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achrn  
#1 Posted : 16 December 2013 15:49:12(UTC)
Rank: Super forum user
achrn

Another bit of information about the progress on CDM update dribbles out. Now it's 2015, and the CDM coordinator role is going:

Judith Hackitt addressing the Westminster Legal Policy Forum on 5 December:

"2014 will also see us embark upon some changes to CDM as part of the guidance overhaul. It will not significantly change the technical standards which underpin the Regulations – they are not controversial and have stood the test of time. We are simply intending to streamline their delivery.

"The revision which we are preparing to consult upon is underpinned by four priorities: simplify the package to make them easier to understand and comply with; achieve satisfactory transposition of the parent Directive; improve their accessibility for small sites; improve standards of worker protection through the above.

"Overall we believe that the revised package will deliver significant savings to businesses through the streamlining of processes and the removal of the CDM co-ordinator role will be much more accessible to those involved on small construction sites due to the simpler structure of the regulations. The production of guidance has the needs of small businesses at its heart to deliver satisfactory transposition of the parent Directive and improve worker protection.

"Current plans are for the revised Regulations to come into force in April 2015 and formal consultation is expected to start early in 2014."

http://www.hse.gov.uk/ab...cripts/hackitt051213.htm
PH2  
#2 Posted : 16 December 2013 16:15:06(UTC)
Rank: Super forum user
PH2

Thanks for the heads up.

PH2
bob youel  
#3 Posted : 16 December 2013 17:13:08(UTC)
Rank: Super forum user
bob youel

standards dropping all over the place - nothing new then
firesafety101  
#4 Posted : 16 December 2013 20:33:12(UTC)
Rank: Super forum user
firesafety101

So are they saying there was never a need for CDM C in the first place?

allanwood  
#5 Posted : 17 December 2013 08:06:05(UTC)
Rank: Forum user
allanwood

There may be trouble ahead!

redken  
#6 Posted : 17 December 2013 08:59:06(UTC)
Rank: Super forum user
redken

Thanks for the link, I though was more interested in this quote from her speech. The last sentence will be very controversial for many large organisations.

"Just as we are doing in HSE there’s a need for everyone to take time to ensure that they are focussing on the real priorities – the real hazards that could cause serious injury or damage people’s health. Paper cuts incurred in the office and unlikely to be life threatening so why do so many organisations respond to them by conducting a full investigation?

This is partly about recognising that some of the risks are harder to tackle – health, process safety – but this is where you will have much more impact on outcomes in terms of prevention of harm to people. But its also about having the courage to let go of the trivial – the things which have become part of the drive for “continuous improvement” even when you have reached the point of seriously diminishing returns."
MEden380  
#7 Posted : 17 December 2013 09:39:14(UTC)
Rank: Super forum user
MEden380

Does this mean all Registered CDM Coordinators are going to be pensioned off by the HSE - Where's my sandals and deck chair, early retirement whoopee - I don't think so
Yes simplify, yes ensure small construction projects are brought in to the fold - who is going to ensure the procedures are to be followed. Oh I forgot FFI - more small projects , more material breaches, more money, more fee collectors. Or am I just being realistic ?
allanwood  
#8 Posted : 18 December 2013 08:16:25(UTC)
Rank: Forum user
allanwood

Under the Construction (Design and Management) Regulations 2007 (CDM), there is a legal requirement for the client to appoint a CDMC. However, following the recent review of legislation carried out by Professor Löfstedt, it is anticipated that the CDM Regulations will change — despite Löfstedt stating that the CDM Regulations are generally “fit for purpose”.

It is widely believed that the HSE will carry out a 3-month consultation period similar to the others that have recently been held for COSHH, DSEAR and other key pieces of legislation. Changes were expected in 2014, although it is now speculated that this may be pushed back until 2015, and of course, any changes will need parliamentary approval.

It is anticipated that changes will include the removal of the CDMC role, placing the design phase and health and safety co-ordination with a “principal designer” (this new role has yet to have a formal title assigned), and the removal of the competence assessment criteria found in Appendix 4 of the regulations.

