Personally I would hate the concept of a plan that is developed by one group that is then imposed as a structure onto the contractor to develop to completion. Many contractors use their own plan format based on their OWN management systems and often the twain do not meet. The object of the PCI is to supply information for the contractor to use. It is NOT meant to be a definitive plan structure.

Bob

After the Olympics there was much fanfare (by the HSE) about how beneficial CDM 2007 had been during the construction of the stadium and the athletes village. Also how early input from the appointed CDMCs had contributed to this success.

This may be spin. These works may have been so successful from a health and safety perspective because the HSE were involved every step of the way as they were such high profile projects.
As mentioned before the HSE`s line is whatever is dictated by Government policy.

One year they say CDMC`s had been an invaluable asset on the project. The next year they are an unneccesary expense that projects can do without.

Bob

I mean the success from an health and safety perspective was because the HSE were involved every step of the way. Not that that success should be attributed to them. More due to the fact that the organisations involved in delivery new their every move was being scrutinized by HSE construction division because it was such a high profile scheme.

I doubt there will have been another project in recent times that was visited as much by the HSE as much as the Olympic Park and Stadium.

Yes, I am suggesting that organisations take more care when under the spotlight.


Regards

Bob
http://www.hse.gov.uk/ab...-2012-games/hse-role.htm
Regards

Paulw71

You definitely are making my point. This HSE blast is so clearly a publicity blurb rather than reality - they really needed to be seen to be part of this hoping to climb on the backs of others to be seen to be essential and effective. I have spent so many years auditing that I have seen multitudes of blurb like this which melt into nothing when you start to find the evidence, or rater try to find it.

I actually believe that designers and contractors can do safety well if allowed to and the " I am more important to the client than you " attitude" is avoided. The real problem is to get that co-operation to work, which good informed clients can do if they choose to do so.

A history lesson (inclusive of information from old publications that you are unlikely to findline in electronic format) for some of you thinking about your consultation responses!!

Paragraph 26 of the Consultative Document misleadingly indicates that there has been a dramatic shift in where serious and fatal injuries occur over the last 10-15 years. Small and medium sized projects have always exhibited disproportionate reported (let alone reportable) accident rates.

“The significant role some of the major firms play in influencing safety performance is reflected in the review of fatal accidents in 1977. Almost 80% of fatal accidents in 1977 appear to have occurred in the medium and smaller firms. For example roof working….accounted for 19% of the fatal accidents. There was a significant absence of household names.”

“Thirty fatalities, 23% of the total occurred to employees working for companies carrying out relatively minor work. The deceased were working in small gangs employing not more than three men.”

Source – Construction Health and Safety 1977-78, HSE 1979

"About three quarters of those killed at work are self-employed or work for a contractor employing 15 people or fewer BUT about half of fatalities happen on sites with more than 15 workers".

Source – Revitalising health and safety in construction, DDE20, HSE 2002

Not clear as to the input data for this statement – possibly analysis of fatalities recorded in 2000/01, broken down by type of construction in pie chart on page 7 of DDE20 which illustrates a fairly atypical mix with nearly one third involving new build which in my experience is unusual.

DDE20 paints a somewhat misleading picture as HSE statisticians point to a substantial proportion of the fatal accidents arising from construction work as being coded to sectors other than construction. For example, when I investigated the death of a painter in a bingo hall this would be coded as occurring in a place of entertainment, i.e. would not be taken into account when identifying the proportion of fatalities that occur on medium to large sites. RIDDOR does not include for the identification of size of enterprise or size of site (so this information is not routinely analysed).
Of 21 site fatalities I investigated between 1981 and 1990, 17 were on sites with less than 15 workers. The vast majority of these 17 were on sites with less than 5 workers.

So whilst the gap between best and worst performers has continued to widen since DDE20, this is not “the reverse of the historical picture” rather that the best end of the industry has improved at a greater pace than any improvement at the other end.

