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#1 Posted : 27 March 2007 14:48:00(UTC)
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Posted By MAK Having checked the competency requirements for CDM-C in the ACOP 2007 Appendix 5, and am looking specifically for smaller projects assessment Stage 1 (see paragraph 231), I would like to know if anyone else has wondered why CMIOSH doesnt appear to be acknoweldged as part of the professionally qualified criteria examples of attainment, nor as part of the H&S in contruction field of knoweldge and experience? I find this a bit strange considering this is the only route by which a "health and safety practitioner" in the Construction industry can become chartered. Secondly, as being a "member of health and safety register administered by ICE" is given as an example of attainment, and membership of Institution of Construction Safety (formerly the institution of Planning supervisors, can anyone lead me to the ICS or tell me how you get on this H&S register of the ICE. thanks
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#2 Posted : 27 March 2007 15:20:00(UTC)
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Posted By Bob Youel I feel that this will set H&S professionals back years; a great opportunity has been missed I currently work with ICE and similar, whilst they are great people they and similar will take the big £ and kudos; as I cannot see any general clients going to other than those mentioned in the regs/ACOP
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#3 Posted : 27 March 2007 15:40:00(UTC)
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Posted By John Caboche MAK, A couple of reasons I think. 1)I would imagine that it is because IOSH weren't fully involved in the CDM consultation - the APS was and have put their oar in, and the HSC has listened. 2)CMIOSH in itself is not really a measure for construction expertise - many CMIOSH haven't been near a construction site professionally - this is despite the Construction SG being the largest specialist group if I recall correctly. I would be interested to know the amount of members of the construction SG who are CMIOSH compared to those who are TechIOSH - this is because traditionally the construction industry are cheapskates and generally don't pay for their safety practitioners to achieve a VQ4/NEBOSH Dip/whatever to achieve the academic requirements for CMIOSH status. The traditional route has been the Gen Cert followed by the Const Cert as a route into construction health and safety and you kind of stay at that level. Sweeping generalisation but I speak as I find generally having been involved in the construction industry myself now for the best part of 22 years as a site agent and project manager before getting involved in construction safety. There is going to be a shortage of high level CDMCs now the HSE have come off the fence and set criteria for competency, there aren't a lot of chartered professionals currently fulfilling the PS role and even less with the NEBOSH construction cert. John
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#4 Posted : 27 March 2007 16:21:00(UTC)
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Posted By MAK Completely agree Bob. John thanks for the update I didnt know that IOSH were not involved in the consultations wouldn’t you say though, that chartered membership of any of the other duty holder role organisations may also be considered as not quite providing a set NVQ level of H&S knowledge and risk management experience either? But while I really don’t want to restart the argument of who I feel is best placed to do the PS/CDM-C role, other than in an ideal world we (PS/CDM-C's)would all have : • design AND • construction AND • H&S consultancy experience (this would be achievable in a set degree programme of course where we could gain real-life experience on construction sites) to a set measurable standard AND • be on a lifelong CPD programme where of course our employers allowed us to attend every course/seminar and • have sufficient resource to do our normal job and • have full memberships of all relevant organisations, and • of course this would all be funded fully by our employers. I hold an NVQ level 7 in health and safety/safety risk management in line with the revised 8 Level grading system by QAA/QCA, without a NEBOSH. I earned this enduring a 3 yr programme while working as a junior PS/PS in the industry for many years so understandably I've been a bit resistant to going through a NEBOSH construction certificate. Many CMIOSH's previously posting on the IOSH forums obviously do have several years construction experience. thankfully for us who post asking for advice Fortunately I can meet the competency criteria as set, but still feel that the criteria has overlooked IOSH membership and the investment it takes to become a chartered health and safety professional, if CMIOSH were coupled with "relevant experience" etc. I see no reason for exclusion.
