CDM 2015

[kerry davies]

Purely for those with management responsibilities on the bigger, mainly outdoor gigs HSE has just issued this guidance.

 

It will not affect most BR members but if they do stumble onto a CDM site as a contractor it would be useful to have a copy downloaded somewhere.

[indyld]

Just bumping this really, as it seems that discussion on this topic has rather dried up which strikes me as odd considering the April 2015 has been and gone. So, the question to the BR members is "What is your place doing [differently] with regard to CDM now?"

 

Curious to know the range of responses, based on differing situations and scales of work/venues plus different contractor arrangements. In some ways, I 'get' more of this as it relates to the large scale, site-specific world - of events in particular. But what if you are a tech in a small theatre? Maybe you are just 'keeping on keeping on' with your usual "Managing Safely" schizzle.

 

(Hoping for something other than the sound of tumbleweeds. Or rants about hi viz vests during scene changes)

 

:unsure:

[johnlinford]

I agree things have gone suspiciously quiet on this front.

 

I attended the RoSPA Legislation Update a couple of months ago which spent some time on the CDM issue, and the honest answer seems to be that the construction sector hasn't got its head around some of the issues, particularly confusions between client, principle designer and principle contractor - terms that are even more confusing in the event and theatrical worlds.

 

Particularly small builders working for domestic clients, the client doesn't care or want to care and yet has a responsibility under CDM - likewise the wedding reception in the venue won't give two hoots about the responsibility. I do see issues arising (and indeed most of the accidents I've seen arising) when multiple contractors have not been coordinated - for example florists and staging loading in at the same time and clashing. Despite production nominally being "principle contractor" unless the venue and other contractors (caterers, etc etc) recognise why this structure must be in place it will be very difficult to do anything meaningful.

 

My perception is that the honest truth is that very little you do in theatre or small-scale events will ever be notifiable - as long as you have robust policy and a good safety culture in place then nothing more needs to be done (other than being able to prove it).

[indyld]

My perception is that the honest truth is that very little you do in theatre or small-scale events will ever be notifiable - as long as you have robust policy and a good safety culture in place then nothing more needs to be done (other than being able to prove it).

 

This was my reading of it too. A pertinent quote from the HSE Chair of the JACE:

 

In many production and smaller scale event related construction activities in the entertainment sectors, where risks are generally considered to be lower, CDM management provisions will be of limited relevance beyond what is required by other health and safety legislation. In accordance with HSE’s Enforcement Policy Statement and Enforcement Management Model, where interventions do take place, the priority will be to consider the effectiveness of risk management, not compliance with CDM administrative arrangements. The need to consider CDM compliance for such activities by HSE post April 2015 will be rare.

 

In a nutshell, decent safety management in accordance with the 'usual' legislation and should interventions be needed then strict compliance to CDM admin will be considered of less importance than that of general risk management.

 

In terms of projects being notifiable, I feel that it does depend on how the 'design and construction' phases of the project (show) are defined. The run of performances are, I would argue, outside of the construction phase timeline and more generally fall under the 'usual' H&S legislation. However, taking a single production with a 3 week design process and a 4 week build prior to the actual installation could be argued to be a project life cycle longer than 30 days, even assuming that the demounting of the show at the end of the run is a distinct project (depending on how this fits with temporary works in CDM - not something I've looked up in detail). Conversely, the build period could be likened to the fabrication of parts prior to 'construction', and therefore presumably once again just fall under the 'usual' safety management in the workshop.

 

Given the above quote, it seems as if too much wondering about CDM in our world is not particularly productive but I find it interesting nonetheless. What at one point looked like it was going to cause a flap in certain parts of our industry, which perhaps should be termed the Tallescope Effect, seems to have rather fizzled out.

 

Would still be interested in hearing from others.

[kitlane]

Let's not forget that the Working at Height Regulations were predicted to precipitate the end of the world as we know it, even before Tallescopes became a specific focus of attention.

 

In response to CDM we are completing the Construction Phase Plan (one side of A4) and posting it on a noticeboard along with the production schedule and key contacts. Pretty much everything else continues as normal. My view was always that if you were fulfilling H&S requirements already then for the vast majority of what we do very little would change.

 

The one possibly contentious point is that the production manager has implemented a blanket "hard-hat / Hi Viz / Toe Cap" policy for fit-ups, focus etc. I got myself worked up ready to argue the toss on this but it's worked out well. With so many students involved it is easier to make it a blanket policy than to have to explain when to put your hard-hat on. The Hi-Vis jackets are colour coded so we can see who is a student or in-house tech immediately. Plus they are printed with the department name so a touring company can easily find an electrician or stage technician even if they haven't yet learned everyone's names.

[kerry davies]

Hi Kit, it is no surprise to me when an idea needs to overcome initial reluctance but is wholeheartedly welcomed once that initial hurdle is surmounted. It is human nature to fear the unknown even if it promises improvement, people are small "C" conservative.

 

CDM is merely formalising what most reputable organisers have been doing for many years. What puts people off are the labels like client, PC and PD. Once they get their heads round renaming the promoter, the PM/Site/Safety Managers we are all accustomed to there is hardly any change. For those who need to do the full paperwork thing, Star events have their procedures on their website and the one key point to remember is that up until CDM the HSE took a hands off approach to our sector. This was found to be illegal and discriminatory under EU law so they will in future enforce in the entertainment sector.

 

Where Rob and John both wonder how things will pan out, especially for the smaller enterprise, is where people need to keep an eye out for ABTT/PSA/PLASA news. HSE do a project called safer sites on small building sites. The 2013 results ensured that they would do it again which we as a sector do not want to happen. In 2014 they found that;

Unacceptable conditions and dangerous practices were found at nearly half of the 1,748 repair and refurbishment sites visited by HSE inspectors, with 1 in 5 sites so poor, formal enforcement action was required. Many of the issues found could have been easily prevented with simple, straightforward management and planning.(My bold)

[Pete McCrea]

I'm not sure if this has already been posted here, but the HSE have published guidance on how CDM applies to the events industry.

 

See here.

 

It's quite clear and helpful, and at first look confirms my thoughts that those doing things 'properly' already don't need to make many changes to 'comply'.

[kerry davies]

Thanks Peter, beat me to it by minutes. I would urge everyone to read through at least their own sector's guidance whether they are in supervisory roles or not. The examples and templates are especially useful and, as you say, are no more than what any reputable people have been doing for years.

 

The mods might want to merge this with my last safety topic?

 

Moderation: Done!

[kerry davies]

Just a heads up on the latest catastrophe by our beloved leaders in government.

Having spent time and effort last year on changing CDM to make the "Principal Designer" the responsible person rather than the "Construction Coordinator" they now say that small scale construction work is stifled by this change and are in the process of trying to mess things up even more.

 

I am sure you will all join me in congratulating the ministers responsible in their sterling efforts to "ease the burden of regulation".

 

Or maybe not? The HSE won't having spent a fortune telling people all about last year's ministerial wonderworks.