The ICE’s expert health and safety panel has said it broadly supports the proposed changes to Construction, Design and Management (CDM) regulations 2007, but has reservations around whether they provide sufficient clarity.
The proposed changes to the regulations come amid efforts to roll back red tape and simplify the regulatory environment for businesses. The ICE has been closely involved with the review of the 2007 standard, and produced the report CDM, three years on to advise on how health and safety standards can be improved.
In its response to the Health & Safety Executive’s (HSE’s) consultation, the panel said the 2015 standard retained many familiar aspects, namely, the importance of the client providing information, the principal contractor, construction phase plan, physical standards on site and the health and safety file.
However, it raised concerns about some fundamental changes proposed, and in particular, the demise of the CDM coordinator, the requirement for a principal designer, the removal of explicit competence requirements, the removal of the exemption for “domestic clients” and the publication of HSE guidance, as opposed to an approved code of practice.
In its response, the panel said the structure and definitions included within the proposed CDM 2015 regulations should be clearer - particularly as they are designed to be more accessible to small and medium-sized enterprises.
While supportive of the replacement of a CDM coordinator with a principal designer, the panel said the HSE should be aware of the additional competence requirements this would place on those designers, as well as the additional training that this regulatory change would require employers to carry out.
Panel chair David Lambert commented: “The ICE is broadly supportive of the proposed changes in CDM 2015.
“There is a real need to reduce the amount of red tape confronting construction firms, and the newly proposed regulations should go some way towards that.
“However, there remains a need to clarify definitions in the new code, and provide clear guidance which emphasises proportionality of effort and avoids any unintended bureaucracy before implementing CDM.”
Last month, the panel hosted a CDM consultation event, streamed online to over 140 participants, at the ICE’s headquarters in London.
Input from delegates was used in the Institution’s final submission to the HSE.