The construction phase co-ordination duties are likely to be assigned to the principal contractor, and client duties for domestic projects are anticipated to lie with the first appointee (eg the architect or the contractor). Another aspect that is likely to change is the introduction of the full application of the CDM Regulations to all projects with more than one contractor on site; this will also include all domestic projects.

While the Löfstedt report was intended to improve and remove duplication from current health and safety legislation, the removal of the CDMC has caused some controversy among the industry. There are some who believe that good CDMCs improve health and safety on construction sites, in addition to improving timescales and keeping costs in control. Others meanwhile, believe that the removal of the CDMCs will streamline processes.

Whatever your thoughts for now, the current regulations must be adhered to and so a CDMC must be assigned when the project is notifiable to the HSE. A project is notifiable if the construction phase will be longer than 30 days or 500 person days (domestic clients are the exception).

the above is an extract from croners that i recieved this morning and leads to the following questions:

1. if professor lofstedts opinion was that the CDM regulations where "fit for purpose" why in times of austerity are we spending vast sums of money re-writing the CDM regulations when a possible few amendments would have been more than adequate to bring them up to speed with what would be required of the origional european directive?
2. is it not down to poor interpretation of what is required by the CDM regulations that is the problem? and if this is the case why aint we tackling this matter head on, and issuing revised guidance on the matter?
3. if the government is so anti european why are we rolling over to europe again?
4. or is this just attack on "elf n safety" for the sake of political point scoring by the government?

achrn  
#9 Posted : 18 December 2013 10:33:46(UTC)
Rank: Super forum user
achrn

Croner are out of date - things they say are 'anticipated' are now stated by Judith Hackitt - see teh speech transcript.

allanwood wrote:

1. if professor lofstedts opinion was that the CDM regulations where "fit for purpose" why in times of austerity are we spending vast sums of money re-writing the CDM regulations when a possible few amendments would have been more than adequate to bring them up to speed with what would be required of the origional european directive?
2. is it not down to poor interpretation of what is required by the CDM regulations that is the problem? and if this is the case why aint we tackling this matter head on, and issuing revised guidance on the matter?
3. if the government is so anti european why are we rolling over to europe again?
4. or is this just attack on "elf n safety" for the sake of political point scoring by the government?


1: because it looks good in the Daily Mail. Lofstedt basically said "nearly all of it is fine and fit for purpose, I recommend do nothing much" and the government response was "we welcome Lofstedts recommendations and we will eliminate 87% of health and safety legislation".

2: To some degree, but the CDM-C role is not explicitly required by the directive. Arguably, much of the poor interpretation is propagated (or encouraged) by CDM-Cs

3: Because saying you're anti-european looks good in the Daily Mail, but really no rational person would actually takes us out of it.

4: See - you knew it was because it looks good in the Daily Mail all along.
MrsBlue  
#10 Posted : 18 December 2013 10:48:14(UTC)
Rank: Guest
Guest

Quote "Because saying you're anti-european looks good in the Daily Mail, but really no rational person would actually takes us out of it" unquote.

achrn - by stating this you are saying that the majority of the UK population are not rational.

Also it is the Daily Express who are crusading for the UK to leave Europe - in this instance give the DM a break.

Rich
achrn  
#11 Posted : 18 December 2013 13:46:22(UTC)
Rank: Super forum user
achrn

Rich777 wrote:

achrn - by stating this you are saying that the majority of the UK population are not rational.


I disagree. If you actually set out the issues, pros, cons etc. I don't believe a rational person would take us out of it. If you could actually get all of the UK population to look at the implications of a full withdrawal from the EC, I remain of the view that the vast majority would stay in.

The people that have actually looked at the implications of how the country would proceed if withdrawn from the EC are the political parties. All but the mainstream parties are in favour of us remaining in.
Bruce Sutherland  
#12 Posted : 18 December 2013 18:20:31(UTC)
Rank: Forum user
Bruce Sutherland

heck may be we need to pre-empt devolution in Scotland next....
MrsBlue  
#13 Posted : 19 December 2013 08:45:29(UTC)
Rank: Guest
Guest

I shall not labour the point concerning the political side of this discussion other than I must be watching alien TV and listening and reading news stories which don't exist on "achrn"s earth.

