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Posted By Renown II
Need some sound advice.
My company are taking down racking in our warehouse, then rebuilding it 90 degrees from its original placement.
A contractor is going to carry out the work, but state we need to apply the CDM regs. I disagree that CDM applies to racking.
Are they correct? If so, how do I apply the regs?
Kind regards
Renownii
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Posted By SJA
Yes CDM Applies, but it may not be notifiable depending on the project duration.
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Posted By Ron Hunter
It could be argued that racking is not that much different from (say) flat pack furniture.
I certainly don't think it falls within the intended meaning of "structure" within the CDM Regs.You certainly won't be presented with a H&S File from the contractor when he's finished.
Issues of temporary access (scaffold/MEWP etc) should be "covered" by Management Regs, Work at Height and PPE regs - not construction work.
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Posted By Renown II
Thanks to you both.
The meeting is this afternoon (only sprung on me this morning), so I have now something to go on.
Have looked at the regs and it is debatable, but on google, racking companies insist that CDM does apply!
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Posted By Ron Hunter
I've had a quick look at some of the "information" on some websites.
Some of the information I would have to say is at best spurious. The construction of a mezzanine I would conceed as coming within the definition of construction work, but to suggest that racking comes within the definition of a "structure" in a CDM context is, in my opinion, just plain wrong.
I notice some companies out there offer to "undertake all CDM duties on your behalf"!!!
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Posted By SJA
Ron
I have been involved in a number of Racking contracts and it is definitely under CDM, when you are talking about the erection of load bearing racking structures that can be 20m+ in height, it is a little different to your IKEA wardrobes.
Renownii, your racking contractor is correct I would strongly recommend that you listen to the advice that they are providing you with, they (as I am) are advising you from a position of experience and first hand knowledge as opposed to personnel opinion.
SJA
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Posted By Ron Hunter
SJA - you're not telling us WHY you are of that opinion.
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Posted By SJA
Ron because of past experience and discussions I have had with HSE inspectors where I have been involved in the removal and re-erection of such racking systems and because of the content of the ACOP.
You have indicated that you "don't think it falls within the intended meaning of "structure" within the CDM Regs".
I would strongly disagree with this, lets not forget that in the ACOP the term "Structure" categorically include: Mast; Pylon; Pipe; River; Cable; Tower; Fixed Plant; Formwork; Scaffold; Falsework; or anything similar to these...
Also "Construction Work" includes: Fitting Out (including the fitting out of a warehouse!); and the Assembly on Site of Prefabricated Elements.... etc.
It is very clear to me.
With regards to the presentation of Health and Safety File at the end of the project, you might just be surprised! All racking needs regular inspection and maintenance, the same as with any other building or structure, it is not a case or erect and forget.
As for your comment regarding the use of scaffolding to provide access, this clearly illustrates a lack of knowledge in the required work process. But there again if scaffolding was required, hey presto, CDM would apply, though as stated in my original posting, it would not necessarily be notifiable.
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Posted By Ron Hunter
SJA let me make clear that I mean no disrespect to the racking industry here.
In your last post you are somewhat 'free and easy' with the wording contained within the Regs for the definition of "structure" - it's best to stick with the definition as actually stated in the CDM Regs.
Use of scaffold means ("hey presto") that the Work at Height Regulations apply (every time). CDM would only be pulled out of the hat were you actually engaged in construction work (as defined).
Yes, racking can be big, complex, has to be put together by competent people, and it needs regular inspection.
But then so does an Airbus 320.
My point being that there is sufficient regulation around this activity (HASAWA, Management Regs, WAHR)without adding any burden via CDM. I do feel there would be a wholly unncessary cost were the job to go over the 30 day CDM threshold.
What reference did the racking industry make to construction regulations prior to 1994 I wonder?
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Posted By Renown II
Hi SJA
I have now been appointed as the CDM co-ordinator and requested to prepare a health and safety plan for the racking dismantling and reconstruction.
As this is my first CDM job, and you have experience in this field, do you have an example or a template for the plan that would help me. I would like this to be right first time.
The job should take no more than 5 days with 4 men, so it is not notifiable.
(Many thanks to both you and Ron for your input, but the racking company has decided that this comes under CDM.)
Thanking you in anticipation
Renownii
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Posted By SJA
If it is lasting for 5 days with 4 men you really do not need a CDM-C, although it does come under CDM, it is not notifiable and so does not require a CDM-C or Health and Safety Plan etc.
These days CDM applies to all construction work, but not all construction work is notifiable, in this instance you just need to ensure that you have a competent contractor and obtain copies of his project specific risk assessments and method statements etc.