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#5 Posted : 27 March 2007 20:07:00(UTC)
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Posted By Bob Youel there are many CMIOSH who have no construction experience and ditto designers who have never left the drawing board to visit a site in years if ever - my in law to name but one - however designers are seen as the ones in the 'know' irrespective & best of luck to them Its up to IOSH members to push harder and sell themselves many designers that I work with are supprised when I quote that my design experience covers civil, fabrication and mechanical areas - which most of them do not - they then come round
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#6 Posted : 27 March 2007 20:23:00(UTC)
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Posted By holyterror72 Bob, You've hit the nail on the head. Its not just about H&S but also knowledge of the design process, buildability and various other site related issues. Its a mystery to me as to why individuals think that because they are CMIOSH it automatically moves them to the top of the PS/Co-Ordinator heap (as an opinion expressed in many of the other endless CDM forum threads). Its as pertinent to the hairdressing industry (for example) as it is to construction I'm afraid. That's why Tech IOSH has always been deemed 'far enough up the ladder'. It seems to be a way of thinking linked to a bit of a general misunderstanding as to what PS/Co-Ordinator's actually do (although I believe many don't think they do anything).
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#7 Posted : 28 March 2007 08:44:00(UTC)
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Posted By John Caboche Mak, to a great extent I agree with you, I'm lucky in that I tick all the boxes in Appendix 5 of the ACoP and will be able to carry on acting as a CDMC. I think that your VQ if based on a construction environment is as valid as a construction cert and if it isn't in all honesty you shouldn't have that much trouble in passing the construction cert. This is the first time HSE have come of the fence and talked about competency - in some ways I think it's a good thing, and I also think that a blanket "CMIOSH" status is no measure or guarantee of competency in a specialist field - unless you can demonstrate experience in that specialist field along with academic qualifications you aren't really competent. As I have said previously there are a lot of CMIOSH out there who don't know about construction as a specialist field, and as I have intimated earlier you may be better off with a TechIOSH with a construction cert as being able to demonstrate more direct experience of construction. The big issue I think as far as the HSE view is control of what goes on on site as much as in the design office, I believe that the devil is in the detail, especially reg 9(2) which intimates that the client should make arrangements (Somehow...)to monitor arrangements and make sure they are maintained throughout the project and will rely on the CDMC - hence the need for a valid construction safety qualification as well as construction knowledge in the competency section. That's just my take reading between the lines - and I know there are a lot of designers who have never been out on site - I work with a few of them!! I also know quite a few CMIOSH who haven't been on a construction site. That's why I think the Construction Cert is mentioned, - it's a lot easier for a chartered professional acting as a PS to attain that than it is for a person holding the Construction Cert to become a chartered building professional and subsequently take up the CDMC mantle. In terms of carrying the construction safety torch I think the APS have stolen a march on IOSH by being involved at the very earliest stage of the CDM consultation, I believe that IOSH as an organisation weren't that heavily involved, if at all - although I stand to be corrected and subsequently I think HSE place more credence upon them than IOSH, John
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#8 Posted : 28 March 2007 08:56:00(UTC)
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Posted By Robert K Lewis The real problem with this appendix for me is that it is very bit and peace without a clear pathway to demonstrating competence. It also mixes corporate and individual competence in a rather strange fashion. What is even worse is that the possession of HSE or other guidance seems to be a recognised piece of evidence of "competence" for some items - see the first entry on Policy Statement as a prime example. The real boat for improving competency assessment has in my view been missed at both individual and corporate level. It is one of the reasons why the Midland Branch conference on May 8th at the National Motorcycle Museum has majored on this item with 2 workshops and 2 presentations approaching it from very different positions. There are still places left and I hope to meet many of you in my corporate competency workshop. Bob
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#9 Posted : 28 March 2007 09:07:00(UTC)
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Posted By MAK Thanks to all of you have posted. As you have all said there is no easy answer and being able to tick the boxes is no absolute guarantee that any CDM-C is entirely competent for a given type of project. I still think the criteria needs to be exanded to fit all the other types of specialist background experience and alternative pathways out there i.e like Bob mentions above for example Robert, As usual you look at the issue from a wider perspective. thanks for your input. Still hope to meet up with you at the workshop but as John states above, there remains the negative impact from employer non-investment in H&S training in the construction indsutry thanks again all.
