Proposed changes to Construction Design Management
In March 2014 the HSE launched its proposed changes to Construction Design Management regulations in a consultation document. The key points of its proposed changes to Construction Design Management regulations involve maintaining or improving worker protection, simplifying the regulatory package, improving health and safety standards, implementing the Temporary or Mobile Construction Sites Directive in a proportionate way, discouraging bureaucracy and to meet better regulation principles.
In order to implement these key points, there are three proposed key changes:
Replacing the CDM-C role with the Principal Designer (PD) – The aim of changing from having a CDM-C to appointing a PD is largely driven by the desire to meet the requirement of the TMSCD which requires pre-construction co-ordination. The PD will be responsible for: Planning, managing and monitoring the pre-construction phase, ensuring that where reasonably practicable, risks are eliminated or controlled through design work, passing information to the Principal Contractor (PC), ensuring co-operation and co-ordination from workers, ensuring designers comply with their duties, assisting the Client in preparing the pre-construction information, preparing the health and safety file.
Changes to the threshold for appointment of co-ordinators – TMCSD currently requires the appointment of co-ordinators wherever there is more than one contractor. The consultative document aims to set out sensible and proportionate arrangements for the co-ordination of projects which fall within the scope of this requirement. The consultative document sets out that it is expected that the PD role will be discharged by the person responsible for the design work. The belief is that there should be more effective co-ordination, particularly of smaller and poorly managed projects involving significant health and safety risks.
Changes to the threshold for notification – Under the proposed changes a project is notifiable if the work is to last longer than 30 working days with more than 20 workers working simultaneously at any point in the project or exceeds 500 person days. So in practice it would be possible to have a project on site for say 40 working days with the maximum number of persons on site not exceeding say 12 (max possible 480 person days) or 60 days with 8 workers (max possible 480 person days). With the introduction of the ‘and 20 persons’ element to the revised notification threshold, it is likely that less projects would be notifiable under the proposed changes.