Posted By Heather Aston
Mark

Wasn't aware there were any draft regs?

HSE had a discussion/consultation exercise in 2002 and a proposal was published in Summer 2003 that the Regs needed amendment.

There was supposed to be a consultative document out in 2004, but I haven't seen one?

HSE has put some stuff on its construction page - with particular reference to designers' duties - was that what you meant?

(or have I completely missed the consultative document.....?)

Heather

Posted By Heather Aston
John

I was aware of proposals for change via the HSE discussion document and so on, but had been expecting to see a consultative document for draft Regs on the HSE website. (which is why I queried Mark's use of the words "draft regs")

I hadn't seen the CONIAC paper on the APS website (have now thanks) - looks as though publication of the CD and draft regs on "general release" for comment has been delayed until April 2005 (don't hold your breath with an election coming up) and at the moment it's only been circulated via CONIAC within the construction industry?

Mark did send me a document - which I assume to be the draft regs - but it wouldn't open (not sure what sort of file it was?). Thanks anyway Mark.

I think some clarification of the planning supervisor role will be useful and I would also think that the title "co-ordinator" describes much better the role that individual actually plays.

However this isn't really my area of expertise so I'll go away now and leave it to the construction experts!

Cheers

Heather

Posted By Ron Hunter
It's difficult to comment at this time when consultation and document circulation is still limited within HSC/CONIAC - the context of the report paper M3/2004/3(available as pdf) from APS site is difficult to follow in detail without access to the draft documents being discussed.
The HSC are presumably duty bound to issue a CD for wider consultation at some stage next year?
The change of thought on abandoning Planning Supervisors in favour of 'lead designer' duties is surely a significant change of tack.
In my (humble) opinion the current CDM Regs and ACoP work well when employers/duty holders are motivated, accept and understand the overall value of adopting health and safety management principles into a construction project from "cradle to grave". A significant part of the problem is surely continued non-compliance, in many instances due to lack of knowledge or understanding - the old argument of taking the issues back to the syllabus of further education establishments and CPD surely still applies, particularly for Designers/Planning Supervisors (-sorry Project Co-ordinators)?
Will a change or tinkering with Regulations actually result in improvement? Are there actually sufficient enforcement resources for proactive work by the HSE?
In any event, I do tend to subscribe to that old adage "The Law is written for lawyers", and believe that the availability of clear and concise information and guidance for duty holders is far more important. In that respect, I consider the current ACoP (HSG 224) to be good enough.There is in addition a good selection of excellent industry guidance available. I hope that we do not have a further period of confusion or misinterpretation by this 'step change' approach to CDM. I also hope that HSE keep HSG224 as a seperate publication from the current HSG150 (however it might be retitled) as far as possible - I otherwise fear a rather bulky and unwieldy guidance document!
A final thought:Are problems with CDM merely one instance of much wider non-compliance with the general principles of risk assessment as per Reg.3 of the Management Regs. across all sectors of UK Industry and Commerce? Are we attempting to treat the symptoms as opposed to the disease?