Rank: New forum user
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Hi, I'm getting a little confused and would appreciate some advice please. We operate a 'responsive repair team' who carry out day to day general repairs within the social housing sector. This team is made up of own employees and a few small sized contractors. My question is could i create a 'blanket' construction phase plan covering the works we do repeatedly do every day? If not does anyone else on here have a similar situation and how do you manage?
Thanks in advance
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Rank: Super forum user
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A generic CPP pro-forma makes good sense for basic maintenance type tasks. There is also an app provided by the HSE for this type of scenario available for IPhone and Android. We out source all our responsive repairs and maintenance so it is down to the contractor to provide documentation.
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Rank: Super forum user
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Yes I believe you can, a lot of large FM contractors have integrated the requirements of the CDM regulations with their H&S systems.
So they pick up pre-construction information e.g. tenant issues, asbestos etc., and relay it to the operatives with the job instruction. The operatives then carry with them a copy of the policy and procedures, generic RAMS etc. Once on site they carry out a short risk assessment to ensure there are not usual risk and hazards not covered by the generic RAMS.
They do tend to have work planners/coordinators in the office managing this, tracking locations, responding to queries and supporting the operatives.
With the new regulation there is sometimes the sticky issue of who is the PD. If the HA have issues a specification then they are, if they have just issues a job instruction e.g. replace a socket, then I believe you are, as you will choose the actual socket.
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Rank: Super forum user
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agentsmith wrote:Hi, I'm getting a little confused and would appreciate some advice please. We operate a 'responsive repair team' who carry out day to day general repairs within the social housing sector. This team is made up of own employees and a few small sized contractors. My question is could i create a 'blanket' construction phase plan covering the works we do repeatedly do every day? If not does anyone else on here have a similar situation and how do you manage?
Thanks in advance I think that this is a perfectly reasonable response to the need to a CPP. Maybe an hour or twos training with the guys (and/or girls!) so they understand what it is and where it is to make sure everyone I son board and you'll be good to go.
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Rank: Super forum user
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Alfasev wrote:The operatives then carry with them a copy of the policy and procedures, generic RAMS etc. No way! That's entirely contrary to the stated objectives of CDM, which is all about reducing bureaucracy. The employer's task is to ensure a competent workforce via provision of appropriate supervision, information, instruction and training.
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Rank: Super forum user
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If you know the jobs they are going to why should the operatives not be issued with only the relevant RAMS and then update these so that they are truly task specific. There are many formats that can be adopted to allow a generic assessment for a task to be updated to make it truly task specific which is what the regulations actually require.
I agree with the concept of an overall management plan which can be updated via the job card with location specific information BUT the term generic CPP rings warning bells in my ears as some information can be missed if left to the operative who is time pressured to get the work done. Supervisors have to be involved somewhere in the chain.
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Rank: Super forum user
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So then Ron how do you propose to handle the risk assessment and safe working issues with this type of work? You cannot call possessing the RAMS bureaucracy.
My post was only intended as a general methodology and not an in-depth policy. The operative will only carry relevant documentation. I am not proposing a generic CPP, but the CPP for this type of work is very different from typical construction and a lot of it will be repeated.
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Rank: Super forum user
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With respect, Alfaserv, I can and do call that unecessary bureaucracy.
Why do we have this mindset that construction workers are a special case? No-one presumably suggests that we burden those working in heavy industry,engineering, arboriculture, agriculture, fishery or fuel extraction with carrying round copies of "policy, procedures, RAMS" etc.
All of these Industries are of comparable or greater risk, and all require a competent workforce. Sending construction workers out with reams of paper (or loaded hand-held devices) does not make for competency - IMHO it tends to suggest the opposite.
We have a statute requiring a proportionate approach to providing a construction phase plan. Nothing in that statute suggests the plan must be on-site or in the possession of the operative.
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Rank: Super forum user
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Ron, Construction has developed this methodology of RAMS due to the ever changing workforce, risks and hazards on a typical construction site. It has successfully played a major part in reducing accident rates. If the CPP is not on a typical construction site then there is something wrong!
If I was working at a fixed location I would expect to have access to the policies, procedures and RAMS. I do not expect operatives to carry them around with them but they should have access and be aware of them. How is this to be done with remote maintenance workers who rarely came to the office if they are not kept in the vans? I am not saying a whole set of policies and procedures for every aspect of a company being kept on the van, only that relevant.
Some of the industries you mentioned have relative poor health and safety figures and could learn from others.
I never negated or even mentioned the requirements of competence but have seen excessively large RAMS that repeat core competences rather than refer to them, so perhaps understand where you are coming from.
The post was about remote working maintenance operatives in third party premises. I have managed maintenance crews and it was a practise that worked well. I know other large FM contractors use similar practises but it is only one element of an effective H&S system.