Little improvement can be expected at the small and medium projects unless HSE maximises its influence on these. This means education, inspection and enforcement. The proposed change in threshold for notification is liable to constrain HSE intelligence as to where its resources would be best deployed i.e. to where most serious injury and fatal accidents occur.

Paragraph 28 of the CD suggests that a two tier industry has emerged. In practice, it’s been a three tier industry since at least the 1980s. The best part of the sector was implementing the principles of CDM when “Managing health and safety in construction: Principles and application to main contractor/subcontractor projects” (HSE, 1987) was published. This part of the sector has progressed with a process of continuous improvement of all aspects of project management including those relating to HSW.

At the worst end the roofer who offers to retile a bungalow but has no intention of paying for scaffolding to provide edge protection will continue “business as usual” and is more concerned about detection (and costly prohibition notice – more costly since the advent of Fee For Intervention) than prosecution (and the likelihood of small fine excepting in the aftermath of very serious injury or fatal accident).

CDM offered and still offers the opportunity to secure improved management of HSW issues in the middle tier, not least in those projects which are currently notifiable but which HSE now proposes to remove from the requirement for notification by applying the thresholds in the Temporary or Mobile Construction Sites Directive.

Steve

The CD has estimated values for non-domestic projects on page 65, with over half being less than £100k and estimates of domestic projects on page 73 with 58% being up to 5 days.

The majority of the workforce will be working on small projects (so yes unsurprising that they are disproportionally represented in the serious injuries and fatalities) but Lofstedt and the independent review commissioned by HSE each concluded that CDM 2007 generally fit for purpose, late appointments and excessive bureaucracy excluded.

Now at the small project end, most of the requirements on contractors have been around since the Building (Safety, Health and Welfare) Regulations 1948, yet the self-employed, micros and SMEs are still disproportionally killing and injury people for generally the same immediate causes (falls, collapses, etc). So most duties on a contractor has essentially changed little for more than 60 years. Duty in WAHR to provide suitable and sufficient safe access and a place of work that is safe, in each case so far as reasonably practicable also dates back to 1948 (at least!!)

Now, taking into account that the cost of assimilating "comprehensive revision" of CDM will fall predominantly on the "more structured part of the industry", why are we trying to crack a nut to change to a legislative regime that is unlikely to impact on baby projects.

I doubt that the EC would instigate infraction proceedings against UK for the domestic client exemption in the run up to imminent review of the parent directive, not least since it was by no means the UK deemed to have under-implemented TMCSD - in judgment in Italian case of EC v Martha Nussbaumer. So may be a little less sense of theatrical drama from HSE?

The other aspect of under-implementation on projects where there are or are likely to be more than one contractor could have been dealt with by a simple amendment such that duty on non-domestic client to appoint CDMC and Principal Contractor would apply to such projects. Simple amendment that would be easily assimilated by the structured part of the industry.

Peter, I like you simple solution, but think of all the Ministerial time that would have been saved and all the Government bureaucratic, Civil Service, Star Chamber and think tank jobs that would have been lost had this CDM 201x exercise not taken place!

Peter, you mean ?


?

John

Abolishing the CDMC is going to make safety matters much worse. If the HSE want to safeguard smaller jobs they should start visiting domestic jobs although they might be removed by angry householders for trespass.

A very grey area as domestic premises with no commercial aspect are exempt . Therefore I personally do not believe they have any warrant at the moment- very different if you were a landlord of course. They can take photographs from a distance and request the builders to accompany them onto public land for questioning but that is about it.

BJC

"domestic premises"... could you please explain what they are exempt from in H and S terms

If there is a work activity going on then where work is defined as for profit or gain -- which I think dates back to Factories Act and notional factories .. as Peter Gotch has been trolling through his archives I am sure he can help --- then my understanding was that an HSE Inspector had a right of entry.

I look forward to your reply

Kind regards

Bruce