I am trying to put together a HSE construction phase strategy, with specific reference to CDM and Mining regulations. Roles and Responsibilities. I would appreciate any examples or advice.
Two attempts have been submitted and rejected. I am beginning to question my own ability and or of those who are reviewing the document.

The issue is the legislation for integrating both surface and underground works, i.e. the shaft sinking and the site preparation works. Naturally the sub surface works do not come under the CDM regulations therefore their is no need for a CDM'c and yet the new Mining regulations, due to become statuate next April are much more goal setting rather than the previous prescriptive mining legislation which it is replacing. Not before time, could allow us to have a similar role, yet under a different guise. My approach is that in the spirit of CDM it would make sense to continue using the CDM'c and Principal Contractor roles to ensure that we demonstrate site control for communication, and co-operation purposes.