Rank: Forum user
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Hi all,
What are your views regarding the apparent requirement for all construction projects to be required to develop a construction phase plan?
Previously a plan was required for notifiable projects but there is no link in the draft Regs or CITB guidance to suggest that the creation of a plan is triggered by such a project.
Martin
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Rank: Super forum user
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I do not see it as an issue. The Construction Phase Health & Safety Plan can be made into a huge unwieldy document even for small projects or it can be a relatively simple document.
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Rank: Super forum user
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As long as the document is proportionate with the project, I see no fundamental problem with the requirement that the construction phase have a documented plan on every project. What is critical, however, is that we get some guidance that actually demonstrates that, and shows what 'proportionate' and 'adequate' looks like.
Some projects have always required a plan - demolition requires a written plan under CDM07 regardless of the size of the project and whether notifiable or not, for example.
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Rank: Super forum user
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If you take a Method Statement for example, they can be large or very small documents - depending on the complexity of the task, risks, etc. So I assume it will be the same for CPPs. Indeed, some CPPs may actually be nothing more than a hybrid MS for smaller projects. The HSE may provide guidance or even a template in due course.
I would guess that many small projects will not have a CPP, or as we know it - just another prescriptive standard which will be either forgotten or ignored. The offender will probably get nothing worse than an EN to put one in place, assuming they are visited by a regulator, which in itself is unlikely.
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Rank: Super forum user
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I agree that A decent "health & safety method statement" can be used as the construction phase health & safety plan for small projects! It is just the label you give!
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Rank: Super forum user
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I use a Method Statement with the following items in a table format
Project
Document Ref Number
Task or work operation
(This safe working procedure has been prepared for the following work. No other work other than that detailed must be carried out) Location of Work
Short description of work:-
Safe Methods to be adapted:- 1. Supervisory arrangements 2. Monitoring arrangements(i.e inspections/audits to ensure that operatives/supervision as stated) 3. List of plant & equipment to be used 4. List of personal protective equipment required 5. Sequence of work to be carried out 6. Health & safety precaution s/control measures applied Items 5 & 6 can be combined and presented as an annexe so that:-
• activities are listed • hazards associated with the activity are identified • risk level is evaluated (if appropriate) • control measures are listed for the hazards identified on the basis of risk level 7. First aid provision 8. List of arrangements for seperating specialised activities 9. Controls for safety of third/other parties on site 10. Have activities assessed as “high risk” been identified with specific control measures? List references—can be combined with items 5 & 6
11. Emergency arrangements Prepared by:- Name Designation Signature Date
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Rank: Forum user
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Thanks for all your responses.
I see a lot of smaller contractors being caught out with this -especially in the domestic arena or for small maintenance/repair jobs.
Larger contractors will not see any changes imposed by the Regulations but I expect it won't be too warmly received by smaller operators - they will see a greater bureaucratic burden.
I agree that getting contractors to think about the management of H&S before they start a project is a good idea (and may not be too onerous depending on the size, complexity of the project) but I think compliance is going to be limited, unfortunately.
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Rank: Super forum user
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I thought the CPP would not be required for single contractor works?
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Rank: Forum user
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I think as soon as another Contractor is appointed then its a different ball game - so if a scaffolder is involved for example then that triggers the PC role. This will cover a great many small projects.
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Rank: Super forum user
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It is not an apparent requirement !
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Rank: Forum user
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Until its set in stone then technically it is. Not that I expect there to be any changes to the draft before it is passed.
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Rank: Super forum user
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FireSafety101 wrote:I thought the CPP would not be required for single contractor works? I think you thought wrong: "A client must ensure that before the construction phase begins, a construction phase plan is drawn up by the contractor if there is only one contractor, or by the principal contractor;" "If there is only one contractor working on the project, the contractor must draw up a construction phase plan, or make arrangements for a construction phase plan to be drawn up, as soon as is practicable prior to setting up a construction site. "
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Rank: Super forum user
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Ahh got beat to it...however, the above post is correct according to the draft ACoP. Another extract below.
Drawing up a construction phase plan
161.
'For single contractor projects, the contractor must ensure a construction phase plan is drawn up as soon as practicable before the construction site is set up (regulation 15(5)). Guidance on contractors’ duties in relation to the construction phase plan is set out in Appendix 3. Further guidance, including a template for a construction phase plan, is provided for contractors working on small scale, routine and domestic projects on HSE’s website [link to Busy Builder leaflet and template to follow]. A smartphone “app” providing a template for a construction phase plan is also available from the Construction Industry Training Board website [link to app to follow].'
Now that should open up a can of worms...
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