Ten questions unlock door to Contractor CDM compliance
The CDM Regulations 2015 are taking time to ‘bed down’ as demonstrated by the responses to our recent CDM 2015 Five Minute Survey. See below. We hear and read reports of uncertainty and confusion despite the presence of extensive HSE and Industry Guidance explaining the regulations.
We have therefore decided to distill what is required of each CDM 2015 duty holder into a set of simple questions which can be used to structure self-appraisal and confirm compliance with the new legislation.
These questions are those most likely to be asked by HSE during a routine project intervention or incident investigation. The strength and veracity of your answers may affect the prospect of enforcement action by the regulator.
The role of the Contractor under CDM 2015 has been subject to less changes than other dutyholders. However, the structure has changed so we have now produced our fifth and final set of ‘Killer Questions’ which deal with the role of the Contractor.
Remember – reference to ‘Contractor’ duties means the duties of the appointed business / organisation and not the employees who carry out the actual work of the Contractor.
What are YOUR answers to these questions?
The following questions are based on the legal requirements on Contractor under CDM 2015. A robust answer to each of these ‘Ten Killer Questions for Contractors” should deliver compliance with your responsibilities.
- Client awareness – How do you satisfy yourself that the client is aware of their duties under CDM 2015?
- Skills, knowledge etc. – How do you ensure you have the necessary skills, knowledge, experience and organisational capabilities in place on the project?
- Site access – How do you ensure work on a construction site does not begin unless steps have been taken to prevent access by unauthorised persons to that site?
- Direction by Principals – How do you ensure you comply with directions given by the principal designer or the principal contractor?
- Plan, manage and monitor – How do you plan, manage and monitor construction work carried out by you or workers under your control so that it is carried out without risks to health and safety taking into account of the general principles of prevention?
- Construction phase plan – How do you ensure your compliance with those parts of the PCs construction phase plan (CPP) relevant to your work on the project and that a CPP is drawn up where you are the only contractor on the project?
- Worker skills, training etc. – How do you ensure that persons you employ or appoint to work on a construction site have, or are in the process of obtaining, the necessary skills, knowledge, training and experience to safely carry out the tasks allocated?
- Worker supervision and induction etc. – How do you provide each worker under your control with appropriate supervision, instructions and information including a suitable site induction (where not already provided by the PC) and the procedures to be followed in the event of serious and imminent danger to health and safety?
- Worker risk information – How do you provide workers with information on risks to health and safety identified by your risk assessment and any other information necessary to enable the workers to comply with the law?
- Welfare facilities – How do you ensure that the requirements for welfare are complied with so far as they affect you or any worker under your control?
The questions can be used to structure your consideration of the HSE and Industry Guidance.
CDM 2015 Information and Templates
We have published a great deal of further information and templates designed to support Clients, Designers, Principal Designers/Contractors and Contractors in meeting their duties under CDM Regulations 2015.