Rank: Forum user 
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Hi All - I'm worried.....let me tell you why.....
I work in a private school, we have risk assessments in place, method statements, asbestos plans etc for our in-house maintenance and IT teams to go about their daily tasks such as repair, redecoration, maintenance and other 'construction works' as detailed under the CDM regs... Because we undertake these tasks I appreciate we are, the Client, Designer, Contractor and Principle Contractor depending on whether there are more than one contractor.
So as a Contractor does this mean we have to put in place a Construction Phase Plan every time one of the in house maintenance team do any 'construction work' (literally dozens of jobs a day!) as defined by the regs?
In paragraph 147 under 'who is a contractor' it states 'This also includes companies that use their own workforce to do the construction work on their own premises' - My interpretation of this is yes we will need a CPP (and H&S file) so my question is how on earth are the rest of the members working for similar organisation planning on doing this???? - Generic CPP?
Also does my workplace need notifying on an F10 as the construction work is greater than 30 days (we have been here for over 160 years already) and will therefore we will exceed more than 500 days?
Thanks in advance!
BL15
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Rank: Super forum user
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Yes... I am afraid you will need a CPP.
BUT it need not be complicated or a total ball ache.
Do a CPP which is for "day to day maintenance, repairs or installations". Put what you need into it and support it with your (already existing) risk assessments and method statements.
Site rules can be derived from contracts of employment and job descriptions so that is easy too.
As for F10, think of one repair as one project. If the care taker repairs a broken fence it will not be notifiable, however if you build a new extension it will not fall into the remit of this CPP so you would need a specific one for this project and would need an F10.
Hope that helps!
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Rank: Super forum user 
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No.............you don't.
Your roles are entirely in-house. You already have all the things you describe. CDM2015 describes the key elements of a CPP as (a) Management Arrangements, (b) Site Rules and (c) Project Specific Risks.
I'm willing to bet you can point at your existing documents for all of that.
NO ADDITIONAL PAPERWORK REQUIRED for those day-to-day tasks.
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Rank: Forum user
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Cheers guys, really appreciate you both taking the time to reply to my post.
And both very valid opinions that both make sense - although interestingly, they are both very conflicting opinions. I suppose my frustration is that the HSE haven't put any guidance out there that fits my scenario, which to be fair will be the same scenario for a heck of a lot of organisations…
Any inspectors out there wish to clarify?!?!?
I've been in safety now for 15 years and have defended safety legislation on many occasions because I can see the sense in it, even when it does add layers of paperwork…but these regs really are misguided. I know they are driven by Europe and the HSE's hands were tied, but who in there right (european) mind thought this was a good idea? I would be interest to know how other member states have implemented the directive though their legislation and of course whether it is actually enforced in the way it is in this country.
Thanks again and I would welcome other forum users views who have in-house maintenance teams?
BL15
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Rank: Super forum user
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So here we have two HS bods with different outputs. Now if a punter was paying for this output (advice) one would be clearly wrong.
Where are we going wrong?
Jon
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Rank: Super forum user
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Ron Hunter wrote:No.............you don't.
Your roles are entirely in-house. You already have all the things you describe. CDM2015 describes the key elements of a CPP as (a) Management Arrangements, (b) Site Rules and (c) Project Specific Risks.
I'm willing to bet you can point at your existing documents for all of that.
NO ADDITIONAL PAPERWORK REQUIRED for those day-to-day tasks.
I can see where Ron is coming from and I do partly agree.
However, if you take what Ron has said and bundle them up into one document entitled "Construction Phase Plan" you will meet the requirement.
I think we are agreed that what you have described come sunder the remit of CDM defined construction work, which then requires you to have a phase plan.
While, in my opinion, Rom is correct (you have the elements - or most of the elements) it is the CPP that is required and if you were asked to produce it and went to several different documents referencing part of them I don't think that would show a great level of competence to the inspector.
I think the answer probably lies somewhere in-between my initial response and Ron's.
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Rank: Super forum user 
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I don' think Ron and Ashley are entirely disagreeing.
Yes you need a CPP. No you don't need any new paperwork.
For the tasks you're doing, you already have a CPP, it just doesn't say 'CPP' on the front. If you want to be doubly certain, you can put the documents you have in one pile and put a piece of paper labelled 'CPP' on the top of the pile, I suppose.
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Rank: Forum user
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BL15 - I work in exactly the same environment as you and we have a large team of in-house maintenance staff. My current focus is on getting the CDM documentation right for our projects which involve outside contractors and sometimes our in-house team work alongside them. However for the day-to-day maintenance tasks, we have risk assessments and unless told differently I will be doing no more. CDM also states that the CPP is relevant to the project, has sufficient detail and is proportionate to the scale and complexity of the project and the risks involved.
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Rank: Super forum user
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I think the issue that has never been satisfactorily resolved/defined by the HSE and various CDM versions - is when does 'normal' building facilities maintenance really change to design and construction activities.
Routine building maintenance shouldn't need any excessive paper work or overboard safety plans.
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Rank: Super forum user
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Those seeking further assurance can log on to Anthony Lees' (HSE) recorded webinar.
Straight from the horse's mouth as it were - one of the key objectives of CDM is a reduction in bureaucracy.
https://iosh.adobeconnec...t=true&pbMode=normal
Worth pointing out too that the additional resources HSE are loading onto their website are intended for the small builder - i.e. an employer whom HSE recognise will not necessarily already have formal procedures, arrangements, policies, RAMS, etc.
All adds up to a proportionate and pragmatic approach to be applied by all.
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