Industry awaits anticipated HSE consultation on proposed changes to CDM regulations.
Back in May 2013, the HSE construction policy team prepared and presented, to the HSE Board, draft new regulations, a consultative document and impact assessment for proposed changes to CDM regulations.
Under pressure to meet an October 2014 implementation date, word has it, any day now a 12 to 13 week public consultation on the changes could begin. Here we outline some of the points expected to be included in the proposal.
Time for change?
Correspondence reviewed to date, suggests the proposed changes favour structural simplification, based upon a linear approach to the way projects are procured and managed.
The independent CDM Co-ordination role is likely to become redundant, replaced instead by project planning co-ordination duties carried out by a 'Project Preparation Manager'. This person(s) would be an existing member of the project team (i.e. client, designer, project manager or contractor as appropriate). Explicit CDM duty-holder competences would be substituted by more general requirements equivalent to HSW Act.
A reduced application threshold for the full regulations has also been muted, to include any project with more than one contractor / sub-contractor. Client duties may also be extended to include domestic clients, but these could be treated as a special case with the first appointed contractor or designer taking on responsibility for the domestic client duties.
We hear the HSE are also proposing dropping the ACoP and anticipate only producing ‘core’ guidance – leaving the industry to produce its own sector and discipline specific guidance.
An October 2014 implementation target has been outlined, but delays could see this date pushed back. In any case, a ‘soft’ transition is anticipated rather than specific transition arrangements being included in the regulations.