Do CDM regs apply for regular weekly block cleaned and regular external window cleaning in a housing association? Reach and wash system in place for window cleaning

Cleaning does not fall under the CDM Regulations unless it involves toxic or corrosive chemicals, high pressure water jetting or grit blasting.

The following is extracted from CDM Regulation 2.

Construction Work:
The carrying out of any building, civil engineering or engineering construction work which includes any of the following:
(a) the construction, alteration, conversion, fitting out, commissioning, renovation, repair, upkeep, redecoration or other maintenance (including cleaning which involves the use of water or an abrasive at high pressure or the use of corrosive or toxic substances), de-commissioning, demolition or dismantling of a structure;
(b) the preparation for an intended structure, including site clearance, exploration, investigation (but not site survey) and excavation, and the clearance or preparation of the site or structure for use or occupation at its conclusion;
(c) the assembly of prefabricated elements to form a structure or the disassembly of prefabricated elements which, immediately before such disassembly, formed a structure;
(d) the removal of a structure or of any product or waste resulting from demolition or dismantling of a structure or from disassembly of prefabricated elements which immediately before such disassembly formed such a structure; and
(e) the installation, commissioning, maintenance, repair or removal of mechanical, electrical, gas, compressed air, hydraulic, telecommunications, computer or similar services which are normally fixed within or to a structure.

Designers would have to address how these cleaning operations are performed in a safe and healthy way, but the CDM Regulations do not apply to the operations.

It is irrelevant that these activities are performed by a Housing Association, as domestic clients are excluded from the duties, but domestic property is not!

It should be noted that, even though the CDM Regulations do not apply to cleaning operations, the Health and Safety at Work, etc. Act, the Management of Health and Safety at Work Regulations, the COSHH Regulations, the Manual Handling Operations Regulations, etc, still do apply and a safe system of work is required.