Not really sure what your question is...CDM 2015 applies to all construction related work regardless of whether it is a 'small job' or a large project. The only difference between the two is the notification threshold for the F10, which you have already mentioned.

I mentioned in another thread my conversation with a double glazing company that can do 8 different jobs in a single day. They will not be having CPP for every job.

You haven't seen it because it isn't a requirement of the regs. I don't know where Palmer20061 derives the requirement from, but the regs are explicit: "During the pre-construction phase, and before setting up a construction site, THE PRINCIPLA CONTRACTOR must draw up a construction phase plan " (my emphasis).

Perhaps I got that bit wrong (every contractor involved has to submit a construction phase plan). It was from a presentation by the HSE and that was certainly my understanding from the talk - but the regs as quoted above don't seem to imply that......

for the purpose of this area as far as I am aware a project starts at the conception stage of things and as things develop the project develops and continues after the mechanical aspects are finished until all things are finished e.g. all docs are signed off after site work inclusive of snagging etc. is complete The terminology is all wrong [but I did not expect anything different] as we should be quoting the need for a management plan that describes how jobs are managed not just a comment about a plan

Ron I don't know about you but I do not believe everything I'm told. Therefore I as the Client would want visibility that a CPP has been prepared. Otherwise I do not believe a client could properly fulfil the duty set out Part 2 Client duties 4.-(5) A client must ensure that— (a) 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; and Although clients do not approve the CPP it's not unusual for them to review the document for suitability and where necessary provide feedback. In some cases this may have been undertaken by the now extinct CDM-C. I would not trust a PD to review the CPP for suitability. Ray

Ron Some fair points. I would add that in the case of a LA, e.g. Decent Homes project, a CPP would be drawn up for the whole project where there is normally only one PC. The difficulty arises where there are smaller projects which might come under repairs and maintenance. In which case a hybrid MS/CPP will no doubt be the result. These may not get the scrutiny that a major project would, but generally the risks are quite low as well. The only defence is one of reasonably practicable I suggest. The CDM Regs have never fitted comfortably with all types of so-called construction work, such as certain types of maintenance, which in my view is not construction work per se. LA's have their own difficulties not just with CDM but also CAR 2012 which essentially applies to non-domestic properties, whereas a LA has as you have rightly pointed out has thousands of properties to maintain. It appears to me that regulations are now days written by an army of lawyers with very little esoteric knowledge of health and safety management.

In deciding what is a project under the new regulations you need to study all of regulation 2, Interpretation. The CPP should be in proportion to the project and unlike many I currently see should not repeat the regulations, and company policies and procedures. Most well organised maintenance contractors, with a little tweaking and the cooperation of an informed Client, should not find it hard to comply. For example maintenance CPP could be the tweaked specific risk assessment and method statement which reference company policies and procedures/handbook/site induction. As a client you should have already vetted them (or used SSIP) and be happy with their policies and procedures. The CPP does not have to be a large document.

The above mentioned CITB CDM Wizard app allows you to tailor your CPP to suit your needs. & its a free of charge app too!!!

Whilst I tend to agree in principle with alfaserv, unfortunately Appendix 3 (particularly section 5) of the draft L153 goes into a fair amount of detail on the requirement for the CPP "H&S management arrangements". Production of that info. for every CPP (i.e. for each and every Project) is I think a significant burden, one which I fear will tend to perpetuate an overly bureaucratic approach to compliance. Do note though, that there is no reference (that I can find) to a statutory requirement for the CPP to be available on Site!! Notable too that guidance suggests CPP should NOT contain detailed method statements.

I've had a brief look at this app. I agree it's a useful tool for the SME working in domestic client Projects and in that respect, I don't knock it. I'm not convinced though that it meets the HSE regulatory and guidance criteria for a CPP. Rather it seems to populate a generic set of potential risk controls to enable the contractor to develop safe systems of work for a range of risk topics. This seems to be at odds with the clutter-free HSE promoted approach to CPP. If applied across the broader Industry, this could result in a significant retrograde step - CPPs full of generic assessments, Method Statements, etc. - the very thing HSE are at pains to prevent? It will be interesting (!) to see how HSE web-based guidance develops, particularly if HSE promote (And the HSE Guidance suggests this will be the case) the CITB Wizard as a satisfactory approach to CPP compliance.

