So in this context, taking (including cleaning which involves the use of water or an abrasive at high pressure, or the use of corrosive or toxic substances) using water jetting to remove graffitti for example, would this activity now require its own Construction Phase Plan?  What are your thoughts?

Sorry Sally, pressed the post button too quick. What I meant to say was that your plan for graffiti removal would probably look more like a RAMS or a SOP than a Construction Phase Plan.

SNS, please see my follow up post. Also the HSE guidance PDF you refer to in your post states that it would not be sufficient for a notifiable project, if you look at the template they have provided it would be covered by a RAMS or SOP as I suggested.

HSE definition of construction work includes;

Hi,

In answer to your question on what constitutes CDM and in particular water jetting it is classed as CDM and will require a Construction Phase Plan (CPP), please see below the reasons why. Risk Assessments and Method Statements (RAMS) are not a CPP. The CPP is the management of the job the RAMS are the carrying out of the task. This is explained in L153.

A CPP is required whether the project is notifiable or not. The CPP should be proportionate to the project and for the water jetting task you describe this will mean it is not too onerous or detailed.

Good advice can be obtained from the Water Jetting Association (WJA) who have written a Code of Practice for water jetting in conjunction with the HSE. 

Please see below the rationale of why water jetting is CDM:

• “construction work” means the carrying out of any engineering construction work and includes—other maintenance (including cleaning which involves the use of water or an abrasive at high pressure)

• “structure” means— any building, timber, masonry, metal or reinforced concrete structure, waterworks, reservoir, pipe or pipeline, road, lagoon, or structure designed to preserve or alter any natural feature, and fixed plant

• WJA Code of Practice the term "Water Jetting" will be taken to include all pressures up to 1700bar (25000psi)

• Construction good practice classes “high pressure water jetting” including the use of additives and abrasives, at
  pressures above 140bar (2030psi) and up to 1700bar (25000psi)

• The most serious potential accidents relate to the direct impact of a water jet on the body. The pressure required to penetrate the skin is in the order of 7bar (1OOpsi)

I would advise, if still unsure, you seek assistance from a construction qualified health and safety professional who is APS accredited to give you proportionate guidance on what should be in place.

I hope that this helps?

Originally Posted by: hilary

If you had more than one Contractor working on this project then it would automatically fall under CDM and a Pre-Construction Phase Plan and Construction Phase Plan would be required regardless of notifiability.  They do not need to be complex but they do need to look at all the risks. 

However, if you just employ one person/organisation to do this task and it doesn't meet the notifiability criteria then it would not be CDM and you could get by with RAMS. 

Stick to one person would be my advice.

Hilary, with respect, you seem to lack a clear understanding of CDM2015. CPP is required regardless. See Regulation 15.