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PIKEMAN  
#1 Posted : 12 December 2019 15:11:49(UTC)
Rank: Super forum user
PIKEMAN

An organisation employs a small workforce and routinely installs equipment on housing association properties. Each install takes 2-3 workers a couple of days.  Obviously this is not notifiable under CDM. What though if the contract was to install at say 150 houses across best part of a year? This would arguably exceed the 500 person days and be notifiable? My view is no, in fact this is lots of simple projects strung together in 1 contract, it is not a project in the normal meaning. Has anyone experience of this and can advise?

RayRapp  
#2 Posted : 13 December 2019 09:28:30(UTC)
Rank: Super forum user
RayRapp

I have worked on projects where the workforce is transient and doing essentially the same task so it was more convenient i.e. less paperwork, to lump all the small projects into one large project and notify the HSE. The choice is yours.

Hicks41931  
#3 Posted : 13 December 2019 14:59:28(UTC)
Rank: New forum user
Hicks41931

I think you are putting too much emphasis onto the notification.  Notification is a stand alone requirement now albeit a legal one, but does not trigger duty holder appointments and I would say in this case it does not necessarily need notification.  The work will still come under CDM though and require to be managed as a cdm project.  In the case of a term maintenance contract, my view is that you would do an over-arching CPHSP to cover the general methods of managing the work and have specific RAMS in place for different types and location of work.  If there is no pre-construction requirement or design issues, then even the HSE have said that a PD is not necessary, as it is the everyday type of work for the PC and they can manage that side of the cdm regs as well.

peter gotch  
#4 Posted : 14 December 2019 12:16:14(UTC)
Rank: Super forum user
peter gotch

Pikeman

When I ever have an issue with interpreting CDM, I always default to consideration of what each relevant party should do to comply with the Health and Safety at Work etc Act 1974 (assuming in GB) and common law and apply the "neighbour test" (Donoghue v Stevenson). Have done this for 25 years!

In cases like yours I also apply the pragmatism test - what's the easiest way of managing this Contract - to treat it as one CDM "project" or X 100 two or three jobs, exceeding the 500 person day threshold. Answer almost certainly the latter. One "project", one notification (not exactly an arduous thing to do).

One PD, one PC, together with Pre Construction Information - generic + any localises issues, one Construction Phase Plan + ditto, probably limited Health and Safety File information + ditto (building on what was available within PCI).

In your specific situation there are likely to be some common issues + local variants on subjects such as services and asbestos containing materials - might be some common themes e.g. where housing stock has been subject to estate wide upgrades, but probably some one off changes, particularly if there are some owner-occupiers as a result of Right to Buy (where the new owners did things like put in lots of polystyrene tiles when they were popular and the fire risks were not very well publicised.

Don't take what the HSE says with anything but a pinch of salt. HSE current guidance on CDM is simplistic at best.

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