New CDM Regulations aim to tackle among other matters the unacceptably high number of people suffering from workplace dust and emission ailments (more than 13,000 says the HSE)* but they also signal an end to CDM co-ordinators. So what now for building site safety asks Gareth Billinghurst, director and senior auditor at online safety legislation experts Cedrec.
Both current and new CDM Regulations have a responsibility to ensure that there is a supply of fresh air, where reasonably practicable. This covers the construction site and its approach to ensure that both employees and the general public are protected from any dust and emissions. They also require that work and industrial plant that could have an impact on air quality carries effective devices to provide visible or audible warning. This places an immediate duty to act on the visible impact of dust but not on the long term and accumulating effect.
However, it is clear that the current level of dust- and emission-related illness is far too high and therefore clearly necessitates the need to update assessments and management across the board particularly smaller sites, where constraints on resources, finances and time used for training, assessments, audits and dealing with causal labour all have a considerable price tag.
But looking ahead to the changes, for some the most welcome news will be the replacing of CDM co-ordinators with principal designers. There has been an outcry from many sources in the industry that this role simply creates unnecessary cost to construction projects, and ultimately adds another (unwanted) expense to an already expensive building process.
As the title suggests, the role helps co-ordinate the safety commitments for the entire range of people involved on a construction project, so while many may only see a financial inconvenience, the job actually forms a cohesive lynchpin for safety throughout major construction projects from start to finish.
So if the aim is to reduce unnecessary construction site costs, does this mean buildings will be cheaper? It’s impossible to say but the responsibility to keep a site safe will always remain paramount – it’s just going to be shared between everyone: from designer to principal contractor.
My hope is that the brightest and best CDM co-ordinators will be retained and used to help those with responsibility quickly find their feet. After all, construction sites are always complicated and dangerous places to manage, with an abundance of different contractors, trades and skills; so anything that ensures safety functions are carried out to a high level of competency has to be welcomed.
It is entirely possible that the main reason for these changes is because of the new requirement for applying CDM to smaller construction work – like domestic projects and those that fall below the F10 notification. Such projects would struggle financially if they had to pay for a dedicated CDM co-ordinator to manage the safety of their development (in the future, most small projects will use the client or principal contractor to fill this role).
And what about domestic projects? The client can’t fulfil the role. So will they bother with the expense of a competent designer to fill the principal designer role? It’s unlikely, they’ll simply manage it in house, paying lip service to the concept of designing-in safety from the drawing board upwards.
Construction sites consistently have the highest fatality rates of workplaces across the UK, so the correct guidance, support and interventions by the HSE must be in place to ensure that CDM works across the whole sector. Only time will tell if CDM co-ordinators are being made scapegoats simply for the ‘sin’ of being seen as a construction industry overhead. All we can hope is that the level of safety we currently enjoy is maintained or improved in light of the new changes.
Gareth Billinghurst is director, consultant and auditor at Cedrec Information Systems
* Statistics from the HSE included an estimated 13,000 deaths a year from occupational lung disease, of which dust and diesel emissions form a large a percentage even when discounting asbestos. When including the well-known risks and conditions from asbestos, such as mesothelioma with 2,535 deaths and asbestosis with 464 deaths in 2012. There is also silica dust to consider. This comes from many stages of construction work when working with materials such as stone, concrete, brick and ceramics. Silica dust accounted for 789 deaths from lung cancer in 2005. When all agents are reviewed together, the HSE have given a figure of 4,000 employee deaths last year of Chronic Obstructive Pulmonary Disease (COPD) from exposure to either dust, gases, vapours and fumes.
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Gareth
The reality is that ‘domestic’ clients will not be aware of the duties contained in CDM 2015. By default the duty will fall to the contractor or principal contractor. With regards to a designer, most likely an architect or small builder, they will have little knowledge of CDM either. So you can forget about designing-in safety or any other safety practices when it comes to small domestic projects and that includes a CPP and H&S File!