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When does a construction site become a factory?
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Posted By Mark Damrel The Principal Contractor is constructing a large factory and installing plant and equipment (robots, conveyors etc.) . Commissioning falls under CDM but when is commissioning complete? We have considered that machine guarding testing, slow running at 10% speed and low voltage testing is commissiioning. A section of the factory is then fenced and handed over to the client. That section ceases at this stage to become a construction site under CDM. The client then teaches the robots and carries out trial manufacturing runs. Any work carried out by the Principal Contractor after handover of a section is carried out under the clients permit to work system. Have we got it right?
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Posted By Ken Taylor On the face of it, I think you have got it right - although there seems little relevance these days, in terms of health and safety, as to whether something is called a factory. The place remains a workplace throughout and the change is in who is in control and whether the CDM Regulations and other Construction regulations are applicable. Partial hand-overs can bring problems - but you have obviously considered it desirable in this case and are exchanging paperwork, signatures, sorting out insurance cover, risk assessments, etc.
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Posted By Mark Damrel Ken thank you for your response. The matter of which sets of regulations apply and which enforcing authority is in control concerns us. It is also we think critical that we have a clear line of authority in both the construction site situation and the factory site situation. The competence for running the construction site we think is with the principal contractor. The competence for running machinery in trial runs and production lies with the manufacturing client.
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Posted By Ken Taylor Your questions have highlighted an important point. It is important to know who, where and when someone is in control of the workplace. The duties that arise from site control under CDM will be with the Principal Contractor and he/she will need to ensure that competent persons are working in the area of control under the established site rules, etc. This underlines the need for all changes of control to be agreed and documented to the parties concerned and areas of control clearly defined.
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When does a construction site become a factory?
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