Radically amended, CDM 2015 comes into force in April.
As reported by Construction Manager, it removes the role of CDM Coordinators, placing most of their duties with a “Principal Designer”
It also introduces an obligation for all duty holders (in Regulation 8) to ensure that Principal Designers, Designers, Principal Contractors, and Contractors have suitable “skills, knowledge and training” to take on their specific roles safely.
Other changes include:
- Principal Designer being in control of the pre-construction phase;
- default appointments on domestic projects requiring contractor to undertake client duties;
- clarification of the client’s duty to provide pre-construction information
- explicit duty of Principal Designers to advise and assist clients with the preparation of pre-construction information and management arrangements for health and safety.
Paying ‘lip service’ to the changes by appointing CDM Coordinators as ‘Principal Designers’, may not be acceptable.
Likewise, appointing architects as ‘Principal Designers’, who then outsource the role to CDMC’s, may not cut the mustard.
Clients may find themselves in difficulty. They’ve got to ensure Principal Designers and Principal Contractors are capable of fulfilling their responsibilities for all work, including non-notifiable maintenance and repair.
Principal Designers will have around 80% of the CDM-C’s role. They won’t have to legally check the construction phase plan, but if they don’t have the necessary skills, knowledge and experience, e.g. to collate pre-construction information, like utilities surveys or asbestos reports – then the client is taking a chance and a big risk.
The HSE has not published a set of competence criteria for the role, as for CDM 2007. Instead the legal requirement is focused on their “skills, knowledge, experience and where necessary training” relevant to the project.
The CITB has also published a 78 page suite of guidance documents targeted at specific duty holders, replacing the 140-page Approved Code of Practice.
The HSE’s plan to produce a shorter “micro” ACOP later this year.
If you or your client/s would like assistance with this or other construction issues, give us a call.
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