Whether they do or do not fall into CDM 15 I think people here are making too big a meal of the CPP requirement. The CPP has to be tailored to suit the type, size of the project, I believe a simple one pager will suffice for the smaller project.

Mike I recoginse that for small jobs such as mainteance type work a CPP is not really relevant or needed. However, if it falls within the ambit of the regulations and is deemed construction work, then strictly speaking you need a CPP. Moreover, there must be something simplle which you can prepare which is a one-pager - for an example, a form with very basic info which only needs a few fields completed, the rest can be fairly generic I suggest. Ray

Ron, perhaps not, but that is the reality of this absurdity.

It may well be an unfortunate consequence, but I for one will be resisting that approach within my Organisation. The HSE call for a proportionate approach and a reduction in bureaucracy. We have a 800+ repair and maintenance workforce carrying out thousands of jobs (construction projects) every week. I'm confident we can apply a generic approach to compliance via existing management arrangements, site rules and specifics such as asbestos registers etc.). These tradesmen are competent, skilled well trained and informed. They manage very well without carrying reams of risk assessments and method statements around with them up to now. Why would they need a raft of (useless) "Construction Phase Plans"? Bigger jobs - yes, OK, a CPP - but in proportion.

Ray Rapp said...."Therefore I cannot why a pro-forma could not be designed which would reflect the simplicity of the task and be included in the job pack". Is that not what the HSE have suggested they will produce in their Busy Builder leaflet [ref page 78 para 17 of the draft CDM guidance]. That is what I am waiting for.

Mike good luck with your new form, I hope you meeting with site personnel goes well. IMO make it as simple as you can as long as all the right stuff is included. Please feedback how it went. Cheers

Are we all getting bogged down in semantics here? Nowhere does it say - in any laws or regs that I am aware of - that a document has to have a specific heading or title page... In my opinion - if you already have a document or system that addresses the significant findings of your risk assessment - if you have one that sets out your arrangements for organisation, planning monitoring and review, if you have one that sets out the safe system of work - or any combination of any of the above (and if the documentation covers the work actually to be done) - then you probably already have sufficient documentation to satisfy the need for a 'construction phase health and safety plan'.... Even if it doesn't have that title... If you don't have any of the above - then it seems unlikely you will set out to produce a new document??? I don't see a need to add yet more bureaucracy to an already adequate management system just to try and comply with these regs. But of course it will take a brave lawyer to stand up in court and defend a company if they DON'T have the bit of paper with that specific title on it... Shame.

Steve, You posted whilst I was pondering my last post. Nice to see someone supporting my view.

Although the way that you have explained does sound justified i would pose this to you. If these personnel are so experienced and trained then why do they not realise any change in events associated with their jobs. If you look at Risk Assessments - they are only as good as the people carying out the task - however the personnel carrying out the task whether specifically risk assessed or not, in my opinion require more. Not more paperwork and risk assessments but tools / aids that help then understand other risks and hazards. The fact that although they may carry out an engineering facet of an activity something is different from the last time they did it. HAve they accounted for the change taking 2 mins to assess this.Put he controls in place (Point of Work Risk Assessment POWRA in the form of a simple crib sheet and moved on. Or when he change really requires further though how do they overcome this and what assistance is required (if any). I have seen countless tradesman say, im trained, it wont happen to me, ive been doing this years. Then before or after dinner to get the job away they do not assess with he knowledge they have make a for-seeable mistake. Then there is an incident with potential or actual outcomes. This is where a POWRA in a simplified format that fits in the pocket and can be used by the tradesman assists and reduces the probability of risk. A simple CPP may also help with pre planning 1 page max, but his is an alternative way of looking at reducing paperwork and successfully completing activities without forseeable risk to personnel, plant or the environment. Furthermore when i see this working the last part o the puzzle that is forgotten is, what do i do if something goes wrong???