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#10 Posted : 28 March 2007 12:13:00(UTC)
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Posted By Ciaran McAleenan Dear All The ACoP for CDM94 stated that the planning supervisor needs 1. A sound working knowledge of health and safety in construction work; 2. A thorough knowledge of the design process; and 3. Experience of the site processes likely to be involved in the project and in future maintenance, refurbishment or demolition.” The requirements on CDM coordinator competence indicated in Appendix 5 of CDM2007 ACoP are not dissimilar. Column four (referred to as column 3) in the table provided only contains examples. Do not get hung up on examples. Read the opening paragraphs to Appendix 5 before running off and trying to join all the example organisations and taking all the example tests/ exams. If you aspire to fulfilling the CDM coordinator function determine how your skills, knowledge, experience and resources (individual or corporately) will assure the clients of your competence. Best wishes Ciaran
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#11 Posted : 28 March 2007 14:14:00(UTC)
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Posted By Alexander Falconer MAK Just a little pointer, when you specify your NVQ status, ensure that you do not get confused with the QCA/SQC framework levels. There is no NVQ (or even SVQ) level 7 in existence at all Highest is a level 5 (which falls between level 7 and 8 of the QCA framework, and level 11 of the Scottish Qualification framework) The systems in existence are confusing enough!
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#12 Posted : 28 March 2007 16:00:00(UTC)
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Posted By MAK alexander, thanks for making me go back along a line of enquiry that I made august last year as I may need to refer to this in future Please see the extract below and note perhaps I should have added the word "equivalent" to my post. -----Original Message----- > From: Mak > To: d.bottomley@qaa.ac.uk; a.runcie@qaa.ac.uk > CC: GeorgeWilson@aol.com; c.thorne@strath.ac.uk > Sent: Tue, 1 Aug 2006 9.55AM > Subject: Query re NVQ level grading of MSc programme under new QAA 9 level system > > > Dear David/Alan, > > Further to the regrading of the new NEBOSH Diploma from NVQ level 4 to NVQ level 6 under the new system, I have made some preliminary enquiries to my Course Provider SCOSH at the University of Strathclyde as to the equivalent change in NVQ level grading in relation to a Masters degree programme in Safety and Risk Management. > > From a telephone conversation this morning to QCA who referred me to you, it appears that the new system has upgraded the following: > Postgraduate Certificate Safety and Risk Management > Postgraduate Diploma Safety and Risk Management > Masters Degree Safety and Risk Managment > > All now to a level 7 NVQ equivalent, from a previous NVQ level 5. you can verify this national standard and "equivalency" table at http://www.qca.org.uk/493_15772.html. I trust this doesnt offend. M
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#13 Posted : 28 March 2007 16:42:00(UTC)
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Posted By Alexander Falconer MAK I never doubted your credentials at all, I understood exactly what you were meaning in your original thread. However what you have to bear in mind, is that NVQ's and SVQ's are still offered at level 2 (aimed at operators) through to level 5 (senior managment/directors) and are still named as such. I agree that the QCA lists an NVQ 5 as a Level 7 under the QCA guidelines, in addition under SQCF guidelines it is also listed as a Level 11, both which are comparable to the academic equivalent of a Masters Degree. See also http://www.scqf.org.uk/table.htm Personally, I do not see the need for two sets of qualification frameworks. We safety practitioners come under the same banner of UK legislation, so why not qualification levels? Just as a pointer of how confusing things can become. I am currently studying for the NEBOSH Diploma part 2, which according to the QCA (and the course provider) is of similar standing to an NVQ 4, the Level 6 diploma and ordinary/honours degrees all of which are deemed acceptable for Grad MIOSH and eventually CMIOSH. On the other hand, the SQCF lists HNC's as level 7, HND's/Diplomas and SVQ 4 as level 8, ordinary degrees as level 9, and honours degrees at level 10 No wonder there is so much confusion!
