The ‘Construction (Design & Management) Regulations 2015’ affect all schools in relation to building maintenance and/or refurbishment works (see tinyurl.com/psm-cdm-2015). Their aim to reduce the risk of accidents during small works and construction projects by mandating good design, planning and co-operation. They specify legal requirements for on-site safety and welfare facilities, while contributing to a broader recognition that the way projects are designed and managed can reduce risks to workers – and that well-designed buildings are ultimately safer to use and easier to maintain and clean.
CDM regulations apply to all nonroutine project work outside of standard like-for-like replacements or planned maintenance. They define ‘construction work’ as the creation, alteration, conversion, fitting out, commissioning, renovation, repair, upkeep, redecoration or maintenance of a school building – including the provision of mechanical and/or electrical services.
It’s important to note that official notification will be required where the project duration is set to exceed 30 days and will see 20 people or more on-site simultaneously, or where a project will exceed 500 person days. Notification should be submitted online to the HSE by the project client.
There should be no reason to appoint an additional person to administer CDM arrangements if the project team experience required to perform their duties. Schools must ensure they fully understand the responsibilities of the project’s various duty holders and their role in the process. Duty holders in turn have a responsibility to assign appropriately qualified individuals to the project, and cooperate effectively with any other designers and contractors commissioned by the client.
In projects involving non-community schools, the school itself will be the client. They will have commissioned the project in the first instance, chosen the contractors and initiated the work. In projects involving community schools, the client will more likely be an LA, which will decide what will be undertaken and how. The client is positioned at the head of the supply chain and will be expected to put arrangements in place to ensure that risks to health, safety and welfare are properly managed, which will require them to produce an appropriate project work strategy.
Contractors manage or control the subsequent construction work. If only one contractor is involved, they must produce a construction phase H&S plan, describing how the on-site arrangements will be organised, before the project starts. Where more than one contractor is involved, the client must appoint a principal contractor in writing. The PC’s role will be to coordinate all of the contractors attached to the project and produce the construction phase H&S plan.
It’s the job of the designer to prepare drawings, decide on the layout, issue bills of quantity, specify materials and propose any structural changes. A principal designer must be appointed in writing by the client on projects involving more than one contractor. The PD’s responsibilities will include collating site hazard information before work begins and compiling an H&S file over the course of the project. The latter will detail how the project was completed, including ‘as built’ drawings, specifications, details of materials used and operational/ maintenance manuals. The file will then be presented to the client at the project’s conclusion and referred to in future for hazard information ahead of any further construction work on the site.
Louise Hosking is managing director at the health and safety consultancy, Hosking Associates