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Posted By Bob Pedley
I received a copy of the latest version of the CONIAC 20 July 2006 Annex 4 draft CDM 2007 ACoP this week. It looks pretty good but I was disappointed by the fact that IOSH does not get a mention. In the appendix 4 on competence, "Note 1: Chartered membership of a recognised construction related institution", is now a recommendation specifically for the new Coordinator role. Fellowship of Association for Project Safety, Membership of Institution of Planning Supervisors feature.
Is any one from IOSH flying the flag??
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Posted By Brett Day
Given that there are many who act as Planning Supervisors and are competant at what they do despite not being chartered members of IOSH or Fellows of APS. I would be somewhat concerned at this being actively pushed, granted the above can be used as a guide to qualifications but they do not give an idea of depth of experience.
Incidently I tried to join APS, passed the exam but couldn't join at the time as I was not a member of a chartered institute so was barred by the APS membership requirements.
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Posted By Dave Daniel
The last member of the institution of planning supervisors I met insisted on my client complying with the "asbestos at work act" whatever that was, even after I pointed out his error to him. To say his knowledge of H&S was scanty would have been a kindness. If this is competence then I should pack up and go home....
There was a recent thread asking what IOSH might do to support the Olympics in 2012. Perhaps making sure that planning supervisors actually are competent as the law requires might be a good start, and excluding IOSH qualification seems to be a recipe for disaster.
On the face of it there is a serious case for IOSH challenging this issue of a "construction-related" qualification. This smells of protectionism. If you did a CDM job on the railways for example, I doubt that a construction qualification would be appropriate, and likewise if you undertook a CDM job in a factory.
Are you listening Moderators? Perhaps a quiet word onwards might be in order. There IS something useful that IOSH can do!
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Posted By Robert K Lewis
I suppose that the unfortunate aspect of this guidance is that it is trying to make helpful suggestions to an industry which notoriously sees "example qualifications" as being the only acceptable. Even appendix 4 is trying only to provide indications of what might constitute competence not an absolute list/tick box. The very mention of APS, CSCS, IPS and others is going to be read as "you must" in spite of the phrase "such as" being carefully inserted.
The corporate nature of the co-ordinator has also been softened by the guidance. The regs themselves use the singular "person" for designer, contractor, client and co-ordinator. We seem able to see recognise the first 3 in corporate terms but not the co-ordinator - why the perceptual set?
The chair of the Coniac committee is an IOSH member so perhaps we do need to make a clear statement somewhere on this.
Bob
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Posted By Charley Farley-Trelawney
Robert
I was unable to access the link, it would appear to be a non existant page within the HSE, would you perchance have any other link?
CFT
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Posted By Robert K Lewis
You probably need to register yourself onto the CDM forum as I get updates via there from the HSE.
Bob
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Posted By Charley Farley-Trelawney
Thanks Robert
CFT
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Posted By Terry Price
The HSE said it will be put up on the web next week
Terry
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Posted By Robert K Lewis
I would, as I replied to CFT, encourage all interested persons, particularly IOSH members, to register on the CDM forum as there is a debate developing - mostly critical of the draft. Is there not Bob P?!
As IOSH members we need to get involved in the debate and try and move the institution to do so also. I personally am pushing for IOSH to co-ordinate across the parties interested in H&S competency training with a view to defining a concensus view on the syllabuses required from professional to operative level. Your support is needed if this is to get off the ground.
Bob
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Posted By Ciaran McAleenan
Dear all
The debate on which qualification or which institution can lay claim to delivering competence fails to understand that we derive our competence through a variety of routes and when the time comes to deliver a project for a client we need to measure competence against the clients and/ or the regulatory requirements.
(Note CDM proposed not only requires the client to establish competence before offering commissions but it all requires individuals or organisations to be assured of their own competence to deliver before accepting it).
