The report was presented to the HSE Board on the 13th August. Whilst the new regulations are timetabled for release in 2015, it would not be impossible for the HSE to release them earlier. There were in excess of 1,400 responses to the consultation making it one of the largest the HSE has ever seen. The report concludes that there is a broad balance of support for the proposed changes from the main representative industry bodies, whose views were given the majority of recognition.
Key issues from the consultation
- Replacing the CDM co-ordinator (CDMC) role with a principal designer (PD): This element raised several concerns from bodies such as RIBA and APS, particularly over both the designers’ desire and capability to successfully deliver the new role. These points were discussed by the HSE, who have now recognised that there will most likely be a delegation of the PD role to suitably skilled third party consultants.
- Replacing the Approved Code of Practice (ACoP) with role specific guidance: The HSE now recognises that a strong case has been made to develop a shorter "signposting" ACoP, which will now be complemented by the proposed individual role guidance documents.
- Replacement of the detailed competence requirements: The HSE believes that the replacement of the existing requirements is appropriate, however they are now revisiting the drafting of this provision to improve clarity, in light of the consultation responses.
- Client duties: General support exists for the increased focus on commercial client responsibilities, however, in order to comply with the EU Directive requirements the HSE are now revisiting the section of the regulations concerning domestic clients, in order to improve their clarity.
- Changes to the notification requirements: The proposed changes to raise the notification threshold, which is now aligned with the EU Directive, have been deemed appropriate by the HSE. The client will be responsible for notifying projects which are expected to last more than 30 days and involve more than 20 workers simultaneously, or involve more than 500 person days of labour.
We pride ourselves in our delivery of CDM services and our collaborative approach to ensuring the best result for you. We are able to support clients, designers and contractors alike, with any aspect of compliance with the proposed new legislation.
Faithful+Gould is currently finalising our CDM 2015 action plan, developed with our clients in mind to assist you during the transition. Our support programme will include:
- Delivery of national presentations to clients, designers and contractors
- Communication across our networks to raise awareness of the implications of the proposed changes and the timetable for preparation
- Review and updating our training provision
- Updating our service delivery toolkits in line with the new regulations
We will help you to be fully prepared for a seamless transition, well in advance of the implementation date, whether you engage or work with us, and or need training and support.