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lespaul57goldtop  
#1 Posted : 31 March 2017 18:14:04(UTC)
Rank: New forum user
lespaul57goldtop

All, I have seen a few threads when CDM (2105) came out 2 years ago, but since then I wondered if there was any updated views or information on wether you think CDM applies for normal routine maintenance activities within large industial plants? (I work at a Power Station), when we have a shut down and carry out a complete refurb of the units we notify HSE as a notifiable 'project' i.e. >30 Days/500Person Days, however outside of these shutdowns we carry out routine maintenace activities, oil top ups, replacing worn parts, servicinbg of motors and pumps etc., do you consider these as non-notifiable projects under CDM? As a power plant, we obviously come under HASAWA 1974, and as such, have a safe system of work, permit system, with Risk Assessments and Method Statements. but should we also have a Constuction Phase Plan and other documentation required under CDM for general (non-notifiable) maintenance? Thanks in advance.

Kate  
#2 Posted : 01 April 2017 11:11:20(UTC)
Rank: Super forum user
Kate

This kind of routine maintenance doesn't sound like construction work at all, which is the test to apply.  

There was an article in IOSH magazine on the subject which may be helpful: https://www.ioshmagazine.com/article/cdm-2015-maintenance-schedule

thanks 1 user thanked Kate for this useful post.
RayRapp on 01/04/2017(UTC)
RayRapp  
#3 Posted : 01 April 2017 11:51:16(UTC)
Rank: Super forum user
RayRapp

If you examine the Regulation 2 the definition of 'construction work' general repairs and maintenance is included within the ambit of CDM as per below. 

(e) the installation, commissioning, maintenance, repair or removal of mechanical, electrical, gas, compressed air, hydraulic, telecommunications, computer or similar services which are normally fixed within or to a structure,

The alternative view now generally accepted within industry is repairs and maintenance is not normally a 'construction' activity per se. Indeed a very useful link provided by Kate confirms the HSE's thinking. Why the HSE decided to include repairs and maintenance in the first place is beyond me. The real test of course is when a case gets to court...until then, take your pick.

Ian Bell2  
#4 Posted : 01 April 2017 15:31:02(UTC)
Rank: Super forum user
Ian Bell2

Agree with #3. The definitions used in Reg 2 of CDM include general maintenance.

Such is the stupidity of using wide catch all generic definitions.

There is a similar problem with the CDM definition of 'design'. It catches people who don't think they are designers.
peter gotch  
#5 Posted : 03 April 2017 12:08:56(UTC)
Rank: Super forum user
peter gotch

Annex 1 of the parent Directive provides a non-exhaustive list of building and civil engineering works.

Includes 8. Repairs and 11. Upkeep.

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