The UK’s Construction (Design and Management) Regulations came into force during my career
Sometimes my interpretation of the latest Regulations (CDM 2015) seemed to be different to that held by EPCM contractors. Six examples that come to mind are:
The most suitable party to produce the “pre-construction information” is usually the “Client” who has the duty to provide it. It should be as much as possible specific to the project. Organisations who offer to write this are unlikely to know sufficient details of the project and site and swamp the document with generic text from other projects
When an organisation is appointed the “Principle designer”, it should plan to coordinate all designers not just it’s own disciplines. This could include the Client’s process engineers and vendors designing specialist equipment
The “Principle contractors” as site managers, prepare the “construction phase plans” describing the health and safety arrangements for the construction works. They should be encouraged to attach the pre-construction information and not interpret/edit it into their own document. Otherwise key information for the “Contractors” is either missed or wrongly presented
A fenced construction site should not be referred to as a “CDM site” with a “CDM boundary” implying that the Regulations do not apply elsewhere. Better if any site designation stated who is managing it
If the Client takes over the constructed assets for commissioning, the role of appointed “Principal contractor” should be formally ended. The “construction phase” has effectively been completed and with it the application of the “construction phase plan”. There is no need in my opinion to then appoint the Client as Principal contractor
The “health and safety file” should only contain information listed by the appendix in the regulations. Many “Principal designers” wanted to use it to contain all developed design information so the file becomes unmanageable for both production and later use. Information relating to the operation of the installed plant is not required unless related to removal or dismantling. Construction MSRAs (method statements and risk assessments) are definitely not listed
