Construction Health & Safety News, Advice and Information from PP Construction Safety

Survey reveals confusion and non-compliance over PD appointment

Our CDM 2015 One Year On survey was open between 1st April 2016 and 31st May 2016, The survey asked three substantive questions:

1. How does CDM 2015 compare to CDM 2007?
2. How does the Principal Designer (PD) role compare to the CDM Coordinator?
3. How is the Principal Designer (PD) role working

A total of 163 completed responses were received and the majority of respondents (50%) report that their principal role involved ‘health and safety’. Many respondents also completed the free text fields.

Our thanks go to everyone who took part in the survey.

Large majority believe PD not working well

The Survey Data is published in full so that readers might draw their own conclusions. We offer the following observations and conclusions based on the replies and free text comment:

• CDM 2015 v CDM 2007 – respondents are almost equally divided in their overall assessment of CDM 2015 compared to CDM 2007. A significant proportion (37%) report CDM 2015 to be an improvement compared to CDM 2007 whilst a slightly smaller proportion (32%) report that CDM 2015 is worse. In addition, no change was reported by 31% of respondents;
• Principal Designer v CDM Coordinator – a significant proportion (43%) report that the PD role is worse than the CDM-C whilst a smaller proportion (32%) report that the PD role is an improvement. In addition, no change was reported by 25% of respondents; and
• Performance of PD role – a large majority (64%) report that the PD role is working poorly or inadequately whilst less than half this percentage (31%) report that the role is working well or adequately. In addition, 5% were unable to say how well the role is working.

Reluctance, confusion and non-compliance prevail

We asked further questions regarding compliance, understanding and behaviour of dutyholders. The replies reveal the following findings:

• Reluctance and Confusion – a large majority (66%) report that design organisations are reluctant to accept PD appointments. In addition, almost three-quarters of respondents (71%) report confusion over what the PD must do to comply with the regulations;
• Compliance – poor compliance by principal designers, designers and clients is reported by the greatest proportion of respondents. By contrast, good compliance by principal contractors and contractors is reported by the greatest proportion of respondents. At the ends of the spectrum, poor compliance by PDs is reported by 52% of respondents whilst good compliance by PCs is reported by 67% of respondents; and
• Client PD Appointments – significant proportions of respondents report that project clients are: failing to appoint a PD (37%); appointing an inappropriate organisation (48%); or failing to properly resource the PD function (55%).

Main conclusions

We draw the following conclusions from the survey:

1. The Principal Designer function is faltering twelve months after the new regulations came into operation. A large majority report the PD function is not working well (64%) and confusion (71%) regarding the actions required of the PD. The proportion of respondents holding these views has increased since the first survey of visitors to our website in November 2015;
2. Despite the function not working well only 36% believe that HSE guidance on the PD function is inadequate. This suggests that even more time is needed for the regulations and guidance to become understood and acted upon by clients and appointed Principal Designers; and
3. In the short-term the suite of HSE and Industry guidance might be supplemented by further HSE FAQS regarding the PD appointment and delivery of the function. This may help reduce the confusion, uncertainty and non-compliance reported by our respondents.

We would be glad to receive any observations or comment on the survey.

Further guidance on Principal Designer function 

Readers may find our posts regarding the Principal Designer helpful in understanding and delivering on the PD function.

This article was posted on 5th June 2016