Hi David
This has possibly got worse with the changes from CDM 2007 to CDM 2015 and the reduced guidance, with implications that are likely to affect not only members of the construction supply chain, but also assessments in other sectors.
The Approved Code of Practice and Guidance (L144) that supported CDM 2007 did send clear signals as to the level of bureaucracy that might be appropriate when doing supply chain assessments and that did seem to reduce the amount of so called "Blue Tape".
But HSE panicked and replaced the word "competetent" in CDM 2007 with "skills, knowlege and experience" in CDM 2015 and with very little guidance in L153 on how to approach assessing what "SKE" means there appears to have been a return to much more bureaucracy.
I attended a webinar a few months ago, where the speaker was wanting not only accident statistics but also data on HSE enforcement action, but with no attempt to explain how to distinguish between potential suppliers based on what information they provide.
With reduced resources in HSE, for a contractor getting an enforcement notice or being prosecuted is to a great extent a matter of luck rather than judgement. Even more so higher up the supply chain - the Designers and Principal Designers where enforcement has been extremely rare and almost invariably targeted at the micro businesses who can't afford expensive lawyers to resist.
...and, of course, all that a supply chain member needs to do is to change their name and any enforcment action is, in effect, purged from their record.
When I did 4 years in Construction as an HSE Inspector, one well known housebuilder NEVER had a previous conviction when a prosecution report was written - for the simple reason that every single site was run by a company with a slightly different name.
So XYZ Homes (Glasgow) Ltd might have been prosecuted previously but this counted for nothing if the next prosecution was against XYZ Homes (Edinburgh) Ltd.
...and, in practice, such contractors also had very low numbers of accidents (even when they bothered to count them, let alone report those which were reportable) as almost all the higher risk processes were done by subbies. So, if the only people you employ on a site with say 50 workers are a Site Agent and perhaps a couple of General Foremen (no women in those days), very unlikely that one of the direct employees was going to get injured.
Now the assessor may think they can get round that one by asking for accident rates rather than numbers but if the assessor then benchmarks against industry performance they would be comparing apples and pears as the numbers provided are for a very low risk part of a higher risk average.