CDM 2015 – New Guidance

Industry guidelines have now been published for the new CDM 2015 regulations, which came into force on April 6th. Please see the documents below for you to download which have been published by the CITB and HSE. There is also a short video guide for you to view.

If you would like to learn more about CDM 2015 and the impact which the new regulations will have on your construction business, then you may wish to consider attending one of our CDM training courses or enquiring about BSG’s CDM consultancy services. For more details about our CDM 2015 training courses, please click here: BSG CDM Training

CDM 2015 Industry Guidelines
 Clients
Principal Designers
Designers
Principal Contractors
Contractors
Workers
HSE
CDM 2015 Video GUIDE

 

 

Summary of main changes

A summary of the main changes which relate to CDM 2015 are listed below. For a detailed analysis of how CDM 2015 will affect your construction business, please contact us at enquiries@bsgltd.co.uk  and we will arrange for a BSG representative to speak with you about the specialist CDM consultancy services that BSG can provide.

Principal Designer

One area of particular concern is the new Principal Designer (PD) role which will replace the existing CDM Coordinator position. The PD is expected to be a client appointment from within the design team, for example the Architect, Structural Engineer or Services Engineer.

The PD will be responsible for:

• Eliminating or controlling risk throughout the design phase
• Ensuring that the Principal Contractor (PC) is kept updated
• Ensuring that a Construction Phase Plan (CPP) is prepared
• Assisting the client with the preparation of the CPP
• Make certain that designers comply with their duties
• Preparing the Health and Safety file

How the PD is expected to carry out these additional duties remains unclear. Training existing design staff is one option although many expect the PD role will be sub-contracted out to a specialist. What is clear to BSG is that PDs will need a support mechanism to meet their obligations when the changes are enforced, which is one of the reasons why we are working with a number of our members by acting as their Principal Design Consultant (PDC) to help PDs fulfil their duties and comply with the new legislation.

Removal of the domestic client exemption

Domestic clients have no responsibilities currently under CDM 2007. The HSE is proposing to remove the exemption as it breaks the EU Directive. This has led to concerns over small contractors, who only carry domestic works, being subject to new complex regulations which they will have to get to grips with in a short space of time.

Recognising that this change needs to be proportionate, the HSE has recommended that duties placed on domestic clients are taken on by the contractor (or Principal Contractor).

Replacement of the Approved Code of Practice (ACOP)

Following the consultation which took place on August 13th, the HSE is planning a partial reversal of its plan to abandon the Approved Code of Practice when it implements the CDM Regulations 2015, and now intends to publish a slimline version to accompany the new regs at a later date.

The HSE had planned to remove the ACOP, which gives practical advice on implementing CDM 2007, in favour of industry-written guidance. This plan was included in the consultation documents published on 1 April. But an HSE board paper addressing the outcomes of that consultation, makes it clear that the HSE is now proposing to produce a short “signposting” version of the ACOP.

The switch seems to be partly in response to support for the ACOP in the consultation, and partly out of acknowledgment of industry fears that the interlinked pieces of guidance might not be written in time.

Structural simplification of the Regulations

The HSE proposes to simplify the structure of the Regulations to make them clearer and easier to understand. This is largely aimed at small to medium projects which tend to use SME companies. It is claimed that SME companies generally find the current Regulations difficult to understand and follow.

Raising the threshold for notification of projects.

The requirement to notify the HSE about projects expected to last more than 30 days or involve more than 500 person-days of labour will be replaced by a requirement to notify projects involving “more than 30 working days and more than 20 workers simultaneously”. However this will not be the trigger for the appointment of a PC or PD which has been the case to date. Instead, a project with more than one contractor will initiate the allocation of a PC or PD.

Managing the Transition

Many of you will be pleased to hear that the HSE will allow for a crossover’ period of six months for projects under construction when the revised Regulations come into effect. For a substantial majority of projects it will subsequently be possible to continue with a CDM co-ordinator until their co-ordination function is no longer required, subject to a six month limit. This will significantly reduce transitional costs for these projects.

 

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