I hope that this helps.
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Posted By Ron Hunter
RenownII:
Irrespective of the stimulating and enjoyable debate on this post,I have to say that someone is seriously wasting time and resources in incorrectly attempting to apply CDM Notifiable criteria to this work.
All this will do is add unecessary bureaucracy and costs. It certainly won't add value!
The cynic in me says your contractor is trying to gain an extra premium out of this task by misguiding you on H&S requirements.
If you follow this through and Notify the HSE via F10 ( usually a task of the CDM-C) I would expect they might take a very dim view of this practice.
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Posted By peter gotch
Ok Ron, We agree it is not notifiable and hence does not require a CDMC.
However, it does involve Management of Health and Safety at Work Regs requirements, particularly Regs 11 and 12, thence requiring an interchange of risk information, i.e. that exported by / imported from warehouse as regards racking contractor.
What increased costs arise from describing the information as preconstruction information and construction phase plan, instead of e.g. "site hazards" and "method statement" ?
p
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Posted By Ron Hunter
In this particular instance, the Client (my assumption) happens to have an individual with the required competencies (again, my assumption) to conduct the duties of the CDM-C (leaving aside the argument as to whether that role's needed here or not).
This individual's time (and costs) are therefore going to part of the overall Project costs.
In the absence of a suitable internal resource, costs would be considerably more.
Extra bureaucracy and cost, no added value. The very thing that CDM 2007 wants to stop.
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Posted By David Brede
As a practicing CDM C, in a simple straightforward job there is no need to make a bureaucratic nightmare out of it.
As long as the points in the acop are tested and the answers given in the form of a Construction Phase Plan and a H&S file on completion - including not applicables where necessary then why not just get on with it.
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Posted By peter gotch
David, agreed entirely.
In this case, the H&S File....
Requirements for tying the structures to the building and/or each other.
Safe operating limits, mostly safe working loads, including when damaged in terms of continued operation and remedial works.
....which goes beyond the requirements of CDM into what is needed for e.g. HSWA and MHSWR, recognising that CDM is best viewed in the context of other legislative requirements.
Regards, Peter
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Posted By Pete Longworth
That David, is the point. If there is no need for notification what really separates this job from any other movement of plant and equipment around site. As long as it is properly planned (it can be called a construction phase H&S plan if that is what the client wants), with all the risks properly assessed, and all the SSWs properly developed and implemented then surely that is all that matters. As for a health and safety file, this is existing equipment that is being relocated. What information would a H&S file contain that the company does not already possess? In fact what could CDM bring to this job that all the other statutory requirements don't, other than unnecessary bureaucracy.
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Posted By David Brede
CDM is the one of the legislative frameworks that this work has to comply with.
However it is grounded in common sense so as long as you are being seen to address the issues raised by the legislation then there is no huge problem and you are delivering safety during the construction phase and through use, maintenance and demolition when the structure is taken down and replaced with new.
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Posted By Michael S Ward
Everyone seems to be looking at this purely from a CDM standpoint, but not considering it from the racking installation, dismantling requirements.
The main HSE reference for racking [installation, stability, maintenace etc] that I'm aware of is in HS(G)76 - H&S in Wholesale & Retail Warehouses, para 137 to 143. The main referances quoted in this guide, related to racking, is SEMA [Storage Equipment Manufacturers Association]publications. SEMA work very closely with the HSE in development of good practices and procedures for racking installation etc. So perhaps a call to SEMA may shed another point of view on this issue.
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Posted By David Brede
I guess the answer to the last post is in the original question?
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Posted By D3nn1s
Working in the racking industry I sort clarification from a HSE inspector who I met at the Storage Equipment Manufacturers Association (SEMA) safety conference in 2007 his view was that it was a “gray area what mattered was that site is operated safely and that the end user was passed all relevant safety information including Operation and Maintenance information. “
However racking alteration and installation are often accompanied by construction works such as the installation/alteration of lighting and sprinkler systems. When this is the case it is clear that the works would come under CDM 2007.
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Posted By Renown II
The forum has proved how valuable it is, with many different opinions and advice - is it CDM, is it not CDM. The thread could go on for ever and we can all agree to disagree at times.
I wish to thank everyone for their input and help, this topic was new to me, but certainly part of my continuous learning curve in H&S - 15 years experience, but always learning, and always listening to advice, whether from young or old practitioners!!
The job is going smoothly, not notifiable, H&S plan in place, induction training complete, risk assessments etc all done.
A very good exercise, and a very good experience
kind regards
renownii
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