Author Bio ▼


Rhaynukaa is a project safety advisor at BAM Ferrovial Kier JV – Crossrail and a Chartered IOSH member. She has previously worked at the Sleaford Renewable Energy Power Plant. She holds an NVQ Level 5 Diploma in Occupational Health and Safety and Distinction in NEBOSH National General, Construction and Fire Certificates.

September 30, 2014

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Clarity and precision key to CDM Regs reform

By Rhaynukaa Soni

Last Thursday (25 September), the Institution of Civil Engineers (ICE) held its first constructing health and safety conference. With an array of speakers, the content ignited some interesting debate and left the audience with a clear insight into how the UK’s major civil engineering projects are tackling health and safety.

One speaker that raised more questions than answers was consultant John Carpenter. As he correctly pointed out, this is the third time since its inception that the current CDM Regulations have been reformed. As such, we are unlikely to see any further major changes for many years to come.

With this in mind, he argued, it is vital that we get the reforms right and that we clear up a lot of the bureaucracy, which exists with the current regulations. His main focus is around the question of competence. Competence, he believes, means being fit for purpose. However, the regulations refer to instruction, information, supervision and training, and these will require very careful definition if these deceptively simple words are not to cause more confusion. As yet they are not defined.

Each one of those requirements is quite ambiguous and subjective, and this results in massive gaps within the industry and even among major projects. Carpenter highlights the issue of CSCS cards, which only around 50 per cent of the industry currently use – most of them being on larger projects. Even so, the cards themselves are not consistent and, as he points out, some CSCS cards require an NVQ, which by its design do not require training.

He is calling on HSE for far more clarity and a distinct removal of the current ‘fuzziness’ that exists with the regulations. Directing his thoughts to the HSE representatives present, Carpenter asked for those updating the regulations to very clearly define what is and isn’t required rather than reverting to open-ended vague statements.

A point that really resonated with me, and no doubt with many in the audience, was the unnecessary requirement for lengthy paperwork. He told delegates that those that had managed to cut down their paperwork were then challenged and told it was not suitable and sufficient.

‘Suitable and sufficient’ is a phrase that is littered throughout the approved code of practice and, yet again, is very subjective and open to interpretation. If we are to move forward with a positive health and safety culture, we need to consistently ensure that clients, contractors and enforcers are all working towards a common goal.

While I firmly argue that the necessary paperwork i.e. risk assessment, training records etc. should always be in place, I do agree with Carpenter that much of the paperwork that is generated contains unnecessary bumf.

As a result, many pertinent points are often drowned out, usually as the reader gives up after the first ten pages. I am a strong advocate of keeping paperwork to a minimum and that it only contains clear, relevant and task/site-specific information that is well communicated and easy to read/use for every level of an organisation.

With this latest update of the CDM Regulations, we have a real opportunity to ensure that all of those in the industry, regardless of what side of the fence they are on, are moving forward together in a consistent way. As Carpenter concluded: “clarity and precision is key.”

Rhaynukaa Soni is a project safety advisor at BAM Ferrovial Kier JV – Crossrail



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John Bartlett
John Bartlett
9 years ago

Sadly I think that the HSE are just going to go ahead and not take the views of those at the sharp end into account. A complete dogs dinner awaits us.