The strict legal requirement is only "a health and safety file appropriate to the characteristics of the project which must contain information relating to the project which is likely to be needed during any subsequent project to ensure the health and safety of any person. " so if you satisfy that, probably.

The CITB guidance https://www.citb.co.uk/about-citb/partnerships-and-initiatives/construction-design-and-management-regulations-2015/cdm-regulations/ says more (look e.g. at Annex D of the Principal Contractor document).  It is plausible that the manual you are preparing meets the requirements (but I can't say for certain without full knowledge of your works and your manual).

Edited by user 26 April 2024 12:25:53(UTC)  | Reason: got my CIC confused with my CITB

Hi Stockley

You flag up one of the various weaknesses in how the CDM Regulations have been drafted.

"health and safety file" is a defined term in CDM 2015 Reg 2 by cross-reference to Reg 12(5) which assumes the need for a "principal designer" who might not be needed on some of your minor projects.

However, even if there is no requirement for a PD, the Client still has a duty to provide pre construction information including anything relevant from an existing HSF and when the next project comes around if that HSF has not been updated then they will potentially have a problem because the existing HSF may no longer be fit for purpose.

So, in a reasonably perfect world the HSF (or HSFs) should be a living document in which the history of each "structure" and its risks going forward can be tracked, with some hazards being designed OUT and others coming IN. 

All too often what happens is that instead of this approach the duty holders come up with a new set of information relating to each individual project and before long it may become very difficult to see whether the elephant that was originally constructed now looks like a giraffe.

As to the title, nowhere does CDM say that "the health and safety file" must be called "the health and safety file". If the information required by CDM is easily found in one or more O&Ms so be it. 

Firesafety

I think you are reading the legislation much too simplistically and failing to notice the flexibility on offer.

I don't think HSE would approve.

Have you consulted the oracle?

Not much has changed in three iterations of CDM in terms of the content of the "health and safety file".

HSE was represented on the Steering Group and Expert Panel for CIRIA's 1998 publication "CDM Regulations - "Practical guidance for clients....." (Report 172).

Page 67....

"Most clients will have received as-built drawings and building services "operation and maintenance" manuals in the past; the file should be seen as a logical extension of this service, not a separate exercise".

More recently in L144 the Approved Code of Practice that supported CDM 2007:

"258 The scope, structure and format for the file should be agreed between the client and CDM co-ordinator at the start of a project. There can be a separate file for each structure, one for an entire project or site, or one for a group of related structures. The file may be combined with the Building Regulations Log Book, or a maintenance manual providing that this does not result in the health and safety information being lost or buried. What matters is that people can find the information they need easily and that any differences between similar structures are clearly shown."

[My bold in highlighted text from each quote]

So, the oracle says that there does NOT have to be some document that could easily be HUGE called "health and safety file".

Any more than the law says that your COSHH assessment and Manual Handling assessment must be in documents with such titles instead of being integrated into a broader explanation of how the risks of a task have been assessed and an appropriate set of mitigations determined.

Firesafety, back in the distant past in the last Century when R172 was published, the authors of the CIRIA report also commented:

"For some projects, ........electronic media maybe the way to hold, amend and access the data."

We are in 2024.

Would you actually be confident that the sole hard copy of the "Maintenance Manual" is up to date whether or not it is on the shelf when someone needs those bits that are required for the CDM "health and safety file"?

When we bought our flat it came complete with a red A4 book with useful information about e.g. where in the roofspace to shut down parts of the cold water supply. However, we are a domestic client who doesn't need to have accurate up-to-date information.

In contrast, any typical "non-domestic" client has various people coming in at regular intervals to look at this, that and the other. 

Surely you would expect your clients to provide their supply chain (both inhouse and external) with information in electronic format?

Hence, if the maintenance engineer takes away a hard copy print out of the "Maintenance Manual" that is NOT the only copy.

The typical problem that happens time after time is that clients fail to keep the HSF and associated information in a format that can be readily updated, often as everything is pdf'd to save on storage space, as but one reason.

So, what often happens is that someone comes in to do a minor change of the type envisaged in this thread.

Because the supplier doesn't have the expensive software to allow them to amend pdfs, a new set of documentation is produced and added to the stockpile of data. 

Four or five minor changes later, and what was originally an elephant now looks like a giraffe, except that UNLESS the next supplier can see ALL the documents relating to what they are working on, and interpret ALL the changes that have happened then what they may see STILL looks like an elephant.

So back to the guidance in R172:

"Particular care will be needed to avoid a situation where a copy of the health and safety file becomes out-of-date but is still available for reference."

Just like that hard copy that the maintenance engineer has taken off the shelf?

Edited by user 29 April 2024 14:43:09(UTC)  | Reason: Typo

Not the kind of "information" we need Cole33 - REPORTED