The HSE collation of the responses to the consultation as presented to the HSE Board meeting on 13 August 2014 is at:-
http://www.hse.gov.uk/ab...014/130814/paugb1462.pdfRegarding the Replacement of the CDM co-ordinator role with that of the Principal Designer (questions 9-10), the summary in the HSE paper states that:-
32. A small majority (52%) of all respondents supported the proposal to embed the pre-construction
co-ordination function within the existing project team. This proposal would replace the CDM coordinator
role with the principal designer role. Of those CDM co-ordinators who responded, 61%
opposed this approach. Of those who were not CDM co-ordinators, 81% supported the approach.
33. Industry stakeholders were generally supportive of the principle – most notably the Royal Institute
of British Architects (RIBA) and the Association for Project Safety (APS) (both with some
qualifications). There was a feeling that pre-construction co-ordination should be seen as an
embedded skill set within the project team rather than an ‘extra’.
34. Some concerns were raised by stakeholder groups and individual respondents alike. Firstly, that
HSE may have overestimated the appetite for designers to engage with the new role – a position
that is echoed in comments received from RIBA, who expressed some concerns about the ability
of designers to discharge the co-ordination function effectively without recourse to third-party
advice. The concern is therefore that the default position will not change in that the preconstruction
co-ordination function will be delegated to a third party, with an associated loss of benefits. HSE has discussed the basis for this concern with a number of stakeholders and has amended the IA in the light of these concerns to reflect the suggestion that some will continue to
delegate the co-ordination role, particularly in the first two years following the revision.
35. Secondly, it was felt that imposing a formalised system for co-ordination, and the appointments
which would accompany it, might be confusing for contractors working in the SME sector,
particularly those who generally undertake domestic construction and maintenance.
36. On balance, the proposed replacement of the CDM co-ordinator role with that of the principal
designer remains appropriate.
The IOSH response to the consultation is at:-
http://www.iosh.co.uk/~/...M-2015-consultation.ashx