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CDM notification - lot's of small 'projects' under one contract
Rank: Forum user
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Hi all,
I recently agreed to take on some minor CDM-C duties for my organisation. I have attended a couple of good courses with CITB and CSC and have worked on site before so feel comfortable in terms of initial competence to fulfill the role. I also have budget for expert advice should I need it. However...
One thing that currently has me a bit stumped: We have a project of 13 communal floor replacements. There are 13 sites spread over the local borough. Some are on the same estate but mainly they are geographically separated. No individual site will cross the notification threshold.
My question: Do I need to notify HSE because the work is being done by one main contractor and the combined length of work will be over 30 days? Or can I forgo notification and treat them all as separate 'construction' projects?
Many thanks, Jonathan
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Rank: Super forum user
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Jonathan,
If you go to the 4th word of paragraph 15 of the 2007 ACOP, you will see that you have already answered your question.
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Rank: Forum user
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Thanks Stedman. I'm reading that relating to the title of my post - lots of small projects.
And from there inferring that I do not need to notify...
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Rank: Super forum user
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I don't think that para 15 is particularly enlightening in respect of your question and I am not as convinced as you that you can draw a conclusion that you don't need to notify.
We have had a number of similar discussions in the past and if I recall correctly there was some disagreement over the approach to be taken.
Certainly in the past the HSE have advised me that in these situations, you shouldn’t split the project up for the purposes of avoiding notification i.e. treat as one project and notify (or not) on that basis
Others may have a different view.
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Rank: Forum user
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Fair comment Canopener.
I agree that it is not productive or useful to seek ways to avoid notification just for the sake of it. Additionally, I believe that it is not productive or useful to notify 'just in case'.
My approach to all H&S management roles is to maintain compliance and integrity with as little burden/bureaucracy as possible. So, if we don't need to go through the process of notification and everything that comes with it I will have more time to help with the review of risk assessments and method statements etc.
I would still advise the project managers that all other aspects of CDM still apply and that contractor competence is paramount. It would just be nice to be able to reduce the administrative burden of what is essentially low risk work.
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Rank: New forum user
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I was struck by the bold assertion that the person posting considers themselves competent on the basis of the credentials they present.
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Rank: Forum user
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Rank: Super forum user
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ONE contract therefore single project and all the days are accumulated for the project period. A notification with a list of addresses is all that is required.
Yes a competent CDMC ought to know this.
Bob
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Rank: Super forum user
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Commo1979 wrote: We have a project of 13 communal floor replacements. Answers your own question. The "Project" as you refer to it meets Notification Criteria. Your considerations at tender and award must consider whether the contractor selected is competent to conduct the Principal Contractor Role. A trifle tetchy some of the comments on this thread. The duties of the CDM-C on a Project of this nature are hardly complex. A key consideration will be the provision of adequate welfare at all these various sites - as CDM-C you need confirmation of adequate provision, and from the Client's perspective it makes perfect sense to go out and check that waht has been priced is actually being provided. Not so long ago I recall seeing a contractor ripping up vast expanses asbestos-containing floor tiles with and electric floor chisel on just such a Project. I do hope that the requisite asbestos refurb survey and analysis is done, the contractor suitably competent, and a satisfactory method agreed. Ripping up floors by mechanical means attracts one price. Careful prising of individual tiles, shadow-vacuuming, waste disposal, etc. etc. attracts an entirely different price, and hopefully an entirely different sort of contractor. I hope this helps.
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Rank: Forum user
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@boblewis, A fair comment that "a competent CDM-C ought to know this." and I seem to remember that part of competence is knowing your limitations. I do know mine. Hence my question on this forum and the provision of budget from my employer to obtain additional advice where necessary. I won't apologise for not being an expert, competence has to start somewhere or the world would grind to a halt. I've worked full time in H&S for 8 years, spend over 1 year on a construction site and the last 5 years in social housing. I think that gives me a fair starting point when backed-up with 2 weeks worth of APS accredited construction based H&S study and a good support network. I hope we can put the matter of my personal competence to rest now.
My personal opinion is that one contract does not necessarily equal one project. Some contracts are extremely long with significant time gaps and physical distance between construction phases. Not as cut and dry as 1 contract = 1 project.
Thanks Ron for your advice. There are indeed asbestos floor tiles. However, all undamaged tiles are being left in place except for tiles at the outside edge. These will be removed and I will be reviewing the RAMS for this activity. This is a fairly simple project and ideal for me as my first as CDM-C.
All tetchiness aside, this discussion has been very helpful. Thank you to all that have contributed so far...
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Rank: Super forum user
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I do not normally regard APS training as the be all and end all of managing construction safety BUT they are aware generally of CDMC duties and interpretations.
Bob
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Rank: Forum user
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That's true. I agree. This is why I also went on the SMSTS at the National Construction College, which I have to say was a more useful insight into what actually happens on site, and I met a lot of useful people there too...
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Rank: Super forum user
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A contract is let for work and that is the work of the project albeit spread by place and time. Hence a single contract indicates a single project. If each floor was let separately then you would have multiple projects. Treating as a single project is far more efficient in any case, as well as cost effective.
Bob
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Rank: Forum user
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Thanks Bob, I'll take your advice. I am on a steep learning curve. Which I enjoy actually...
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Rank: Super forum user
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Agree with Bob - whilst it's up to the client to define what constitutes the project, it's much easier to manage if aligned with the contract.
One notification, one Pre Construction Info, one Construction Phase Plan, all with multiple site specific information to supplement what applies to all, multiple Health and Safety Files but with largely similar information (or none if no "significant risks" arise from the works - see para 133 of CDM ACOP for definition of "significant risk"
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Rank: Forum user
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CDM notification - lot's of small 'projects' under one contract
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