CDM 2015 – Two years on
03 October 2017
The latest Construction (Design and Management) Regulations have been effective for two years but what has changed?
Over the last 25 years, the CDM regulations have played a great part in reducing Construction Fatalities from 100 in 1991-92 down to 30 in 2016-17 and a proportionate reduction in thousands of non-fatal injuries.
Previously updated in 2007, the regulations are based on an EU directive of 1992 that applies to all mobile or temporary work sites. The essence of the regulations is that around 60% of fatal and non-fatal accidents could have been avoided by better planning of a design or project.
A key desire of the HSE in the 2015 regulations was that designers considered and dealt with health and safety issues in design from the start rather than as a paperwork exercise following completion of the design.
The role of the CDM coordinator under the 2007 regulations was seen as operating in a silo and separate from the design team. By replacing that role with a principal designer (PD), integrated into the design team, more effective coordination would result.
With a disproportionate number of injuries and poor consideration of health issues on smaller sites, the 2015 regulations were configured to place greater duties on clients, designers and contractors.
Whilst the UK implementation of the 1992 EU Directive continues to be the most successful in Europe with the lowest accident rates of all countries, the extra impact of these latest changes has been mixed.
Architects and designers continue to be reluctant to take on the PD role partly because of where their interest lie, partly because of lack of knowledge of risks or legislation and partly because of the additional legal responsibility.
The great majority of this work is still carried out by the skilled specialists previously known as CDM coordinators. Typically, in a third-party position but with increased resources and embedded in the project team from the beginning, this perspective allows focus and objectivity on the health and safety aspects of projects.
Bernie Sims, MD of BSA, one of the UK’s largest independent health and safety practices and with a particular specialism in CDM says ”Many of the changes to the 2007 Regs had great intentions but the Principal Designer still has challenges ensuring that all duty holders work closely enough together. Principal Contractors in turn need to consult more closely with workers, employed and self-employed.”
“We are still finding that designers have a relatively low level of knowledge and training in CDM and run seminars to boost awareness of issues and solutions.”
As a result, the HSE’s plan of action for 2016-17 will continue into the 2017-18 period focusing on duty holders’ compliance and health issues including respirable dust and musculoskeletal risks.
The HSE’s ‘Fees for Intervention’ (FFI) strategy will continue where material breaches are discovered with a view to generate fuller compliance.
Rob Price of BSA added “Better coordination between the duty holders starts with the earliest possible appointment of the PD – it doesn’t necessarily cost anymore and it may save a lot of time and money caused by making changes or getting FFI at a later date.”