With reference to the core document COUNCIL DIRECTIVE 92/57/EEC, upon which CDM is derived consider this…
* Competent co-ordinators (preparation stage) need to have sufficient skills, knowledge, experience, authority and resources to perform the duties outlined in Article 5 (a) through (c), with reference to the particular construction project.
* Competent co-ordinators (project execution stage) need to have sufficient skills, knowledge, experience, authority and resources to perform the duties outlined in Article 6 (a) through (f), with reference to the particular construction project.
There is no reference to qualification or membership of a professional body but clearly there is a need to have “a sound working knowledge of health & safety in construction work, a thorough knowledge of the design process and experience of the site processes likely to be involved in the project and in future maintenance, refurbishment or demolition”.
If designs are to be such that they can be built, used, maintained and eventually demolished in a manner that will not cause harm to the construction workers or users then the debate on competence needs to be focussed on the skills needed to deliver.
If the various Institutions are to do justice to the process and to themselves they need to ensure that in pushing the core competence requirements they avoid any hint of self-interest. This will demonstrate true professionalism.
Regards
Ciaran
COUNCIL DIRECTIVE 92/57/EEC
Web link: http://europa.eu.int/smartapi/cgi/sga_doc?smartapi!celexapi!prod!CELEXnumdoc&lg=EN&numdoc=31992L0057&model=guichett
“Article 5
Project preparation stage: duties of coordinators
The coordinator(s) for safety and health matters during the project preparation stage appointed in accordance with Article 3 (1) shall:
a) Coordinate implementation of the provisions of Article 4;
(b) Draw up, or cause to be draw up, a safety and health plan setting out the rules applicable to the construction site concerned, taking into account where necessary the industrial activities taking place on the site; this plan must also include specific measures concerning work which falls within one or more of the categories of Annex II;
(c) Prepare a file appropriate to the characteristics of the project containing relevant safety and health information to be taken into account during any subsequent works.”
“Article 6
Project execution stage: duties of coordinators
The coordinator(s) for safety and health matters during the project execution stage appointed in accordance with Article 3 (1) shall:
(a) Coordinate implementation of the general principles of prevention and safety:
- when technical and/or organizational aspects are being decided, in order to plan the various items or stages of work which are to take place simultaneously or in succession,
- when estimating the period required for completing such work or work stages;
(b) coordinate implementation of the relevant provisions in order to ensure that employers and, if necessary for the protection of workers, self-employed persons:
- apply the principles referred to in Article 8 in a consistent manner,
- where required, follow the safety and health plan referred to in Article 5 (b);
(c) make, or cause to be made, any adjustments required to the safety and health plan referred to in Article 5 (b) and the file referred to in Article 5 (c) to take account of the progress of the work and any changes which have occurred;
(d) organize cooperation between employers, including successive employers on the same site, coordination of their activities with a view to protecting workers and preventing accidents and occupational health hazards and reciprocal information as provided for in Article 6 (4) of Directive 89/391/EEC, ensuring that self-employed persons are brought into this process where necessary;
(e) coordinate arrangements to check that the working procedures are being implemented correctly;
(f) take the steps necessary to ensure that only authorized person are allowed onto the construction site.”
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Posted By Robert K Lewis
Ciaran
We need to remember however that the HSE has separated some of the co-ordinator functions within the directive among other parties, particularly the PC at execution stage. This does lead to confusion across borders sometimes but we learn to live with it.
I will always come back to the need to stop thinking of the co-ordinator role as a solo flying individual. To my mind its corporate nature is a must and from this stance IOSH and its membership have a definite role in larger projects as part of the co-ordinator function. We get desperately worried about contractors and designers undertaking the role but I think this shouold not be such an issue, Information Barriers can be readily applied and I could produce conflict of interest arguments for specialist PS or co-ordinator suppliers as much as contractors or design houses.
I think we should also look at some of the ambiguities and errors in the guidance as these seem to have been ignored to press.
