Firesafety, perhaps you could clarify?
Leaving aside the role of the Principal Contractor in dealings with e.g. Client, Principal Designer and Designers……..
Reading both your postings from 3 November on this thread I think that you work for more than one shopfitting contractor, who in each case takes on the role of Principal Contractor on their projects.
In each case, you neither write the RAMS for external sub-contractors, nor review what such subbies produce.
So, does somebody else within the Principal Contractor review their subbies’ risk assessment documentation? If not, how might the PC comply with all the elements of their duties under health and safety legislation including e.g. CDM Regulation 13, including 13(3)
(3) The principal contractor must—
(a) organise cooperation between contractors (including successive contractors on the same construction site):
(b) coordinate implementation by the contractors of applicable legal requirements for health and safety; and
(c) ensure that employers and, if necessary for the protection of workers, self-employed persons—
(i) apply the general principles of prevention in a consistent manner, and in particular when complying with the provisions of Part 4;
(ii) where required, follow the construction phase plan
In contrast you do write the Principal Contractor’s RAMS but the PC employs the joiners and electrical people, but you don’t do the RAMS for the sparkies as you were advised against doing so by an HSE Inspector, so in practice, you are effectively only doing the RAMS for the joiners, though I guess probably also for e.g. site establishment?
So, who writes the RAMS for the electricians and who reviews these?
You broadened the scope of this thread to introduce the subject of unannounced inspections.
Are you really sure that your inspections are entirely unannounced. Surely you sign it at each site and wait for e.g. a Site Agent to turn up before touring the site? – by which the bells are sounding that the Safety Man is on site and things might get quickly changed to look better.
….and are you the trusted adviser or the policeman who can easily get the Site Agent the sack if the score for your inspection doesn’t meet some target?
“Many years ago I introduced league tables for the site manager/foremen to compete. Any low scorers were hauled into the MD's office and bollocked, some repeat offenders were fired on the spot. “
After that the scores went up. Of course, they did!! My guess is that the Site Agents and such like started to demand evidence to justify most of any points deducted.
Let’s face it. You have given these Site Agents cause to worry about their future employment, so it is in their interests (and those of the workers) to put in place processes to slow down your ability to do “unannounced” inspections.
….and I would be interested to hear how you have managed to come up with a scoring system that is sufficiently balanced to enable the score to be representative of all aspects of sites where the works may vary substantially.
Suppose we omit some of the things that could be expected on some inspection form e.g. evidence of project notification and a Construction Phase Health and Safety Plan and stick to the nuts and bolts, can you be sure that a score of 95% might not mask one or two issues which could easily be lethal?
I don’t know how many issues you consider but let’s propose 20 issues each scored from Zero to 5, such that the maximum score would be 200, and 95% is reached at 190 out of 200.
Those 10 lost points (or more if you are having a bad day) could be down to a subbie worker standing on a defective stepladder or one of your sparkies doing “live work” without justification. Either or both giving an HSE Inspector the justification to serve a Prohibition Notice or instigate prosecution!
Let’s imagine what these 20 issues might be…..
- From your forum name, I assume that Fire would be right up there, possibly with more than one rating.
- …and I assume that you will check the Welfare.
- You are working at shops, so even when closed, right beside the public, so something like “Site Security” has to be in there.
- You have subbies, so the interface with them has to be another.
- There will be alterations to Services on some projects.
- Sometimes, the work will involve moving walls around, where some may be load bearing, others not, so may be an item for Structural Safety or Temporary Works>
- You need stuff delivered and removed, so an item for transport, possibly considering offsite logistics – the big killer at the London Olympics.
- You have to Store materials for the works.
- ….and deal with the Waste
- …..which means Manual Handling and
- Lifting equipment
- ….and they have to move things around which means Slips and Trips
- ….and climbing up stairs and ladders etc, so Work at Height, possibly with multiple scores.
- The joiners use power saws, the sparkies use drills, and others use Machinery, so an item for PUWER
- …and one for Electricity
- …and the equipment is noisy, so one for Noise
- …and it Vibrates
- There may or may not be ACMs so an item for the A word.
- But that’s not the only material you need to worry about, so an item for COSHH
- …and another for DSEAR to take account of the flammable or explosible materials.
Now, I am going to suggest that these 20 may not be anything like of equal weighting, but how far from being of equal relevance could vary substantially depending on the nature of the works.
As example, it is often said that the single greatest cause of premature occupational deaths is falls from height but that is only because many work-related fatal accidents involving road and other transportation are outside the scope of RIDDOR and hence rarely counted, but also as the far greater number of deaths from occupational disease happen years after your inspection and hence also likely to be outside the numbers games your clients may be playing.
So, should you increase the number of items for COSHH and reduce the number for Work at Height?
…and when the worker sues your client for beat knee as they are a joiner spending much of the day kneeling down to fix the new skirtings to the walls has your inspection form failed?
Edited by user 06 November 2023 17:17:19(UTC)
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