To get back to CDM my experience of them (only 3 which is a very small sample) considered the roll "money for old rope"

Rich
achrn  
#14 Posted : 19 December 2013 09:50:56(UTC)
Rank: Super forum user
achrn

Rich777 wrote:
I shall not labour the point concerning the political side of this discussion other than I must be watching alien TV and listening and reading news stories which don't exist on "achrn"s earth.


If it's such a no-brainer and everyone is really in favour of full exit from the EC, why are we still in it?

It's because actually, it is to the country's benefit, and everyone knows that really. The only people that say they will withdraw from Europe are the ones that think they'll never have to deal with the consequences. Rather like the lib-dems pledges over tuition fees. It's easy to sound grand when you know you'll never have to actually put up.
Hart41323  
#15 Posted : 19 December 2013 10:27:06(UTC)
Rank: New forum user
Hart41323

As with anything there's good and bad. The worst I've experienced is direct from designers. I see large sites continuing as they have, smaller sites getting away with what they can and the HSE hoovering up a lot of FFI on domestics who won't even know what hit them.

A short headline will trumpet 'CDM Regulations slashed' and no one will realise the downside for domestic jobs until its too late. I think a revision of the regs is sensible but to change this much when people are workign to a system which does the job pretty well in most cases is a backwards step.

Sorry - don't have anything to say on Europe or the Daily Mail / Express.
achrn  
#16 Posted : 19 December 2013 11:12:45(UTC)
Rank: Super forum user
achrn

Hart41323 wrote:
As with anything there's good and bad. The worst I've experienced is direct from designers. I see large sites continuing as they have, smaller sites getting away with what they can and the HSE hoovering up a lot of FFI on domestics who won't even know what hit them.


Yes, I agree with this. I've relatively recently had quiet a lot of building work done on my house. I appointed what I thought was a decent builder, who was well recommended (actually the second most expensive quote). When I was living on site I was continually nagging the builder about things (mainly work at height - their access to the roof for example). I wasn't living there for most of the build, but when I did drop in I was still picking them up on stuff towards the end of the project. If I can't make them do it right, what chance a naive domestic client who doesn't know what 'right' looks like? Some domestic clients are going to be gobsmacked to employ what they thought was a reasonable builder and then get hit with penalties from HSE, if HSE decide the client role has not been fulfilled.

Hart41323 wrote:
I think a revision of the regs is sensible but to change this much when people are workign to a system which does the job pretty well in most cases is a backwards step.


The comment I gave on the last CDM review / consultation basically boiled down to that they aren't perfect, but we've finally reached the point where nearly everyone in most of the industry at least knows what they ought to be doing, so on no account should they be tampered with now.
Steve e ashton  
#17 Posted : 20 December 2013 12:49:04(UTC)
Rank: Super forum user
Steve e ashton

"Its also about having the courage to let go of the trivial – the things which have become part of the drive for “continuous improvement” even when you have reached the point of seriously diminishing returns."

From Judith? The phrase 'physician heal thyself' springs to mind...

How many 'material breach' invoices for FFI are based on obviously trivial bureaucracy rather than real risk to life and limb? I have seen one 'Material Breach' letter which openly acknowledged that no significant risk had been identified (despite the combined best efforts of an Occ Hygiene specialist and a process engineering specialist as well as the Generalist inspector over a combined total of four days on site!) - yet went on to impose a fee for inability to produce largely irrelevant paperwork..
carrwood  
#18 Posted : 23 December 2013 06:49:14(UTC)
Rank: Forum user
carrwood

So is this the thin edge of the wedge? Eliminate the interfering CDMC and no more H&S problems in construction.

So prof could you look at getting rid of these interfering safety practitioners next, just cost us money what with their stupid ideas on protecting people, not forgetting the fortune they cost in salaries.

Well yes, Prime Minister it maybe difficult, but if we succeed in getting rid of the CDMC who knows what is achievable, thinking out loud Prime minister what about all those Environmental Advisors we could start scare stories about them next, jus a thought PM.


You couldn't make it up!
allanwood  
#19 Posted : 23 December 2013 10:07:12(UTC)
Rank: Forum user
allanwood

So the role of the CDM-c has been confirmed as going in the review, and what are they going to replace it with - low and behold a lead designer!!!
In my experience most designer are just not interested and will gladly leave health and safety to be dealt with by others, so theres not gonna be much improvement with this piece of the review then is there?