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#14 Posted : 28 March 2007 17:15:00(UTC)
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Posted By MAK Do what I did, pick one standard or equivalent your happy with if you need to and stick with that one. Essentially its only the people undertaking these courses who care about the level it achieves. In real-life H&S its what we know, not what level youre graded at (as the guys posting above advise) by any one organisation. You may find that you will rarely find an employer that knows as much about NVQ's or SVQ's and levels that you apparently do, neither will most care unless its to prove on paper that you should technically be competent in this respect only according to the paper your qualifications are written on. Good luck on your course M
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#15 Posted : 29 March 2007 12:30:00(UTC)
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Posted By noiseman The incompetence of IOSH not to even have their organisation listed as potentially suitable in the CDM 2007 ACOP beggars belief. This will cost their members a fortune in lost contracts and force them to join groups such as the APS.
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#16 Posted : 29 March 2007 13:23:00(UTC)
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Posted By Robert K Lewis Noiseman Be very careful with the use of the term incompetence - it is a very difficult concept to prove. Wrongful acts by competent persons/organisations means that they may well be negligent but not necessarily incompetent. It will be one of the issues that will have to be addressed under regulation 4 assessments. If a contractor has a couple of notices against their name are they incompetent? Or more pertinently are they still competent. You can argue this out both ways. It is one of the reasons that I personally feel uncomfortable with both appendix 5 and the tables on pages 52 & 53 of the acop. Simple documentary proof is being used to measure something that is much more complex than is being admitted. We are probably will have to wait for case law to clarify the situation but perhaps the HSE will shy away from using reg. 4 because it will be exceedingly difficult to prove a party is incompetent. Bob
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#17 Posted : 30 March 2007 08:18:00(UTC)
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Posted By ddraigice Rob, I think you've missed the point. The competence issue in the regs and ACOP is not to allow HSE to prosecute for incompetence. There is no need to do that as there are so many regulations that someone can be prosecuted over for failing to do something -irrespective of whether the word "competence" comes up in the investigation or court room. There are a few other issues within CDM 07 that are almost impossible to enforce on. The whole purpose of the ACOP and regs is to be a step by step guide for every one in the process to follow to ensure the projects are planned and controlled from the start. As for whether IOSH missed a trick - I wouldnt be too worried. If you can prove your competence then fine - and maybe you'll need to be a member of another organisation to prove that, maybe not. But what this does do is exclude people without the knowledge, experience and will to do the job properly and not just sit back and watch the money roll in. Unfortunately, when I was in the construction division in HSE there wer far too many of these people about who just did not have a clue. Even as far back as a few months ago I met a PS who, when I asked him about why there was no PC on the job he replied, "Well, its an option but surely no-one really uses a PC for CDM...." And guess what... he was a member of the exact same body everyone is moaning about. I could go on about the IOSH registered H&S consultants who I found actually walking on fragile asbestos cement roofs with fragile roof lights in them alongside the client or doing other stupid and dangerous acts but I think you get the picture.
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#18 Posted : 30 March 2007 08:53:00(UTC)
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Posted By CFT Scenario. CDMC appointment for 20 million pound commercial project. Client is experienced in past projects. CDMC is previous PS with MRICS and 10 years experience in similar sized projects. No detailed H&S academic qualifications, MAPS, but nowt else. Potential CDMC seems to understand the requirements of CDM 2007 but has concerns regarding appendix 5 ('Guidance for assessing competence of a CDM co-ordinator for a larger or more complex project, or one with high or unusual risks')states it is nothing more than a guide whereas I see it as quasi legal prescriptive guidance within a descriptive set of regulations. Would they get past you for further consideration? Just curious. CFT
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#19 Posted : 30 March 2007 09:16:00(UTC)
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Posted By Robert K Lewis ddraigice I was reacting to the mention of the " incompetence of IOSH" and was trying to highlight the fact that a failure to act in the manner one expects of a competent person/organisation to act is more likely to be seen by the courts as negligent rather than incompetence. The reason the HSE will probably not use the regulation is this very factor. However I still think they could potentially find mechanisms to make this regulation have more bite to it. After all if a client is unable to demonstrate how he has assessed competence should there not be a simple regulatory breach. The lack of formalised system to do this could be all that is required after all. I would similarly argue that PCs in particular should be evidencing clear systems for managing their contractors' competence. No clear system should set the alarm bells ringing. Ultimately back to the original thread, the guidance I think is poor in this area and will need further work at some point. Bob
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#20 Posted : 30 March 2007 15:19:00(UTC)
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Posted By noiseman Bob I actually do carefully read posts before I reply. Why is IOSH is not mentioned as a "potentially" competent body in the ACOP. That will cost most of us at least an extra Membership fee ie with the APS and probably a great deal more in terms of lost contracts. The Friday Rant only quelled by chilled Chablis or a John Bull and Vodka.