Bob
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Posted By David S Burt
Bob,
I opened a thread on this very subject on the Internal Business Forum on the 21 June and I must say that to date I have found the responses very disappointing.
The reason for opening the debate on the Internal Business Forum is because I believe this is a matter that needs to be discussed by the people who are most likely to be affected by the outcome i.e. IOSH Members.
I am starting to think that the Safety Professionals who work in construction are a minority group within IOSH. This conclusion is based on 150 views and 8 responses (one of which was mine) to my posting over a month ago and 651 and 13 responses in under one day on this forum!
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Posted By Robert K Lewis
David - Several of the responses to your thread were also mine. But I totally agree with you. Too few people actually want to do more than speak from the sidelines so to speak. I am putting pressure wherever I can but the voice of IOSH is rather muted. My best guess is that by the end of October we will have missed the boat as an institution. If members are that interested they need to make sufficient noise to get the process moving forward - as you say preferably on the Internal Business thread where we can have an open approach and robust discussion.
Bob
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Posted By David S Burt
Robert
I found it very refreshing that the Olympic Delivery Committee has made a really positive statement on the Standards of Health and Safety that will be applied during the construction of the facilities for the games. The full text can be read on the latest news section of the IOSH Web site.
I also fully support the statement that Lawrence Waterman has made on this subject in his role of Head of the ODA Health & Safety Team.
My understanding of the revised CDM Regulations is that they will not be in place until later this year and they will not be retrospective. By that time the contracts for the construction activities related to the Olympics will have been let and therefore the numerous works relating to both the Tier 1 and Tier 2 Projects will be carried out under existing legislative requirements.
This means that despite the revised ACOP not recognising Chartered Safety & Health Practitioners as being competent to undertake the role of Project Coordinator (as defined Appendix 4 of the current soon to be accepted draft ACOP),currently defined as the Planning Supervisor, Competent IOSH members should still be able to take an active, productive role in assisting the ODA and Lawrence in achieving their goals.
Perhaps there is still hope for members of IOSH to be seen to be making a valuable contribution to Health & Safety in the construction industry.
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Posted By Robert K Lewis
David
I would that we could have such a situation. I will keep hitting the same drum however when I state that the proposed guidance has failed to emphasise what is in the regs - namely the corporate nature of the Co-ordinator role. If we recognise and hold on to this fact we can construct, excuse the pun, a team drawn from professionals across the board to provide the best possible role. It is also explicit in the current version of CDM. I would hope that the ODA is able to take this on board, after all there is another 5.5 years to run of the contract work.
It would also perhaps herald an opportunity to disband the APS et aliter as a supposed professional body and allow it to become an interested group in the industry. Sanity says that we must use the right competent professional staff for construction roles if we are to improve performance, including H&S, not fiddle about with persons trained for one task and part trained for another.
Bob
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Posted By Roland Crane
Just a quick note. At a recent IOSH Branch Seminar on the changes to CDM, a member of the audience asked the speaker (a senior HSE Inspector), what the HSE's view was on comments made by APS on the new changes. His answer, We do not recognise APS!
I am now confused!
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Posted By Les Welling
On another matter but closely related. My daughter worked for an agency and was sent to a company. Having arrived there she was asked where her PPE was. Totally bemused she asked the company to supply this. The company said that the agency should have provided this. Having spoken to the agency she was told she had to supply this herself! The LA EH&S Office were not helpful as they were not clear on this. My view is that the company should supply this free of any charge of course as per the PPE Regs. However, it appears that with agency staff the law is not as B&W as we think!
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Posted By Robert K Lewis
I have seen agency contracts of employment that purport to provide PPE and then charge the person if it is not kept in good condition and needs replacement!! This included rubber gloves.
I do think it about time the HSE and the EHO, as applicable, took this problem on board. The agencies often state to employers that they provide such as PPE then pass the cost to the poor employee.
