I offer you the day-to-day "upkeep and maintenance" of roadside drainage by "gulley tanker" vehicles. I doubt anyone would consider that everyday operation in a CDM context, although a case could be made. Are you in a similar scenario? Are there any unusual risks arising and would Notification, CDM-C appointment and adoption of a PCI/CPP approach add any value or improve the management of these risks? Are you confident that "others" (i.e. members of the public) are afforded maximum protection via your control measures and adopted work methods? Where all else fails, you could ask the nice people at HSE for an opinion! 30+ days of drain clearing may be of more interest to our friends at EPA/SEPA or the National Rivers Authority!

Is this one large drainage system on a single site or a series of drains on different sites? If the former, then since "drainage works" is included in the definition of "structure" I think it might get caught by the strict definition. If the latter then I don't think the notifiable part of CDM is meant to apply to multi-site works is it? Either way it doesn't sound right calling this construction work. Ring the HSE and ask.

Sorry, actually turned the page over on my ACOP and found the definition of "structure". So it is notifiable etc. Thanks for prompting me to think though!

Williams, Definitely "construction work" in my book and has been since I was inspecting construction sites as an HSE Inspector in the 1980s. So this is maintenance of a structure. Most of the definitions of "construction work" and "structure" derive directly from the definitions of "building operation" and "work of engineering construction" (the latter definition extended by two codes of regulations) in now repealed Section 176 of the Factories Act. I would also treat the whole thing as a single project - logistically easiest project management solution and tried and tested way of dealing with similar multi-site works, e.g. local authority highways maintenance term contracts. Remember that just because the CDM regulations apply whether or not a project is notifiable doesn't mean that the project documentation needs to be complicated. Should reflect the size, complexity and risks associated with the work and in practice you need exactly the same documentation for various parties to comply with duties under the Management of Health and Safety at Work Regulations 1999 as you do under CDM 2007, noting finally...... that nowhere in CDM does it say that the Pre Construction Information, Construction Phase Plan and the Health and Safety File shall be so titled. So, PCI - Client provides information about the site and its environment (interface with higher education operations, thence site rules etc) Construction phase plan - Method statement inclusive of traffic management, site management structure and arrangements for welfare, emergencies etc H&S file - anything found in the drainage system that we didn't already have documented knowledge of and which presents future risks e.g. any step irons have rusted away, or there's a shopping trolley in the sewer that will need removal at some point. (and, yes when I did my confined spaces training, there was a shopping trolley in the artificial sewer!!) regards, Peter