I am seeking views on the definition of construction work in regard to CDM 2015.

It seems to me the definition of construction work 2(1)e has not changed but in the 2007 ACoP a list of what was not considered as construction work was included (para 13) and this is not within the current draft guidance.

Putting up marquees and planting trees is currently not considered construction work nor is general maintenance of fixed plant (with some qualification) - what are forum members views.
Will general maintenance of fixed plant (air conditioning, heating and ventilation, fire and security alarms, lifts,etc etc ) now fall into this ? - if so presumably so will planting trees and putting up tents.

I'm not arguing these activities should not be properly and thoroughly planned and carried out safely but the paperwork burden of the production of cp plans will be enormous and at odds with the HSE's stated aim to cut bureaucracy.

I think the increased need for CPP`s on small projects is why the HSE keep banging on about the new mobile phone app for smaller builders (and no doubt other basic CPP software that will be probably be released) and hence the inclusion of the last part of "Reg 2 interpretation" (2).

Says who?

I have read the letter achrn has kindly provided a link, but it does not specifically mention marquees or trees. I have yet to read anything where the aforementioned are covered by CDM 2015.

I agree with lwthesm, a marquee is a prefabricated/temporary structure under the regulations and this was one of the reasons that the events industry kicked up. The new regs have widened the meaning of construction and I am not saying it makes sense.

However the CPP only has to be in proportion to the risks. The law about controlling risks has not actually changed and most reputable companies are adequately controlling the risks.
On colossal projects the CPP is not a single document and not held in one place. But what they do is ensure that the information required to adequately control the risks are cascaded down to the individual sites.

A similar approach can be taken for small jobs. In the example of the marquee the CPP can consist of a site specific risk assessment and method statement, and company’s policies and procedures. It does not all have to be onsite.

CDM2015 will be implemented and resolved all the quicker if we cease attempting to redefine terms already defined!

Both Construction work and STRUCTURE are already defined in Regulation 2.
The whole emphasis accords with that given in Annex 1 of the Parent Directive.

"Marquees" do not fit within the given definitions, and are not a "temporary structure" in the context of formwork, falsework, etc.

Sorry disagree, a marquee is a prefabricated structure.

“construction work” means the carrying out of any building, civil engineering or engineering
construction work and includes—
(c) the assembly on site of prefabricated elements to form a structure or the disassembly on
site of the prefabricated elements which, immediately before such disassembly, formed a
structure;

“structure” means—
(a) any building, timber, masonry, metal or reinforced concrete structure, railway line or
siding, tramway line, dock, harbour, inland navigation, tunnel, shaft, bridge, viaduct,
waterworks, reservoir, pipe or pipeline, cable, aqueduct, sewer, sewage works, gasholder,
road, airfield, sea defence works, river works, drainage works, earthworks, lagoon, dam,
wall, caisson, mast, tower, pylon, underground tank, earth retaining structure or structure
designed to preserve or alter any natural feature and fixed plant;
(b) any structure similar to anything specified in paragraph (a);

Thanks Ron, I am lucky not to be in a position to decide for real, all my stuff is clearly construction. Time will tell.

Below taken from HSE website

Are the CDM Regulations enforced at events?


The erection of some temporary demountable structures at entertainment events falls within the definition of ‘construction work’ in regulation 2(1) of the Construction (Design and Management) Regulations 2007 (CDM).

However, HSE policy is that the CDM Regulations do not provide a useful regulatory framework for temporary structures used in the entertainment industry. This is because the CDM Regulations were specifically drafted for the procurement and delivery of projects in the construction industry. The processes and management arrangements in the entertainment industry can be significantly different.

Instead, organisers and their contactors should focus on compliance with The Health and Safety at Work etc Act 1974, Management of Health and Safety Regulations 1999 and other relevant regulations (eg Work at Height Regulations 2005).

I note with interest the debate on marquees at events and whether or not they will fall in scope of the new CDM 2015. I can assure you that they will as will a whole manner of other activities that although once fell within scope were not enforced by the HSE because they once did not feel that CDM was the right fit for the entertainment industry.

To answer one statement about prefabrication, most TDS is prefab in some way or another, otherwise it would not be commercially viable. It is the activity of installing this that falls under the new enforcement rules, it has always been CDM as it is and always has been construction activity. Event sites do share some of the same risks of traditional construction in that we have plant and machinery, work at height, manual handling, lifting activities with cranes, hot works etc.. therefore it is no surprise that this has come to light under the review of the Directive and more notably as a direct result of the work the HSE undertook during the London Olympics.

With regard to weddings and other domestic parties, yes, it falls in to scope. How this will be monitored or enforced will be an interesting watch. The HSE are keen to stress that they will enforce based on risk proportions however it will still come in to law on 6th April 2015.

As a member of at least three national committees in the event industry I am fairly close to this and am involved in work directly with the HSE to form the targeted guidance for stages and outdoor events.

As a side issue I (as in Star Events Ltd with Roger Barrett) have also just been involved in putting together a new guidance document just for stages, you can download a copy at http://www.stareventsltd...ractice-Star-Events1.pdf

As for all the other questions in relation to CDM and events, it will affect us all in some way or another. CP Plans will be required to be appended to event management plans or safety files but do not need to be 500 pages, if it just signposts where the info is in the EMP, then this is going to be adequate for H&S enforcement purposes. The key new things we will be looking to improve at events that are currently not well managed are, sanitary conveniences, welfare in general and being given time to plan and deliver the job safely. The CP Plan has a special definition in law, therefore it will not be enough just to say that the info is in the EMP.

With regard to how the terminology maps over from traditional construction to events, I think a new colloquial term will become common soon and that will be the 'client group', ie the client, the promoter, the agent(s) and the production company. All the others will feed information in to this group who will provide the EMP which will include the CPP. I know that many other groups are involved in helping their members, ie ABTT, PLASA, PSA, PACT, NAA, NOEA and so on, so if you are members of any of these groups, get in touch with your representative. If changing sets between Acts in a theatre production is in scope, you can pretty much imagine that most other things could fall in as well.

This will be fine for big events, or those managed by seasoned professionals, I will be keen to see what happens in the smaller, or community based events.

The key message is this, nothing major is changing, we are already doing a majority of the requirements under CDM 2007 and many of us are already using CDM principals to plan event safety. All we are adding is a CPP that is proportionate to the risks to ensure that the construction and de-rig of an event is co-ordinated and safe, that has to be right, right? As a safety professional I am in favour, if I was an event organiser, I might be slightly worried, but that is only because of the extremely poor way in which this consultation and delivery has been handled and the fact that there hasn't been any focused education from the HSE to ensure that lay people know about this.

How many events are there in the UK every year? We will probably never know but I'd imagine its in the hundreds of thousands (incl. domestic using TDS) and there aren't that many registered event organisers, so who are all the others?