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CarolC  
#1 Posted : 07 June 2013 12:20:10(UTC)
Rank: New forum user
CarolC

We are scheduled to refit a supermarket in July but on scoping the project we found asbestos material that required emergency removal. Now that the offending material has been removed, we are required to make good the area and install fire lining to improve the store’s compliance status prior to the main refit. There will be a gap between these works and the actual refit, and as such they could be regarded as totally separate minor works, not requiring a CDMC. However, my understanding is that these additional works are on the basis of a variation to the PO for the refit and not on a separate PO, so in an effort to ensure that we are not in danger of breaching the CDM regs I contacted the CDMC for the refit to ask them to raise an F10, because if it is to be taken as one continuous project it will exceed the 30 day threshold. The CDMC is now saying we should not start on site on Monday as it is too short notice for the HSE to digest the notification and the earliest they would advise SOS would be 17th, to give them (CDMC) time to assess the project plan. It is not unheard of for short notice to be given to HSE in the event of a project’s status changing. The HSE will already be aware of the work at the store from the notification of the Asbestos removal work. Surely the important thing is that we are making the store safe, and that we have suitable and sufficient RAMS for our people to work safely on site and maintain the safety of the store team and general public. I would suggest that we should be allowed to start on site initially with some site-specific and task-based RAMS that should be suitable and sufficient for the minor remedial works. The project plan can then be developed and enhanced for the main refit work later on. I would be interested to hear other opinion on this: The crux of the matter appears to be whether these are 2 separate jobs or one continuous one, and if the latter, whether short notice to HSE is acceptable?
yulkok  
#2 Posted : 07 June 2013 12:39:18(UTC)
Rank: Forum user
yulkok

Surely as the project has now become notifiable you cannot start on site until such time as the CDMC says that the health and safety plan has been sufficiently developed. Regards Yul
CarolC  
#3 Posted : 07 June 2013 12:55:34(UTC)
Rank: New forum user
CarolC

But how developed would it need to be to be sufficiently developed? A project plan is an evolving piece of work and is amended, updated and upgraded to suit the development of the project. I would still suggest that initially some site-specific and task-based RAMS should be suitable and sufficient for the minor remedial works, backed up with the store's existing emergency fire plan being adopted by the site operatives. The project plan can then be developed and enhanced for the main refit work. Quote from the ACoP: “4 The effort devoted to planning and managing health and safety should be in proportion to the risks and complexity associated with the project. When deciding what you need to do to comply with these Regulations, your focus should always be on action necessary to reduce and manage risks. Any paperwork produced should help with communication and risk management. Paperwork which adds little to the management of risk is a waste of effort, and can be a dangerous distraction from the real business of risk reduction and management.”
hserc  
#4 Posted : 07 June 2013 13:53:12(UTC)
Rank: Forum user
hserc

As far as I can see, the only stipulation as to what point in time a notification has to be made is, as soon as practicable after the appointment of a CDMC. Also having a fixed time before works commencing is not consistent with the other rule, of a project becoming notifiable after it starts. The time for the HSE to "digest" the information is in any event irrelevant as the F10 is not seeking permission to commence, it is only a notification that certain construction work (which otherwise we need not have mentioned to anyone at all) is subject to an F10.
Lundkvist  
#5 Posted : 07 June 2013 13:59:06(UTC)
Rank: Forum user
Lundkvist

I agree with hserc, there is no minimum time period you have to leave between notifying the HSE and starting the work as long as it is done BEFORE. I guess in principle you could send the F10 in, have a cup of coffee and a read of the paper (maybe catch a couple of rays in the nice weather lol) then get on with your construction. It may not be best practice but there is nothing strictly speaking in the law to stop it.
achrn  
#6 Posted : 07 June 2013 16:02:15(UTC)
Rank: Super forum user
achrn

yulkok wrote:
Surely as the project has now become notifiable you cannot start on site until such time as the CDMC says that the health and safety plan has been sufficiently developed. Regards Yul
What's a health and safety plan? If you mean the construction phase plan, I refer you to ACOP para 108 c - "CDM co-ordinators don't have to ... approve the principal contractor's construction phase plan, although they have to be able to advise clients on its adequacy at the start of construction". So the CDM-C can advise the client that he hasn't had time to comment on the construction phase plan, but it's the clients duty to ensure an adequate plan is in place, so if the client is satisfied of that without the CDM-C's comments, then the law is satisfied, is it not? I agree with everyone else that the notion that the HSE needs time to digest an F10 is nonsense. Sounds like a CDM-C making up excuses in order to give himself more time to do his work.
CarolC  
#7 Posted : 07 June 2013 17:36:41(UTC)
Rank: New forum user
CarolC

Thanks everyone, good to have my opinion vindicated Carol
riskybizz  
#8 Posted : 11 June 2013 08:33:03(UTC)
Rank: Forum user
riskybizz

IMHO CDM will improve when re-written in 2014
allanwood  
#9 Posted : 11 June 2013 10:06:36(UTC)
Rank: Forum user
allanwood

riskybizz - would you care to enlighten us as to why you think the CDM review will improve things?
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