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Ten questions unlock door to Principal 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 Principal Contractor under CDM 2015 has been subject to less change that the function of Principal Designer. However, the structure has changed so we have now produced our fourth set of ‘Killer Questions’ which deal with the role of the Principal Contractor.

See also ‘Killer Questions for Clients, Principal Designers and Designers.

Remember – reference to ‘Principal Contractor’ duties means the duties of the appointed business / organisation and not the employees who carry out the actual work of the Principal Contractor.

What are YOUR answers to these questions?

The following questions are based on the legal requirements on Principal Contractor under CDM 2015. A robust answer to each of these ‘Ten Killer Questions for Principal Contractors should deliver compliance with your responsibilities.

1. Skills and knowledge etc. – How do you ensure you have the necessary skills, knowledge, experience and organisational capabilities in place on the project?
2. Principle Designer liaison – How do you liaise and share information with the principal designer (PD) relevant to pre-construction phase and provide the PD with any information for inclusion in the health and safety file?
3. Plan, manage, monitor – How do you plan, manage and monitor the construction phase and coordinate matters relating to health and safety taking into account the general principles of prevention (GPP)?
4. Construction phase plan – How do you ensure that a compliant construction phase plan (CPP) is drawn up and thereafter reviewed, update and revised?
5. Contractor compliance – How do you organise contractor cooperation and coordination, ensure contractors apply the GPP consistently and follow the CPP?
6. Access and induction – How do you prevent access by unauthorised persons to the construction site and provide authorised persons with a suitable site induction?
7. Welfare facilities – How do you ensure the welfare facilities comply with requirements throughout the construction phase?
8. Worker cooperation – How do you arrange cooperation between you and construction workers in developing, promoting and checking the effectiveness of H&S measures?
9. Worker consultation – How do you consult workers (or representatives) on matters connected with the project which may affect their health, safety or welfare?
10. Worker information – How do you enable workers (or representatives) to inspect and take copies of any information specified in the regulations?

The questions can be used to structure your consideration of the HSE and Industry Guidance.

CDM 2015 Information and Templates

See our initial CDM 2015 Survey taken after 6 months and our further survey taken 12 months after the CDM Regulations 2015 came into operation.

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.

This article was posted on 25th August 2016