Building’s inaugural webinar on the CDM regulations raised all manner of questions, not all of which were dealt with at the time. Here, Peter Caplehorn of Scott Brownrigg tackles some more
The online seminar about the CDM regulations on 24 May was Building’s first foray into the world of interactive live seminars. Judging by the fantastic response, we are sure to be hosting many more. An audience of more than 380 gathered around their computers to listen to three leading health and safety experts discuss the latest regulation changes.
As well as being able to watch live presentations, viewers could also pose questions to panel members during their talks. Sixty questions were sent it, some of which were addressed during the 15-minute question and answer session at the end of the seminar. The questions we did not have time to address have been answered by Peter Caplehorn, one of the speakers at the webinar. As technical director at architect Scott Brownrigg, with responsibility for health and safety, Peter has intimate knowledge of CDM 2007.
What makes a project notifiable?
All but domestic work is subject to CDM; 500 working hours or 30 days is the threshold above which you must notify.
Is the appointment of the CDM co-ordinator essential before the planning application?
In the 1994 CDM regs, the designer advised the client of its duties. Why not allow it to still do so, with elaboration done by the CDM co-ordinator? Otherwise, how does the appointed designer advise the client?
That is still the case – in fact it is a duty.
Would you expand on the notion of taking CDM on board in competition design, bearing in mind that entries often bank on the use of untested methods and technologies?
CDM analysis should start before the initial design. This applies to competition entries because they could be built, but that should not limit design. New and innovative designs must identify the hazards they generate and the designer should be able to explain how they can be addressed safely.
Surely a designer should also consider management, manual handling and display screen equipment regs?
Agreed. All the relevant regulations should be taken into account. The welfare regulations are now part of the CDM regs and are therefore worth noting.
How do designers ensure preparatory safety works, for example scaffolding and temporary welfare facilities, are carried out properly?
Designers only have to point out that welfare should be provided. They should not get involved with scaffold design. Other specialists should undertake the design.
We supply and install shop fronts. Sometimes they come in one piece and, as they can be heavy, they give rise to hazards. Under CDM who is liable – us or the architect that insists on a certain design?
The designer or architect should insure “hazards” are either designed out or identified, so if there is one heavy component it should be flagged up and explained as a hazard. You, as the competent specialist, should then be able to allow safe methods of installation.
We are a specialist subcontractor designing, making and installing products. How does CDM influence us? And what duties do we have?
You should read the industry guide on designers, contractors and workers.
Some designers still call the summary of their CDM reg 11 actions the “design risk assessment” while some call it a “register”. The content is fairly similar, so what’s in a name?
The name is not really the important issue. The main points are that you consider issues, record notes on your actions and have a method to publish hazards others needs to be aware of. I prefer the name hazard register.
Is the Diohas (Designer’s Initiative on Health And Safety ) website up and running yet?
Not yet, but hopefully will be by the autumn. In the meantime, many of the guidance points I have spoken about are included in the RIBA health and safety Charter practice template.
What about repairs?
The regs appear to require the application of CDM principles to repair and maintenance, although these aren’t notifiable. Is this correct?
These need to be considered by the originating designer and include demolition at the end of a building’s life. If it is standalone work, rules on scope and notification apply.
I have heard a lot about design for construction issues but nothing about continuing maintenance. How do you see the new regs improving the safety of maintaining new buildings or refurbishments?
Access cleaning and maintenance are as important. Architects must consider how buildings are accessed and materials. See industry guides and the Coniac (Construction Industry Advisory Committee) guide at www.constructionskills.net
Work in progress …
What is the position if a client buys into a project already in progress?
The client and design teams should be given the CDM analysis produced so far and must be happy with the content before they take the scheme forward.
What happens on projects that were in progress on 6 April when CDM 2007 was introduced? What is the timeframe and the requirements for transferring from the old regs to the new ones, bearing in mind the roles are subtly different and need to be realigned?
Contractors and CDM co-ordinators are expected to behave in accordance with the new role, but the regs changed overnight, so in practice everyone is still learning the ropes, However, by now they should have fully embraced the new roles and requirements.
The perils of paperwork
What paperwork do designers need to produce to show they have complied with the regs?
Designers need confirmation that they have informed the client of its duties, confirmation of risk analysis throughout the design process (drawings and notes) and a hazard register to pass on before starting on site.
What format should pre-construction information take?
It should be easy to read with clear simple documents. Designers should provide drawings with mark-ups.
We have a problem of paper overload, with stuff being included just in case. Is it possible to penalise unnecessary paper?
People are automatically penalised by being inefficient and taking their eye off the ball.
Are designers’ risk assessments still required?
No. A summation of the hazards, particularly a drawn one, is best. Certainly no huge pre-formatted tabularised documents.
You can still watch the CDM webinar at www.building.co.uk/cdmwebinar. And look out for editorial webinars on the planning white paper and the Code for Sustainable Homes in the near future