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Posted By Jonathan Sandler CMIOSH
With the Rail Industry via the new regs getting rid of the term method statement and within the new proposed CDM regs the risk assessment to be removed, and replaced by Safe system of work, how long will it be before all industries work only to a safe system of work?
Can it be achived?
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Posted By energy saver
How can you write a safe method of work without doing an assessment of the risks first?
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Posted By Jonathan Sandler CMIOSH
if you write/produce a safe system of work for the task you wish to carry out, then from that document you will manage to obtain the method on how to do the task and the risks associated with the task.
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Posted By J Knight
Hi Jonathan,
I'm with energy saver on that one; for something to be described as 'safe' it surely must be claiming to eliminate identified risks, and how can it do this if an RA (of some sort) hasn't been carried out? I mean, I could write a system of work for laying sub-sea pipework in the next half hour, but it certainly wouldn't be safe, as i know nothing about the hazards and risks associated with the work except in the very broadest of terms (its wet, its dark, there's pressure). Just writing a 'safe system of work' won't give you the risks; the risk knowledge informs the ssow,
John
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Posted By ddraigice
So in essence you've done a risk assessment then?
The requirement for an RA is not in CDM.
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Posted By J Knight
Hi Folks,
People keep saying the requirement for RA is not in CDM; I have CDM 2007 in front of me and it says:
'information on the risks to their health and safety -
(i) identified by his risk assessment.
OK this is contractor's duties, and if you mean an overarching RA for the whole project, no this is not in CDM, and the CDM-C has to apply the principles of prevention. How can the principles of prevention be applied without an RA? I think what we have here is an explicit implied duty (I'm ready for the tablets now, nurse) to carry out an RA, and I think that's how it will work in practice,
John
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Posted By ddraigice
Yes but strictly speaking there will be a note somewhere saying that it refers to an RA as required under management regs.
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Posted By J Knight
Hi,
Exactly my point; the requirement for RA is fully spelt out in the management regs, so all CDM2007 needs is to talk about the rpinciples of prevention, and there is your RA nestled firmly in CDM,
John
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Posted By ddraigice
OK look at it this way - if HSE or LA were to prosecute a company for not having an RA on a CDM project they could not prosecute under CDM - only under M regs.
The same requirement is in WAH regs - but it stems from the Management regs. (and COSHH come to think of it but that may be the exception.... I'll have to check)
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Posted By J Knight
That's fine, again, just what I was thinking; but at the end of the day it doesn't matter too much which particular set of regs the prosecution case cites; its the size of the penalty that counts,
John
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Posted By GSP
Risk Register?
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Posted By Jonathan Sandler CMIOSH
Dear all
Please note:
Please have a look at the HSE website under "Construction" and the sub heading "Designers". You will find that the HSE recommend an alternative to Designer's risk assessments called "Hazard Elimination and Management List". Also provided is an example of how this should be filled in. It should also be noted that this type of information could be put on design drawings for PCs to consider.
Regards
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Posted By db
Jonathan,
The CDM regs require designers to take account of the hierarchy of control. They have never specified how to do this - one way the Acop suggested was by Design risk assessments.
The new guidance suggests they could do it using design lists as the hazards are usually generic and can be found in numerous places including RIBA and the red/green traffic light list (and other places but its too late in the night for me to call them to mind!).
So there is no proposal to remove the need for an RA - and there couldnt be as its set down in a completely different set of regs. I know nothing about the rail industry regs you quote but the same rules would apply. Its just that the assessment of the risks have already been done in the main and they can just be cut and pasted.
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Posted By J Knight
Jonathon,
The HSE page suggests the new lists as an alternative to DRAs 'as a means of conveying information'; it makes no comment about the process which will lead to the identification and control of hazards. That process has to be RA, designers are just being urged to provide the necessary info in a snappier more accessible format,
John
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