Here's a thing my learned colleagues may have an opinion...to what extent should the client have control over the appointment (or removal) of the PC's sub-contractor. Bearing in mind that under CDM 2015 the client is only responsible for the competency of the PC and PD.

Ron

Thanks for your comments. I realise my post is a bit vague and deliberately so because I did not want to give a steer. I have worked on some projects where the PC is forbidden from using sub-contract labour, but as a rule most projects use specialist sub-contractors.

The issue here is the element of risk which is beyond the control of the client if they have no say in who the PC appoints as sub-contractors. If cowboys are used then there is a high risk imported. The problem being that it's often not until there is a serious incident does it highlight the lack of competence. The answer could be written into the T&Cs, but whether this is a practical solution for all large projects is debatable.

Ray

Ray

In addition to the very helpful responses from Ron and Ashley I would add that the Client has responsibility for ensuring their appointed PC has satisfactory arrangements for vetting the h & s competencies of their (the PC's) subcontractors specific to the project works. This can be achieved via the PC demonstrating current accreditation as a PC with CHAS (or equivalent S.S.I.P nationally accredited H & S assessment scheme) or if the appointed PC is not accredited under such a scheme by the PC submitting and demonstrating their own evidence of satisfactory vetting arrangements in accordance with the Clients's own PQQ requirements.

RayRapp,
Think you have answered your own question in your last post. I would as client audit the PC and that includes their appointment of sub-contractors (I would also have this included in the appointment of the PC contract). How far do we go with this audit? That's the question, and, I don't think it's the clients job to keep on going down the procurement chain, however, I do think that deficiencies found during the audit should be made known to the PC by the client in writing.

many moons ago, I was asked to fly halfway around the world to investigate an accident on behalf of an oil major.... I didn't know what to expect as I touched down in Singapore...

It was a fairly straightforward 'man dropped object on leg' type accident, which was a relief. But ... It was on a site with thirty four nationalities working for 'about' sixty different organisations. The Oil Major had excellent procedures for appointing their Principal Contractor - but absolutely no control over who the PC then sub-contracted to. There was effectively no control over the supply chain as a result of which most of the 'organisations' represented on site appeared to be of the 'one man and his dog with a wheelbarrow (or stepladder)' subcontractor type.

I know I am at risk of sounding like a cracked record here. If the contract specifies time cost and quality parameters, but fails to specify health and safety then don't be surprised when the contract management teams (on both sides client and contractor) fail to see health and safety as important to the project or intrinsic to their roles. If the contract does not spell out the supply chain management processes the client wants to impose - then expect a purely 'commercial' approach and for the contractor to do as little as cheaply as he thinks he can get away with.

The OP asks to what extent 'SHOULD' the client have control? I suspect that may be the wrong question. The question should be how seriously does the client want to take safety... And how far down the supply chain does he want to show an interest? And what technical resources does he have to deliver the measures he specifies?

On one recent project - as client lead for safety - I sat in on the selection interviews for ALL second and third tier subcontractor awards as required by the contract terms. The PC(s) may not have liked it... but the client aim was to demonstrate how seriously H&S was to be taken in the project... And it seemed to work. On another large contract - the client had little resource available so simply specified the 'process' they insisted the PC follow....

Horses for courses, but I don't think there is any 'should'... Its all down to client motivation culture and determination.

Ray,

I totally agree with the views and sentiments expressed in your most recent post.

In my experience the Client can often be a hindrance at best and liability at worst with regard to project site health and safety.E.g. turning up without signing in. no p.p.e worn, making unreasonable demands and deadlines etc. My view is that the PC must have complete authority and 'ownership' of the site safety including management of subcontractors. The quality, experience and commitment of a good PC site manager is key to making this work. This is one of the things I focus on strongly in pre-start meetings by getting a name and assurances regarding the quality and experience of the site manager and a commitment to his/her attendance at the site (rather than flitting between 'site managing' several sites).

Another approach I have found works well is for the Client representative to ask the PC site manager to take him/her around the site as a 'joint inspection' with the site manager leading it regarding implementation of control measures for the activities with potential high risk such as working at height, access/egress etc. This can have the effect of providing opportunities to praise good practice whilst identifying bad ones.
Obviously from a Client perspective this is resource dependent as you have referred to. Including an item within site progress meetings (for the larger schemes) for the PC to give a brief report on site safety inspections is also a good idea. These measures need to be implemented in a spirit of mutual co-operation and agreement between Client and PC rather than a 'master/slave' approach.

Just a few thoughts.