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Read Full ArticleMany within facilities management have attended Construction (Design and Management) Regulations training courses and heard of terms like Principal Designer or Principal Contractor thrown into the mix, writes Carl Mannion. But what are FM's responsibilities?
What seems to be absent from a lot of the training courses and CPD events is what facilities management activities are considered to fall under the term 'construction. and therefore, CDM 15.
First and foremost, anyone with an interest in the subject can download for free, a copy of the L153 document produced by The Health and Safety Executive. Type L153 into your search engine and, voila!
Secondly, CDM 15 is quite detailed about what is considered to be 'construction work'. The definition is broad so I will try to paraphrase as much as possible.
Construction work is carrying out any building, civil engineering or engineering construction work, and includes:
Construction, alteration, conversion, fitting out, commissioning, repair, upkeep, redecoration or maintenance such as high-pressure water cleaning, demolition or dismantling of a structure.
This can include painting and decorating (including scuffs and marks), Alteration to doors, pressure washing walkways, false wall installation, installing new socket fittings. All of these activities can be considered to fall under the definition of construction works.
Installation, commissioning, maintenance, repair or removal of mechanical, electrical, gas, compressed air, hydraulic, telecommunications, computer or similar services which are normally fixed within a structure
The increase in the number of facilities management companies that aim to provide a one call, all solutions business approach for their clients, means additional responsibility for CDM 15 compliance. Maintenance of utility services and systems is also considered to be construction work.
The four main things to consider with CDM 15 are affectionately referred to as the 4Cs:
Communication
Co-ordination
Co-operation
Collaboration
Being able to demonstrate how you adhere to the 4Cs will go some way to safeguarding your business and your reputation.
Documents
There are some documents that need to be created and managed throughout any construction project too. They vary in length and complexity. For example, a construction phase plan for a full electrical service maintenance contract in a residential tower block, will have considerably more information requirement than touching walls with paint to conceal the scuff marks.
If you are hiring in external contractors to complete certain aspects of your work, remember to have a process in place which identifies how you selected them from a health and safety perspective. This could be a Pre-Qualification Questionnaire, Framework Agreement or other such tool. What is important to demonstrate is that you have taken health and safety into consideration when selecting a business to contract with.
Contractors
Many organisations forget to reapprove their contractors, meaning they could have been on the framework for 5+ years without verifying basic health and safety credentials.
As with contractors, consider the employees within your organisation against the 4Cs. Are they capable of working in collaboration with other contractors to plan a complex construction project, or do you need to consider additional training and support for them? There are plenty of training courses on the open market to consider for construction based supervision and management. Perhaps the most recognised within the construction industry is the CITB Site Supervisors Safety Training Scheme (SSSTS) or Site Managers Safety Training Scheme (SMSTS). Both courses are specifically designed to support leaders in construction sectors to deliver a project safely. Both courses go some way to demonstrate as an employer, you have taken reasonable steps to train your staff to a recognised standard.
Forward planning
CDM 15 is focused on people coming together to think about completing a project safely from the initial concept, design stage and beyond. This means CDM 15 applies a long time before work on site actually starts. Asking yourself questions such as:
Do we have a site layout?
Will the site be in a live environment where public or office workers may enter?
How can we eliminate or reduce the need to work at height?
How do we eliminate or reduce noise and vibration to the workers and others?
Are there any special considerations such as blocking an emergency exit?
Who will supervise the works being carried out and are they competent to do so?
People and safety focus
In summary, CDM 15 is a people focused regulation that requires clients, designers, contractors and employees to think about how a construction project will be completed from initial concept and design stage.
If you can demonstrate how you have applied the 4Cs (usually with documentation), placed competent people in charge of supervising the works being carried out and show you have considered if your project is indeed a construction project, you are on the right path.
Picture: CDM 15 - get the basics right and the rest will hopefully follow
Article written by Carl Mannion | Published 14 March 2018
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