Bob
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Posted By Dave Wilson
agency is responsible for the provision of ppe and training of employees they send out. site specific induction given by the people in control of the site
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Posted By David S Burt
Roland,
Two points:
1. Could someone explain to me what the provision of PPE to Agency workers has to do with the proposed Draft CDM Regulations that are due to be implemented next year? and
2. What hope is there for IOSH if the HSE do not recognise the APS who are actually named in Appendix 5 of the current and likely to be introduced CDM ACOP? IOSH are not considered as being worthy of a mention in the ACOP.
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Posted By Advanced Safety
David
Good point.
I was also disapointed that the CIOB were not mentioned in the ACOP, as they appear to have the largest membership of general Construction Professionals. In my experience, many Principal Contractors are more competent to assume the role of Co-ordinator than many of the Planning Supervisors i deal with on a day to day basis.
On a lighter note. As a Chartered Builder and a Chartered Safety & Health Practitioner, i have no recognition within the new proposed regulations. I think i will therefore hunt out my tools (not seen since the mid 80's)and return to the noble art of Bricklaying! Although my City & Guilds qualification is also not recognised by the CSCS regime, so will have to get an NVQ!
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Posted By Paul Bradford
I do not agree that Principal Contractors would be best placed to fulfil the role of Co-Ordinator nor do I think that Designers are suited. Both the PC and the designers have their own agenda (be it cost or fanciful ideas about design)
I do believe that the PC should be dovetailed into the design team as they are best placed to advise on builability and advise on aspects of the design which may prove difficult to construct from a safety point of view.
One of the main functions of the Planning Supervisor is to question aspects of the design from a safety stand point without an agenda on cost, quality or appearance etc. I do believe that the current PS organisations are best suited to evolve into the new Co-Ordinator role.
P
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Posted By David S Burt
Paul,
The following is part of the posting that I placed on the Internal Business Forum in June this year.
While I am sure that the criteria to become a Fellow of the APS is very strict and is backed up by a NEBOSH Construction Certificate, the depth and breath of knowledge required to achieve that status is extremely narrow. The following is a direct take from the APS Web site
‘Understanding of the Regulations, the ACOP and the APS Planning Supervisor’s Guide will underpin the answers to these questions which may be in the form of bullet points or notes rather than that of an essay’.
I find it very hard to understand how the above can be deemed to be sufficient to allow any person or individual to be able to provide practical health and safety advice, guidance and support in matters relating to human factors, behavioral safety and complex risk assessments.
On the other hand a competent CMIOSH with a good construction background will possess and have demonstrated the necessary competencies to deal with the above issues. In addition they will or should have an in depth knowledge of the CDM ACOP.
Are you suggesting that that my interpretation of the above is incorrect? If this is the case I must be a member of the wrong Professional Institute. In the same vain I also believe that while a significant number of Health & Safety professionals claim to be competent in Construction and or Civil Engineering the reality is totally different.
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Posted By Simon R
The HSE have today issued a press release regarding the involvement of the Steering Group involved in drawing up the guidance documents for CDM2007.
Towards the end it lists those involved on the steering group and includes 'Institution of Occupational Health and Safety' (sic)
It also includes the following paragraph:
"The steering group welcomes the input of all sections of the industry and particularly encourages other bodies involved in developing guidance to submit proposals to the CONIAC steering group. Anyone wishing to contribute should contact the Chair, Kevin Fear (mailto:kevin.fear@citb.co.uk 01485 577451) or the secretary Stephanie Rafferty (mailto:Stephanie.rafferty@hse.gsi.gov.uk 020 7717 2163) in the first instance. "
Now is the time to get our concerns and comments heard - so let's get to it!
The full document can be found at:
https://www.gnn.gov.uk/c...,674,708,683,706,718,674
I hope this causes some revisions and alleviates some of the causes for debate that have been ongoing for some while. It's down to us as Members of IOSH to state our case , and for IOSH to put it for us
There has surely been enough debate within these fora for the 'powers that be' to have gleaned an idea of what the membership feels.