Another politically motivated legislative review rather than one based on continuous improvement in my humble opinion i just wonder what professor lofstedt would have to say about this? and whether or not he regrets getting involved with the legislative review/cull we are currebtly seeing.
boblewis  
#20 Posted : 23 December 2013 14:00:30(UTC)
Rank: Super forum user
boblewis

I suppose we need to remember that IDS is in charge of the DWP, at least I think so, so we can be sure all changes will be chaotic as has been the case in other DWP areas.
achrn  
#21 Posted : 27 December 2013 08:23:41(UTC)
Rank: Super forum user
achrn

carrwood wrote:
Eliminate the interfering CDMC and no more H&S problems in construction.

You couldn't make it up!


The outrage would be more solidly founded if introducing the CDM-C had eliminated any problems from construction. I haven't yet seen any evidence that CDM-Cs have resulted in a marked improvement in construction safety. Presumably you are able to share some?

allanwood  
#22 Posted : 29 December 2013 16:23:32(UTC)
Rank: Forum user
allanwood

Could this be that the cdmcs yu have encountered have not been fully empowered by the client?
achrn  
#23 Posted : 30 December 2013 08:04:21(UTC)
Rank: Super forum user
achrn

allanwood wrote:
Could this be that the cdmcs yu have encountered have not been fully empowered by the client?


I'm not talking about the CDM-Cs I have encountered, I'm talking about the construction industry overall.

Does your statement mean you do have evidence that the creation of CDM-Cs (specifically, not the existence of the CDM regs) has resulted in a marked improvement in construction safety? Would you care to share it?
allanwood  
#24 Posted : 30 December 2013 09:55:46(UTC)
Rank: Forum user
allanwood

In my humble opinion up until late 2007 early 2008 health and safety was making good and effective progress part of which was the implementation of CDM 2007 and the role of the CDM-C.
However the CDM-C role will only be effective if the appointee is fully empowered by the client and he /she focuses on his/her role and function rather than over emphasis on paperwork and buerorcracy (as mentioned in CDM 2007).
I have seen and worked with some very good CDM-Cs and also some poor ones whom where mainly interested in a paper gathering exercise rather than being a facilitator.
I have also come across principle contractors many of which are UKCG members whose sole intention seemed to be back side covering paperwork based I.e. RAMS for simple tasks covering over 20 pages!!!

The only thing wrong (in my opinion) with the current CDM regulations is poor interpretation and again in my opinion all that was needed was better/clearer guidance on how to comply with these regulations.

You ask for examples of how the CDM- C has improved things well im pretty sure that the accident stats could tell the tale here it certainly does at my current company where the CDM-C is also the Group Health and Safety Manager whom is fully empowered by the board of directors.

everyone is entitled to their opinion and mine is that by replacing the CDM-C with a lead designer (most designers are not the least bit interested in health n safety) is a bad move but only time will tell.
achrn  
#25 Posted : 30 December 2013 10:18:54(UTC)
Rank: Super forum user
achrn

allanwood wrote:
I
You ask for examples of how the CDM- C has improved things


No, I did not. I asked for evidence that the creation of CDM-Cs has resulted in a marked improvement in construction safety across the industry overall.

There's much wailing and gnashing of teeth that abolishing CDM-Cs will cause a terrible worsening of construction safety, but since the introduction didn't seem to cause a magnificent improvement, I'm curious why this is the consensus view.

It's also annoying that every single time this comes up, someone trots out the "designers don't care about safety". I'm a designer. I work in a firm of designers. I don't know one single person that shows any evidence of 'doesn't care about safety'.

It seems to me that CDM-Cs didn't make a dangerous industry very much less dangerous. We seem to have the curious situation that designers, who are working under multiple conflicting requirements, were blamed for not making construction safe enough. Then we brought in CDM-Cs whose sole and only purpose was to make it safer. It didn't get safer, but rather than adopting the view that this means CDM-Cs are failing, or that actually designers were doing as good a job as someone in the design chain can do, the consensus is that it just goes to prove how useless designers are.

