Rank: Forum user
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Probably a little premature but here goes;
what do my fellow safety professionals expect/hope to see from the HSE review of the current CDM regulations?
I for one would like it to be made clear to the supply chain that a successfull assessement by a SSIP member scheme is acceptable evidence of meeting the core criteria (as required by appendix 4). Hopefully this would then do away with the numerous and time consuming in house PQQ assessment schemes that have been developed by most companies.
Allan
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Rank: Super forum user
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Allan,
I would go along with that up to a point. I would say that SSIP schemes meet stage 1 of the competency criteria and should be accepted as such.
However, I have assessed contractors who have attained SSIP accreditation within a specialst field but had no experience at all in the area of construction that they were tendering for (e.g. Electrical contractors tendering for major structural and pipeline schemes).
PH2
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Rank: Super forum user
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allanwood wrote:Probably a little premature but here goes;
what do my fellow safety professionals expect/hope to see from the HSE review of the current CDM regulations?
I for one would like it to be made clear to the supply chain that a successfull assessement by a SSIP member scheme is acceptable evidence of meeting the core criteria (as required by appendix 4). Hopefully this would then do away with the numerous and time consuming in house PQQ assessment schemes that have been developed by most companies.
Allan
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Rank: Super forum user
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allanwood wrote:Probably a little premature but here goes;
what do my fellow safety professionals expect/hope to see from the HSE review of the current CDM regulations?
I for one would like it to be made clear to the supply chain that a successfull assessement by a SSIP member scheme is acceptable evidence of meeting the core criteria (as required by appendix 4). Hopefully this would then do away with the numerous and time consuming in house PQQ assessment schemes that have been developed by most companies.
Allan
I suspect that the issue of competence will not even appear on the 2014 CDM Regulations other than the word.
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Rank: Super forum user
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Agreed Allan, but this unlikely to make the Regs, more likely a clarification within the ACoP. Further qualification is also necessary. There are several good commercial PQQ schemes who chose not to sign up to SSIP - they should be included.
Further, any Organisation which can demonstrate a 'satisfactory' result of a 'recent' accredited Audit of SMS should also be excused from further PQQ examination.
By 'satisfactory' I mean no Major failings, and by 'recent' I would suggest within 3-5 years max.
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Rank: Super forum user
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Allan
I don't think we need to replace CDM2007 any more than we needed to replace CDM1994.
What's needed is for HSE to enforce CDM proportionately targeting the top end of the supply chain i.e. clients and designers. A few targeted prosecutions of large clients for appointing CDMCs MUCH too late and appointing incompetent contractors would go a long way to making CDM work much better.
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Rank: Super forum user
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Also agreed Peter. Reading the limited text available of a great number of the CDM prosecutions on HSE database, it seems that it's still the contractor who routinely gets it in the neck, when there seems to be a suggestion of failure further up the chain at Client/Designer/CDM-C levels.
Lazy "easy target" enforcement I suspect.
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Rank: New forum user
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I understand the CDM Regulations will mirror that of the Temporary or Mobile Construction Site Directive 92/57/EEC. The republic of Ireland currently work under the directive as Project Supervisor for the Design Process.
I would interact with these regulations quite often and SSIP is quite often a benchmark for PQQ in the early stages and all Principal Contractors are assessed accordingly. It is important to note that all hazards so far as is reasonably practicable are mitagated prior to handover to the principal contractor so the risk is not transferable that said if a hazard such as a via duct running under through the site was not raised at the early design stage then a penalty to the client will arise through cost and time will ensue.
Another Point is that AFI form is signed by the client and the client forwards this to the HSA at the early design stage. When the Principal Contractor and Project Supervisor for The Construction Stage is appointed he then has to submit a AF2 form to the HSA that work is to commence on site.
So will CDM 2014 align itself with TMCS directive and remove notification by the CDM Co-ordinator or indeed will it be time to change the CDM Co-ordinator name to the Project Supervisor for the Design Process (PSDP) which also works closely with that of the Principal Contractors Project Supervisor for the Construction Stage (PSCS) It will be interesting to see how CDM 2014 gel the Client requirements through the Designers appoinment into the SSIP process into appointment of the Principal Contractor with the CDM Co-ordinator acting as the glue.
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Rank: Super forum user
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Rank: Super forum user
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With the HSE being tasked to re-write the CDM Regulations just based upon basic text within the Mobile Construction Site Directive, where is all the secondary legislation going which came out of the Construction (Health, Safety and Welfare) Regulations 1996 is going to go and how another new Statutory role (Project Supervisor for Design and Construction Phase) is going to impact on the APS application for Chartered Status?
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Rank: Super forum user
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Stedman: All the '96 CHSWR elements are contained within the Annexes of the Directive. In that respect, the consolidation of '96CHSWR within CDM2007 already mirrors the Directive requirements.
I'm not entirely sure about this domestic client issue. I'm aware of the specific wording in DIRECTIVE 92/57/EEC, however the Parent Directive (1989) and indeed the treaty article 118a are specifically concerned with employer relationships. I suggest that I have no more of a direct "employment" relationship with the builder I commission to repair my roof than I do with the people who deliver and install a new washing machine from Curry/Comet in my kitchen.
As for the APS, CDM-C role etc, much depends on just how closely the HSE want (or are directed) to translate the Directive. The Directive is concerned with the "moveable feast" that is the Project Supervisor.
Nothing (in theory) stopping the UK from retaining the Designer and CDM-C roles?
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Rank: Super forum user
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quote=ron hunter] As for the APS, CDM-C role etc, much depends on just how closely the HSE want (or are directed) to translate the Directive. The Directive is concerned with the "moveable feast" that is the Project Supervisor.
Nothing (in theory) stopping the UK from retaining the Designer and CDM-C roles?
Ron,
According to this months CIOB magazine Construction Manager, this states that there has been endless debate about the role - the HSE is keen to re-open this and generally wants to reach a consensus with the industry over the best way forward."
I cannot see how the APS body can possibly pursue their Chartered aspirations whilst there is also public debate taking place at the same about the role of CDM-C (or Project Supervisor equivalent).
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Rank: Super forum user
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I agree the CDM Regs are of no use unless properly enforced with ENs and prosecutions. That said, I would like to see the new CDM Regs include a generic suite of templates to include a CPP, method statements, risk assessments, site inspections and so on. So that we can all easily understand and review each others documents - now that would be really useful.
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Rank: Super forum user
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ACoP already contains a template for CPP Ray. Site Inspection Checklist used to be in HSG150, maybe still is?
And our old friend the Safety Method Statement - on which health and safety law is entirely silent!
In the most general of terms, for Notifiable Projects, the initial CPP should BE the Method Statement.
i.e. the PCI should highlight the Project Specific Risks and should require that these are specifically addressed in the CPP.
That is one of the basic principles of CDM. Sadly, it hardly ever comes to pass, usually because the whole exercise becomes a cop-out of generic twaddle.
On that basis, I'm wholly against generic templates. Good Project examples, yes, but not templates -beloved of bureaucrats and the bane of a sensible, Project specific and proportionate approach.
On the wider debate, Lofstedt and others would have us believe that poor compliance in the SME construction sector is somehow the fault of poor Regulations. Nonsense of course. Compliance is dependent on good enforcement by the regulator, but first and foremost compliance is down to supply chain pressures - always a stated objective of HSE. Unfortunately the big boys in this supply chain seem to be obsessed with "tick box" compliance via CSCS and repetitive and restrictive PQQ issues - not forgetting the cheapest quote of course!
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