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#21 Posted : 30 March 2007 16:43:00(UTC)
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Posted By Robert K Lewis Noiseman I think the failing to get IOSH mentioned in the acop signifies a deep problem we have somewhere. The construction SG input by John Lacey was seemingly totally ignored because of contrary stronger political pressures from other places. Council too failed to grasp the fact that construction and the impending changes were more than a minority issue for practitioners and a technical lead was not given by IOSH on matters of competence and competence assessment. This does not make IOSH incompetent though. I may have other private descriptions but this is certainly not one I would use. Professional Affairs has stood head and shoulders above the other directorates at Wigston and I wish the others were as effective. It is an area where Lisa, and the President elect will need to focus on in order to force a positive change by the end of this year. Bob
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#22 Posted : 30 March 2007 17:00:00(UTC)
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Posted By John Caboche I would say that IOSH is not mentioned as a "competent body" is because in the specialist field of CDM and construction it isn't. IOSH is too broad a church - Construction SG aside there is not the competence in the organisation to deal with construction issues. As has been pointed out above a CMIOSH member could deal with nothing more than hairdressing salons and the issues therein - it doesn't make them competent in construction. If you have experience in this field and feel left out - join the APS, or the ICE or the CIOB. None of these organisations are ideal in terms of demonstrating competence per se, but they add credibility in a way IOSH doesn't in this very specialist field.
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#23 Posted : 30 March 2007 17:57:00(UTC)
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Posted By holyterror72 John, Agreed. IOSH is a good extra string to the bow' as would be MIIRSM wouldnt it as they should be considered equal to IOSH in this debate shouldnt they?
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#24 Posted : 30 March 2007 18:18:00(UTC)
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Posted By John Caboche HT, I think that the same analagy applies to the IIRSM - too broad a church in reality, but a good string to the bow - very apt analagy.
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#25 Posted : 30 March 2007 18:46:00(UTC)
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Posted By CFT John I note that the IIRSM do not even have any 2007 news available on the website, so one must assume that their interest in CDM 2007 is possibly vague at best. With respect CFT
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#26 Posted : 30 March 2007 20:18:00(UTC)
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Posted By Advanced Safety Hi all After reading this thread i feel dissapointed that some people feel they have to join APS to prove competency. I am sure that a court of law will not consider an open book exam as sufficient evidence of construction/CDM competence. However, i am not a judge!
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#27 Posted : 31 March 2007 00:28:00(UTC)
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Posted By peter gotch 1 Hi All Some of the responses above appear to have fallen into the trap that some of our clients have also fallen into. ....which demonstrates the problems of apparently prescriptive guidelines. The relevent chapter of the new ACOP quite clearly indicates an expectation that for most projects the role of CDM Co-Ordinator will need input from more than one discipline. This is no different from the guidance in the 2001 ACOP/Guidance that supported CDM1994 from Feb 2002. The problem is that clients will be liable to read the content of the table in Appendix 5 of the new ACOP out of context with either its introductory text or the relevant chapter. At this point in time, the person in my organisation, who is charged with identifying a list of persons who will manage our CDM-C activities, is NOT pressing me to apply for membership for APS [which I had till I stopped paying my subs about 8 years ago] He thinks my CFIOSH + 19 years exposure to the construction industy + a variety of other experiences means that I get through his competence hoops. Regards, P
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