I have a retail client who are planning some minor works modifications to lighting, display shelving and signage in a small section of the sales floor at around 500 stores throughout the UK. The works will only require the involvement of 3 contractors at each site (electrician, signage and shelving shop fitter) all directly appointed by the retail client.

For safety reasons each contractor has been scheduled to undertake their element of the works separately out-of-hours on 3 different nights - sometimes with several days in between - to minimise disruption to store operations and avoid persons working at height while other contractors are working below.

Each contractor will have a foreman/works supervisor in attendance with no more than 5 operatives working at any time. None of these contractors are equipped or will be present at the same time to oversee/manage the other contractors works and, therefore, cannot fulfil the duties of a Principal Contractor.

In terms of management arrangements:
- All contractors employed by the retailer have been pre-qualified before been accepted onto their approved framework management system.
- Each contractor is required to provide risk assessments and a method statement for their work which will be checked and approved by the Project Manager before they are allowed on site.
- Welfare is provided through the use of existing in-house facilities.

Therefore, I guess I need to satisfy myself of the following points:-

1. Under CDM2015 the client becomes the Principal Contractor as well as the Principal Designer by default having provided and agreed the works specification?

2. The only person in attendance at each site to oversee the works is the respective stores Night Duty Manager who under normal procedures should routinely issue contractors with a permit to work based on the retailers safety guidance document for contractors working in store and requirement for contractors to work in accordance with their risk assessments and safe systems of work. Would this be deemed suitable and sufficient in terms of managing the works under CDM?

3. Although the works are not notifiable individually on a store by store basis, do they become notifiable collectively by exceeding 500 person days across multiple site locations, with the programme spread over 3 months?

Any thoughts and guidance would be most welcome. Thanks.

This is an enduring CDM question. To answer this you must consider how the works were envisaged, planned and how you intend to carry them out. If it feels and looks like a single project then it is probably notifiable.

For example if the work have been bundled together, considered a single project by the client and carried out under a single contract then it is notifiable.

However being notifiable has lost its ramification under CDM 2015.

I just did a CPP for one like this with another to do this afternoon.

Small works, painting, lighting, joinery etc. a small CPP with a few RAMS.

Not being notified but the same client is involved in lots of such works.

Same Lead Designer (although not notifiable) and just a single contractor. You may say OTT but it does keep a certain control.

Re supervisiong sub contractors, I know what the Regs say but our safecontractor scheme competence checkers want to see documented evidence that our Foreman monitors the work of sub contractors.

I had to devise a section in the daily safety check to include just that with signature.

It is Ray but it is something we can't get away from.

I've been many hours during the pasy few months sorting out the requirements of the scheme for the annual review and think it is done now.

A right pain in the back side and expensive for my client.

I have some presentations from a recent retail event covering the CDM in retail - PM me your mail I'll send you the link