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#1 Posted : 22 May 2020 06:16:28(UTC)
Rank: New forum user

Dear All I work in property for a LA, mainly in property compliance and maintenance, we are Clients (often Principal Designers and Designers) for projects, mostly small-ish. Upon appointing a PC we ask for their CPP to include RAMS. We are careful to avoid 'approving' their RAMS, only commenting if we feel they are insufficient. I think this stance is CDM compliant. Often a PC will also send Sub-contractor RAMS and I feel that we should avoid getting to discussions over these as CDM requires that the PC appoint (and therefore approve the competence of) sub-contractors. However my colleagues often send them on to me (H&S Officer) and once they are in my possession I feel obliged to cast an eye over. Does the community feel that we should indeed review the Sub-contractor RAMS? or make it clear to the PC that they are their responsibility? Or perhaps not review any RAMS at all?

Many thanks in advance. Andrew

#2 Posted : 22 May 2020 08:52:28(UTC)
Rank: Super forum user

What you are describing is your contractor simply passing on sub-contractor documents.

You are not actually being asked to look at sub-contractor RAMS but the document being presented for the task (or part task) by the contractor. Where this could be clearer is if the contractor had

1) Re-published the content on their own letter head

2) Include the sub-contractor document(s) within their master RAMS for the overall task

At the end of the day it is your site they are working on so you need to be sure that for high risk activity there are suitable controls being documented and followed otherwise why would your (or any LA) CPP require such paperwork in the first place?

BTW a good lawyer could argue even if you do not specifcally sign / approve the RAMS by having requested the document and permitting the task to commence based upon the supplied document there is complicity. Your order for example would reference either the project tendered or the contractor reference document and evidential trail back to the RAMS.

thanks 1 user thanked Roundtuit for this useful post.
Kim Hedges on 24/05/2020(UTC)
#3 Posted : 23 May 2020 08:43:46(UTC)
Rank: Super forum user

This is a classic case of 'paper safety'. There is too much reliance on paperwork - why you would want to review a sub-contractor's RAMS I have no idea. As mentioned previously, the PC is responsible for the subbies they employ and as the Client you have selected a competent PC - I hope!

I would review the CPP but normally that is all and any comments would follow. Reviewing or approving is really just semantics. As the Client and/or PD you have responsibilities pursuant to CDM and therefore you need to show some diligence when managing the project.

Kim Hedges  
#4 Posted : 24 May 2020 14:02:41(UTC)
Rank: Super forum user
Kim Hedges

I've previously worked for an LA (or Council) for many years, never in the capacity of H and S. 

Seems to me, if you get these documents, you really should look at them, simply to see that you don't get stuck in a future court.  The RA and in particular the Method Statement from some contractors can be rather generic, that should be stamped on hard, it's lazy and incompentant and put's workers at greater risk, than if the job is properly described.

I work in construction and currently in the lifting game, I often see generic lift plans with method statements written by people who earn hundreds of pounds more than me every day and these MS stink. 

The tasks should be itemised and details of how to do the work should be explained in simple terms for the workers to read and understand.  No big fancy words what task, what tools, what attachments, what plant hire, from whom (and why them). 

#5 Posted : 25 May 2020 09:34:15(UTC)
Rank: Super forum user

I have worked for a LA as the H&S Compliance Manager and on major projects acting for the PC. There are some subtle differences between the two roles but in principle not a lot of difference.

When working for the LA it would have been almost impossible to review all the documents produced by our contractors, never mind their sub-contractors' documentation as well. As a rule I only reviewed CPPs and RAMS associated with higher risk projects.

It is not the client's role to micro-manage projects. That said, the client does have an important role in ensuring certain aspects of the project are carried out as per CDM. So whether you review documentation or not will depend very much on the resources and in-house expertise at your disposal.


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