, when it comes down to it the paperwork has nothing at all to do with the company safety performance/ committment, it just looks good.

Hardly the fault of the Regs or the Regulator that Clients and Principals have failed to embrace the value of commercial pre-qual schemes. I do wish people would stop knocking these pqq schemes -they are to everyone's advantage if recognised and used properly. PQQs do not give whole assurance of competency, stage 2 (project/task specific) assessment is crucial. PQQ intended to free up people's time to focus on stage 2 (and on task performance). Some out there of course are asking for the impossible - essentially looking for legislation that says the cheapest quote cannot win. Let's be honest people: Price is King.

Achrn It appears that your sources are on the ball. Section 11 of the following HSE paper states that competence within the regs goes beyond the requires of the Directive: http://www.hse.gov.uk/ab...iac/200612/m2-2012-2.pdf

Thanks for that link richp. Something is sadly wrong here. On the one hand, the CDM Regs are blamed for poor performance in the smaller construction side, and on the other blamed for “over-compliance” regarding competency issues. I don’t believe either of these issues can be said to be the ‘fault’ of a set of Regulations. Something is very wrong when a Government so hell-bent on reducing red tape sees fit to subject the Construction Sector to yet another step-change in regulation. Change is expensive (and confusing). There are those still coming to terms with change between 1994 and 2007! Looking at the terminology and language of the parent Directive, this proposal for a more straightforward transposition of the Directive will result in yet more unnecessary confusion and cost. Yet another Training Industry Merry-go-Round of misinformation and misinterpretation may ensue, particularly if the HSE are tardy in publishing a revised ACoP ( I give you CAR2012 and NNLW as an example of reigning confusion) Sad too that with the passing of the semi-autonomous HSC, the HSE can no longer stand up to these political pressures and resist such nonsense. This proposal will be expensive – and all for the sake of compliance with political dogma. Constant tinkering with Statute cannot improve H&S performance in the Industry. Law is for lawyers. In practical, everyday terms it doesn’t matter if we have 200 or 500 pieces of legislation. All that matters is that employers and employees have decent access to quality guidance, training and advice.

I'd suggest that poor performance on smaller sites is generally due to a lack of commitment, interest or understanding at this level, compounded by weak enforcement and action.

Whist many of us may well have ideas for improving the current regulations, however much of discussion taking part on this thread is irrelevant if the objective of this exercise is tied up in our current Government’s dash to reduce the burden of red tape on businesses. From reading the press releases, my own assessment of the situation is that the HSE have been instructed to go back and draft a new Statutory Instrument just based upon the basic requirements of the original EU Directive. On this occasion I am not expecting the HSE to even issue an ACOP or any formal Guidance. As a senior CDM-C, my immediate concern is when I start to make my move for the exit. I do hope that I am being over pessimistic, but my strategic intuition has placed me firmly in this camp.