Proposed Revisions to the ACoP for the CDM Regulations
28 September 2000
The following transcript is reproduced with the permission of Stephen Wright who spoke at our User Forum 28th September 2000. Stephen is a policy section head at the HSE and is responsible for the consultative document regarding the proposed revisions to the ACoP for the CDM Regulations.
Bringing Major Changes To The Construction Health And Safety Law Framework
Some people have been ignoring their CDM responsibilities. Some have been producing mountains of paperwork without adding anything useful as far as health & safety is concerned. To others it is a weight that drags them back in their pursuit of business efficiency. It is just a mass of meaningless paperwork. Leading to frustration.
So there you are then, just relaxing with the comfortable old ACoP and along comes the CD (Consultative Document 161 The Proposed Revisions to ACoP). What do you think of it? I really want to know. In that it still needs a lot of work to get it to a satisfactory state. The only way it will reach a usable end format is if you play your part and share your experience of putting the principles of CDM into practice and avoiding the meaningless bureaucracy!
Make no mistake we must do something. Accident numbers are increasing and so are accident rates. The government expects us to do something to turn things around. One strand of this is to improve the management of construction projects and the new ACoP can play a part in achieving that. We need a lot more though. Please send your thoughts to me on the back of a blank cheque!
John Prescott and Bill Callaghan are planning to host a construction summit early next year where construction companies, including clients, designers, etc., will be expected to commit themselves to practical improvements.
The focus groups concluded that the problems were not with the Regulations themselves and that most people could live with them - strangely most of the comments we have received so far have involved suggestions that would involve changing the Regs. The one thing we have ruled out!
We wanted everyone to be able to understand their duties and what they had to do comply. We wanted the guidance to be easy to understand and easy to navigate.
In particular we need to provide information to designers about what information they should pass on to contractors, more of this later.
Case Study Material
Practical illustrations of good practice should help people who want to comply, but don't know how to go about it.
We need to cover the full range of construction work. The CD probably tends to assume that construction equates to building. Ideas about ways to broaden the range of work covered (demolition, civil engineering, engineering construction, maintenance) would be welcome.
It is particularly difficult to ensure the competence and resources of those involved in a project without generating a lot of work. We need to strike a balance here - how have we done? Can you provide a better idea or suggest improvements?
Planning & Good Management
Planning is essential to health & safety, but many plans achieve nothing because they are collections of useless, and unused paperwork. How can we make them into useful documents? Will what we have suggested work? Have you any better ideas/ways we can improve?
One reported problem is that designers often don't appreciate the practical implications of their decisions and the health & safety implications. Is that correct? If so do you agree that it is essential that they do?
I have met 2 groups of people as far as planning supervisors are concerned. There are those who want to get rid of them, preferably terminating with extreme prejudice. Then there are the planning supervisors! I certainly want to get rid of those that don't add value as far as health & safety is concerned. Have we struck the right balance? (Since almost 4,000 copies of the CD, 2/3 of the total distributed so far, have been distributed to APS members responses may be biased. If this worries you, make sure you cast your vote!)
What do you think of our definitions, mainly listed in the glossary? Can you improve on them?
I want the good companies to know what is expected of them so that they can achieve it. I want our Inspectors to be able to enforce reasonable standards where people are not inclined to comply voluntarily. Is it? If not how can it be improved on!
I don't want people doing work that does not generate health & safety benefits, worse generating paper that buries the important bits of information. Have we achieved that? How could we improve on what we have done? Text of guidance needs to be amended in view of these changes, but the changes aren't likely to be substantial. These are the main strands we have tried to draw out for 3 of the key duty holders.
This is probably one of the most significant changes. I believe it provides a sensible basis for deciding what should be communicated. What do you think of the definition and examples? Can they, with some further work, provide the information that contractors need - without loads of rubbish piled on top? I also hope designers who identify such significant hazards will reconsider to see if they can be eliminated or reduced.
CDM is about some of the procedural aspects of managing construction work, e.g. choosing competent players, communication, co-operation and planning, but the requirements about actually managing the work are the general requirements of the Health And Safety At Work act. We have the construction management guidance. Is that enough, or do we need some ACoP? If so can we say something useful that covers the whole range of construction work in a few paragraphs?
The way of achieving improved health & safety in construction, in my opinion, is to improve the management of the whole project from conception, though construction, maintenance and through to eventual demolition - I would say from the cradle to the grave, but I want less of this industry's workforce to end up in their graves prematurely. CDM will not ensure good management, but I believe it provides a suitable framework for good management. Work with us to get it right.
DCM - 16 October 2000