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Rank: Super forum user
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Alfaserv, we do have a common understanding. I confess that I am on a bit of a crusade here. CDM2015 enables (and HSE are at pains to emphasise) a proportionate approach. Previous iterations of CDM have been scuppered by blanket adoption of pro-forma and commercial schemes and systems, something we surely must avoid this time around.
The requirement for a CPP for all Construction Projects does not necessarily mean that additional documents or actions will be required. Many will already be satisfying the extended requirements via existing methods and arrangements - particularly so in the context of the OP scenario.
I'm particularly 'anti' on providing hard copy to operatives - this creates an adminsitrative nightmare when things change and is NOT a substiture for provision of appropriate infromation, instruction and training. I'm also particularly 'anti' systems of work which abbrogate responsibility to building/FM and construction employees to conduct "Site specific Risk Assessments". As Bob rightly says here, operatives are routinely under pressure to get the work done. The concept (and practice) is IMHO disingenuous other than in the most extreme circumstances (e.g. applied by Fire Service).
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Rank: Super forum user
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I'm all for cutting down unnecessary paper work...but CDM just perpetuates this absurdity. We are now in a situation where a CPP is required for ALL projects, RAs are a legal requirement and a Method Statement identifies how the contractor will carry out the task safely. On top of this there may be other documentation, such as an asbestos survey, lift plan, PtW, etc. And this documentation needs to be on site.
Now, that is hardly reducing bureaucracy is it?
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Rank: Super forum user
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I pick up on Ron's use of the word disingenuous as he suggests is applied by the fire service and put two links below to compare fire deaths in general with deaths in construction. The first is stats for 2012/13 showing fire deaths, second is HSE stats for fatal injuries 2012/13. 350 fire related deaths in Britain, 76% in dwellings, Construction is not included in the stats but why should they discriminate in their actions when legislating and providing advice and guidance whether it be to private individuals or construction sites? I believe their concept and practice should be the same whatever. Fewer deaths in construction, caused by various injuries. Happily, (if that is the right word to use) the number of deaths in both cases are falling. https://www.gov.uk/gover...2-13__final_version_.pdfhttp://www.hse.gov.uk/statistics/fatals.htm
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Rank: Super forum user
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IMHO Ron's suggestion not to burden on site operatives with more hard copies of documents is a good one.
Perhaps if the CPP is done in the office and remains there it will suffice and comply with regulation.
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Rank: Super forum user
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FireSafety101 wrote:
Perhaps if the CPP is done in the office and remains there it will suffice and comply with regulation.
I could live with that...still leaves all the other documentation which is required on site.
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Rank: New forum user
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The new CDM regs are not clearly defined really.
When carrying out reactive maintenance it's basically asking you to do a CPP before going to change a light bulb, when a simple risk assessment and method statement would suffice. Creating more work for businesses.
I don't see how you can do one blanket CPP when you may have multi trades working for you. Maybe do one per skillset ?
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Rank: New forum user
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RayRapp wrote:I'm all for cutting down unnecessary paper work...but CDM just perpetuates this absurdity. We are now in a situation where a CPP is required for ALL projects, RAs are a legal requirement and a Method Statement identifies how the contractor will carry out the task safely. On top of this there may be other documentation, such as an asbestos survey, lift plan, PtW, etc. And this documentation needs to be on site.
Now, that is hardly reducing bureaucracy is it? Totally agree Ray
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Rank: Super forum user
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Shelley Davis wrote: I don't see how you can do one blanket CPP when you may have multi trades working for you. Maybe do one per skillset ?
This is what I have advised for people who have maintenance contractors leaving key info (like location) blank. It could almost form part of the work order and need not be more than a few pages.
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Rank: Super forum user
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What we have now is a perverse situation where people are re-inventing the wheel. A CPP was originally a high level document outlining project details, health, safety and welfare management. Underneath the CPP sat other safety related documents, such as the RAMS. The latest offering from the HSE, albeit for small projects, seems more like a Method Statement.
The maintenance CPP could easily be a generic type document with some minor changes for each particular job. The CPP could cover the whole job including other trades with some minor jigging about, unless the work is particular complex, diverse, or high risk.
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Rank: Forum user
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If it's any help we keep one copy of the CPP, RAMS on site so anyone visiting can see it. this has been acceptable to the HSE. Although our work is identical, our sites are not and our CPP reflects these minor variations. We have also started adding temporary works to them as they evolved.
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Rank: Super forum user
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As associates,
If the process you describe is in-house, and the documents are maintained electronically via your intranet, then I agree with your arrangements.
If, however you're talking about leaving paper copies everywhere, then I do think that's somewhat contrary to the anti-bureaucracy intention of CDM2015.
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