Rank: Forum user
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Obviously taking aside CDM Notifiable I wanted to canvass peoples opinion on a topic related to Non Notifiable CDM work.
Obviously we have a set of guidance as to what is classed as construction work as follows and although Non Notifiable we still have to conform to the CDM apart from the Notifiable part. As we are all aware there is a simplified Construction Phase Plan Template for simple works etc which can be used.
BUT bearing in mind the above what in peoples opinion is the break off point as to when CDM doesnt apply for instance at what point should a construction phase plan be used ? One scenario i can think of are as follows. Electrician goes to site to repair and fit a new light fitting total hours 2 or even less Is a short construction Phase Plan required ? Or do assessments on their own etc suffice ? Basically if we do just use assessments for work at what point would a Construction Phase Plan in its shortest format be required ??
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Rank: Super forum user
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If I have read your query correctly, then there is no distinction in CDM between large and small construction projects, except for those which are deemed to be Notifiable. In any case, all construction related projects require a CPP where there is a PC, regardless of the size of the project and one which is proportionate to the task.
On very small tasks you would have to ask whether there is any real benefit in preparing a CPP. A simple Method Statement/Risk Assessment (RAMS) would suffice in most cases. If you want to adhere strictly to CDM you could call your documentation a CPP, or alternatively RAMS/CPP.
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Rank: Super forum user
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The name Construction Phase Plan is in itself not mandatory as long as there is clearly a suitable management plan fitting the task.
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Rank: Super forum user
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Regulation 12(1) and associated L153 guidance refer to prep. of a Construction Phase Plan before a Construction Site is set-up. The interpretation of 'Construction Site' suggests a place set aside exclusively for construction work (discuss!).
Which suggests no requirement for CPP in your scenario. All the other good things making up SSoW need to be available.
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Rank: Super forum user
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Ron, I don't think there is anything to discuss - CDM Regs, guidance and definitions conflict with each other and besides they are poorly conceived and drafted which leads to a lot of confusion.
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Rank: Forum user
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Hi Spud,
In answer to paragraphs 2 and 3:
The definition of ‘construction work’ as set out in Regulation 2(1) in CDM 2015 is broad, non-exhaustive and is largely the same as it was in CDM 2007. Construction work may take place within many industry sectors and CDM 2015 will apply if the activity falls within the definition.
It is not the HSE’s role to provide a definitive interpretation (only a court can do this), there follows general pointers as to how it should be construed in cases of uncertainty.
There are two steps to determining whether an activity falls within the definition of "construction work", and therefore whether CDM 2015 applies.
Step one: The project/activity must fall within one or more of the three categories set out in the definition within L153 Managing Health and Safety in Construction, those being the carrying out of any;
- building work,
- civil engineering work, or
- engineering construction work
If the activity falls within any of these three categories, CDM 2015 does apply. If the activity does not fall into any of the three categories, CDM 2015 does not apply and Step Two is not relevant.
Step Two: If the activity falls into one of the three main categories (identified in Step 1), then the list of specific construction activities in L153 are relevant and provide the second stage to determining if an activity is construction work.
In answer to paragraphs 4 and 5:
Whatever you call the construction phase plan it is a document which must record the arrangements for managing the significant health and safety risks associated with the construction phase of a project. It is the basis for communicating these arrangements to all those involved in the construction phase, so it should be easy to understand and as simple as possible.
The plan should not include documents that get in the way of a clear understanding of what is needed to manage the construction phase, such as generic risk assessments or detailed safety method statements.
In short a construction phase plan is required for all construction work irrespective of size/time required and is the "managing". The RAMS are the "doing".
I hope this helps?
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