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ron hunter wrote:achrn wrote:paulw71 wrote:
So In March, at a coniac meeting, the HSE announced that there where looking at how to take forward the CDM regulatory package. What exactly do you think that meant if not revise the regulations. (change the font in the acop perhaps ?
Revision of the ACOP, which had been discussed. Possibly publication of some guidance, which had alkso been discussed. Not rewriting the regulations, which had not been discussed. Since Lofstedt said don't change the regs, and since the evaluation had not been published yet, and assumption that "how to take forward the CDM Regulatory package" means "how we are going to revise the regulations themselves" would be completely unwarranted. There was NO announcement of any intention to revise the CDM regulations until it was announced at an APS CPD event. That is the fact of the matter. There was an open Meeting in June or July to announce just that. Problem being that HSE haven't published a Minute of that Meeting, and the little they have made public is somewhat buried within their website. Hi Ron I contacted HSE about this and they told me that the minutes of the previous meetings are agreed as accurate and published after the next coniac meeting which I believe will be in November sometime so we can expect to know more of what was discussed then. regards
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From Septmber board meeting: http://www.hse.gov.uk/ab...013/250913/psepb1387.pdfWork to revise the Construction (Design and Management) Regulations 2007 (CDM) has continued. A revised CDM regulatory package was presented to the Board in May 2013. Subject to consideration of a detailed communications strategy, the Board agreed to consider approval of a proposed 12-week consultation period commencing late summer 2013, with a view to new regulations coming into force in October 2014. Key elements of the draft proposals include: a structural simplification of the Regulations to make them easier to understand and navigate (particularly for SMEs); and removal of the Approved Code of Practice, the CDM co-ordinator role and explicit competence requirements. A further key element is a proposal to remove the domestic client exemption, but create a default position whereby duties, which would fall on a domestic client, would instead fall to the designer or contractor. CD has engaged extensively with stakeholders in the period leading up to the planned consultation, and a clear picture is emerging of industry understanding and support. The package is now going through the several stages of Government clearance required prior to opening the public consultation.
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Out of curiosity will the Government be paying redundency pay to all registered CDM Coordinators as their job will no longer exist?
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But in yet another case of exactly the sort of thing I'm complaining about - the HSE in various unofficial non-minuted events and similar is actually saying something different. CONIAC says it's going ahead, but all the rumours, apparently arising from off-the-cuff statements and asides at things like APS CPD events, is that nothing will actually happen until late 2014. So once again, it seems that the real communication path from HSE on this critical matter is obiter dicta at non-HSE events such as APS CPD meetings.
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Rank: Super forum user
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MEden380 wrote:Out of curiosity will the Government be paying redundency pay to all registered CDM Coordinators as their job will no longer exist? It was always stated that CDMC was not a profession so why should there be a right to redundancy ????
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The latest update to the APS breaking news section seems to re-iterate the content of this thread:
"Our latest intelligence is that CDM2014 is more likely to be CDM2015 as it is unlikely that any change to legislation will come into force until 2015. With an election in May 2015 it is possible that it may be an October 2015 enactment."
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Rank: New forum user
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I have sometimes found "news" from APS to be skewed towards what they would like to hear or else an interpretation from their perspective. Here it does not seem to have been referenced properly. I suggest therefore that HSE information direct from HSE is likely to be more accurate. It is very frustrating that HSE seems to assume that everyone in construction is a Member of APS . Also frustrating that HSE uses regional meetings of member groups to make announcements that affect all industry and possibly the public too.
However, IOSH is not the only fish in the sea, either. There used to be over 40 engineering institutions, many of whom will have a strong vested interest in changes to regulations that affect their members. Perhaps HSE should focus on their own direct communications.
In terms of HSE growing up, this is my opinion. It is based on conversations with senior HSE inspectors but also, in terms of CDM, I have long held the view that H&S needs to be properly integrated into design and delivery (construction). We H&S professionals may have been too successful on the one hand, educating our industries so they no longer need us, and too overbearing on the other, using the tactics of fear and dictat inappropriately so that industry has felt smothered in spurious paperwork. I believe that technical professionals like architects and engineers in the construction industry have begun to engage properly with HSE who in turn have "Grown up". I probably mean that their views have become more aligned to mine! They are looking at the design processes, they recognise that no designer can design out all hazard, they are considering complex management issues such as leadership and culture. They are realising that with over 200 sets of Regulations fairer enforcement across them all is reasonable. (Evidence here is that CLAW is being taken seriously now as well as CAW, COSHH etc. They are advertising for technical specialists to strengthen that knowledge base.
I do not agree with FFI because it skews what inspectors look for. They look for simple material breach rather than more subtle matters and push us back to tick box H&S. I now find that I have to advise clients to have far more paperwork than is sensible to workable H&S to satisfy the HSE inspectors. A backward step in my view and possibly one that will add fuel to the fire of getting rid of HSE all together except for major accident investigation and for licensing of major accident hazard sites. [Deleted the rest of my hobby horse]
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Rank: Forum user 
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Dear All
I attended the CONIAC meeting in July when the CDM regulatory package was discussed. Some of the CONIAC committee members had expected a draft revised ACoP and other supporting documents. Once the meeting started it became clear that this was not going to happen. The rest of the time spent on this item covered how the consultation would be carried out.
While several committee members weren't exactly happy about this, it was accepted. It was clear that the draft proposals had to go through some more administrative processes at the Minister/Regulatory Review level and more work on the Regulatory Impact Assessment was needed. It was anticipated that the three month consultation period would start 'in the Autumn'. (I have to admit I was guessing at September.) It was proposed that this would allow sufficient time to take the comments, make any changes and present the findings at the February HSE Board meeting. The aim was to have the new ACoP in place by October 2014.
As we approach November, the February 2014 Board meeting now looks a tad optimistic. Historically those on HSE advisory committees used to identify a need, get confirmation in their work programme, work through the detail and present a draft with the Regulatory Impact Assessment. Now various stakeholders 'informally' consult on a draft (I understand that the proposed draft not tabled at the CONIAC meeting was number 32) and those on the outside of the 'informal' consultation can pick up snippets from others sources, such as the APS website. I'm assuming this is what people call progress.
One should not get too excited about this: the UK Government procurement process for building two massive aircraft carriers is going to deliver us two massive aircraft carriers with no aircraft to go on them! Maybe we will end up with some Construction (Design and Management) Regulation ACoP with no Design and Management in them. If nothing else, it would reduce the 'burdensome Red Tape'.
Cheers.
Nigel
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Rank: New forum user
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Conjecture Conjecture. Lets just wait and see what transpires during the process. In 2007 the naysayers were abundant and what really changed ??? There will always be a need to coordinate H&S Aspects of design and there will always be a need to coordinate H&S During the construction. Lets not jump the gun!!
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