CDM-Cs didn't make it better, so obviously abolishing them will make it much worse? Eh?

allanwood  
#26 Posted : 30 December 2013 15:16:34(UTC)
Rank: Forum user
allanwood

On what basis can you claim that CDMCs havent improved construction from a safety perspective?

What part have all the other duty holders played to improve safety in construction?



achrn  
#27 Posted : 30 December 2013 15:26:10(UTC)
Rank: Super forum user
achrn

allanwood wrote:
On what basis can you claim that CDMCs havent improved construction from a safety perspective?


The fact that statistics graphs didn't plummet markedly when CDM-Cs were invented. Long-term trends have continued pretty much unaltered by the introduction of CDM-Cs.

Look at the graph on http://www.hse.gov.uk/st...s/industry/construction/

Where is the sudden dip with the introduction of CDM-Cs? There isn't one. I doubt there'll be a sudden upwards leap when CDM-Cs disappear. The picture is basically the same whether you look at fatals, or majors, or RIDDORs.
allanwood  
#28 Posted : 30 December 2013 17:44:26(UTC)
Rank: Forum user
allanwood

A downward trend over the last 20 years which continued with the introduction of CDM 2007.

would you care to answer my 2nd question? With regards to other duty holders?

as I mentioned in my earlier post where all entitled to our opinions, and only time will tell if the changes are for the better I like plenty on this forum fear that its a change for the worse.

John M  
#29 Posted : 30 December 2013 19:38:10(UTC)
Rank: Super forum user
John M

Irrespective of whether or not the demise of the CDM Co-ordinator will impact on the overall safety performances or figures it looks particularly grim for the APS as a body.

Jon
achrn  
#30 Posted : 31 December 2013 08:37:05(UTC)
Rank: Super forum user
achrn

allanwood wrote:
A downward trend over the last 20 years which continued with the introduction of CDM 2007.


Continued unaffected by the introduction, yes. That was my point.

allanwood wrote:
would you care to answer my 2nd question? With regards to other duty holders?


Presumably all the things they were already doing and have continued to do that have been gradually driving down the danger in the industry. CDM hasn't of itself had a big impact - the industry has been gradually improving since before CDM and I expect it to continue to improve after parts of CDM are dropped.

The graphs demonstrate all this - if CDM really did have a big impact on site safety there should be a drop or change in gradient or something when it was introduced. There isn't. Creating CDM-Cs didn't improve site safety overall - the trends have not wavered. Creating CDM-Cs has added to paperwork, and created teh APS, but it hasn't done anything discernible to construction industry statistics.
Stedman  
#31 Posted : 31 December 2013 11:17:42(UTC)
Rank: Super forum user
Stedman

John M wrote:
Irrespective of whether or not the demise of the CDM Co-ordinator will impact on the overall safety performances or figures it looks particularly grim for the APS as a body.

Jon

As a Chartered Safety and Health Practitioner and CDM-C, I have always seen the 2007 model as a transient one where if the CDM-C role had been successful and all the other main stakeholders had taken ownership of this, there would have been a natural point where the CDM-C role would have become redundant anyway. Although this has not happened, reluctantly I have accepted that the HSE are firmly proposing the “removal of the CDM co-ordinator role” and without any strong support for the current CDM-C role from any of the other key CDM stake holders, this will certainly happen.

As an APS member, I am also intrigued to know the strategic direction of this organisation when the CDM-C role is removed, especially as it currently has a Chartered application with Privy Council.
John M  
#32 Posted : 31 December 2013 11:43:09(UTC)
Rank: Super forum user
John M

Has not IOSH opposed the APS application for Chartered status?

Jon
Stedman  
#33 Posted : 31 December 2013 14:43:10(UTC)
Rank: Super forum user
Stedman

John M wrote:
Has not IOSH opposed the APS application for Chartered status?

Jon


I thought the IOSH response was confidential, however I have also not any new in the past year with regards to this from APS.
bob youel  
#34 Posted : 31 December 2013 15:10:20(UTC)
Rank: Super forum user
bob youel

Irrespective of who goes and who stays until the enforcers do their job and enforce enough clients and designers properly noting will change and that will not happen

We will be back to the 60's [when I started] very shortly if we are not there already with 0 hours employment contracts and the like
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