Regards
Simon
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Posted By Paul Bradford
David,
I am not suggesting that your interpretation is wrong and I do feel that there can be no correct answers at this stage. We all know what Coniac have suggested and indeed what John Carpenter has suggested as a minimum competency requirement in order to fulfil the role of Co-Ordinator.
Most practising Planning Supervisors I come across (including myself) would not be deemed competent to carry out the role if the suggested competencies are enforced. By the same token there is not one single profession who would be. The point I was making was that the Construction Managers need to have more say at the design stage as they are really the only ones who could steer designers away from designs that are clearly not buildable (from all aspects).
The PS needs to identify potential risks during construction, during maintenance and cleaning and during ultimate demoltion as the end of the buldings life. Manay contractors cannot see that far ahead and are really only concerned with the construction phase (as are most designers for that matter). You still need that independant body (PS) to ask the questions and champion change in designs without favouring one agenda or the other (quality, cost, time etc).
P
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Posted By Advanced Safety
Paul
I must disagree with your thought that the current Planning Supervisor organisations are best suited to the role of the Co-ordinator. I do however agree that no single profession can assume this role. However, i dont see the Association of Planning Supervisors (oops! conveniently changed)encouraging members not to solely assume this role. I am sorry if i sound biased against APS, but i am afraid that this has been built on the experience of dealing with Planning Supervisors on various sized projects for the last 10 years.
A quick example! I have been delivering a number of seminars over the last 6 months, based on the proposed changes to CDM and its possible impact on all duty holders. The seminars have been, aimed at, and attended by Designers and Structural Engineers (at my clients request). During the delivery of the seminars, i found that many of the attendees had assumed the role of Planning Supervisor and many were members of APS. Their general lack of understanding of the current regulations came as such a shock to my client, that we adapted the semiar to include the current regulations as well!
Again, i am not setting out to pick fault with APS, but i really dont feel that any single body should be representative of this role. Try the ICE Register, this is a real assessment of competence that i feel should be encouraged more, and is certainly endorsed by the HSE. (No, i am not registered)
I know this will leave me open for the APS firing squad, but that is my view. No back to polishing my Trowel and staightening my Stabila!
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Posted By Paul Bradford
AS,
I would have to agree with to a certain extent although I do feel that APS are quite a useful organisation (I am not a member of APS).
Eg, Any person with a relevant qualification (appertaining to the design team or construction) can join as long as they have 5 years post qual experience. This would mean that, for example, Interior Designers could join and become practising PS's and not know a thing about construction.
Whilst practising PS's with the correct quals and construction experience who dont have the necessary post qual experience are not eligible to join. I have a degree in construction management which I achieved in 2001 and have 8 years construction experience in total. I am not eligible to join.
I would agree that the ICE register is very highly thought of in construction circles.
If construction managers etc were to carry out the function of a PS then it would have to be a dedicated function and not "lumped" in with the role of PC. The PS role needs to be on a seperate branch of the tree to be able to carry out the role required. So in that context yes Construction managers would be great at the co-ordinator role (if they were acting in that capacity only)!
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Posted By Paul Bradford
In the company I work for there are Planning Supervisors from varied backgrounds with various different skills and competencies.
As a whole Organisation, yes the PS is competent as a "WE" not each person as an "I".
More emphasis need to be placed on the Planning Supervisor as an organisation and not as a single employee.
To be competent, one needs to know their own boundaries and limitations and ask for help or assistance from other colleagues with the necessary knowledge. Therefore I cant see how any one person can be truly competent (unless they are know it all's). I certainly know when to tap in to the knowledge and resources of colleagues and when to make use of the diverse range of skills within my organisation if need be. If in doubt it makes sense to ask for help. I dont think any of us are above requesting help or assistance from others.
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