CDM regulations

[richard]

Not sure if anyone has seen but the HSE are consulting on changes to the CDM regulations, which may mean that scene changes/get ins and the like start to come under such regulations, the below summarises what could happen:

 

Theatres to become Construction Sites?

The HSE has recently released a consultation document that, if implemented, will fundamentally if not fatally, change the way we put on theatre in the UK. The entertainment industry is currently exempt from Construction Design and Management Regulations as found on building sites, but the HSE wishes to change this by implementing the Temporary and Mobile Construction Sites Directive. We are in real danger of having theatres turned into construction sites complete with compulsory hard hats, boots, gloves, goggles, hi-viz jackets etc. which will be fenced off whenever structure (scenery) is being assembled, moved or removed. Interval scene changes will become construction sites, audiences and musicians would have to be removed whilst scene changes take place and streets will have to be fenced off for get-ins and get-outs.

 

Download the Impact Assessment document http://www.hse.gov.uk/consult/condocs/cd261.htm and submit your comments to the HSE by the 6th of June (5 days before the ABTT Theatre Show) and help protect your industry. Do this or lose UK theatre as we know it.

 

What do people think?

[indyld]

..

We are in real danger of having theatres turned into construction sites complete with compulsory hard hats, boots, gloves, goggles, hi-viz jackets etc. which will be fenced off whenever structure (scenery) is being assembled, moved or removed. Interval scene changes will become construction sites, audiences and musicians would have to be removed whilst scene changes take place and streets will have to be fenced off for get-ins and get-outs.

 

What do people think?

 

What I think is that I'm not sure why the above is cited as being a 'bad thing'. I can see the headlines: "Theatre finally gets its act together on H&S". Now, there may be other implications which are yet to be really be examined but the idea that theatre works aren't in a similar category to a construction site in terms of scope seems hard to argue.

[richard]

I think it's about common sense really - I don't see a problem with areas of streets being fenced off during get ins and get outs for example (I have seen some pretty dodgy things happening outside theatres in the west end during ins and outs), but I do think that if suddenly stage crew have to wear hi-viz to do a scene change it might destroy the magic of theatre somewhat. There is also the issue of how "notifications" would be handled - would the HSE need to know about every scene change, or would a theatre just notify the activities for each production.

 

I don't see this as the death of theatre myself, but I don't know enough about what the changes would be.

[kerry davies]

Richard, I take it that your quote is the ABTT response and wonder why I am not surprised they have, yet again, gone bonkers as soon as H&S is mentioned. Why they don't all just quit and work for the Daily Heil or Sexpress I do not know.

 

Back in early April I posted about this in this forum and pointed out that it will have very little to do with the "indians" but that "chiefs" need to be aware of the consultations. Nobody yet knows what the final effects will be but if theatre cannot manage to raise it's game to where outdoor events have been going for some years then maybe theatre does need to die?

 

If they are not good enough to get on the boogie beam with "hairy arsed roadies" why on earth does anyone pay them a membership fee? If they equate H&S with boots and high viz they really are part of the problem rather than the solution and if they are representing you I would be worried, very worried.

 

Rant over. Mutter mumble, tallescope, ######, moan.

[richard]

Hi Kerry, I couldn't actually find your post when I searched, I have to admit I'm not really clear on what the impact this change would have - the examples that are given in the quoted text are not very helpful and the document doesn't seem to mention theatre as an industry. Do you know what changes would be required by this change in the rules?

[itiba]

There's a talk on the new CDM requirements in the upcoming ABTT show in London...hopefully it'll be youtubed as I can't go.

[kerry davies]

The current situation is that event builds already come under CDM but HSE do not enforce as such on events. The biggest part of possible, not definite, changes is if HSE were to ask theatre to use CDM.

 

This consultation itself is about simplifying the existing system for construction work. Our sector has had a "pass" on it for several years and may, or may not, become subject to existing law. It is not new, places like Glasto have been working to a form of CDM lite for a while. I have yet to hear a reasoned argument that it will create real problems for those already using "good practice."

 

The way ABTT have worded that appeal could be taken as; "We now work in hazardous and illegal ways and we are not changing for you or anybody." Event crews don't have a problem with these legal niceties; boots, goggles, gloves, barriers where necessary so why do theatre "professionals"? To claim that scene changers will be forced to wear Hi-Viz vehicle safety measures is just ludicrous.

 

There are valid reservations about CDM use in entertainment but, for heaven's sake, this is not the way to open negotiations with officialdom. Holding a seminar about the consultation after it has closed and before any outcome is known is just silly.

[paulears]

Some theatres do this already for the ins and outs - portable red and white barriers around the trucks, with everyone in hats jackets, boots and gloves - once the dock doors are closed, the they revert back to normal. They have big notices on internal doors leading to the stage - with the "protective clothing must be worn past this point". It doesn't seem to be a problem - and everyone can do it. They have a few spare sets for the visiting production team, and somebody just hands them to people not wearing it!

[itiba]

PSA have made a statement here and have requested comments here but submissions cease on Friday!

[the kid]

Skimming the PSA info and the ABTT info it seems a bit like they are shouting at a river.

 

I am with Paul and what many spaces do, I have always tried to employ a percentage of what is listed already, and I imagine most people will do a bit, boots and vets, or barriers when doing get in, or any number of what are in essence risk assessment criteria.

 

We had this before with those ladders on wheels, and formalising their use because lets face it they are dam weird to everyone else so look risky.

A HGV driver wears a vest when unloading, why cant any tech when unloading?

A builder wears a cap and a vest and boots when building why not us?

 

It is however a case of scale, not much point me wearing a vest when it's just me in a space maybe with 1 other in working light. You could argue that I dont need to wear boots or a hat if I am hanging lights and bounce focusing when I have powered fly bars and lone working.

 

I think what is causing issue is the suggestion that a scene change is a construction - which it is not (also why has it not been mentioned that adequate light should be in existence when constructing).

 

It is what it is HSE are not likely to change much but there is nothing wrong with saying "just CHECK your risk assessments and make sure you are being logical about it"

[Pete McCrea]

I was coming on here with the purpose of seeing whether the PSA link had been posted, and whether people had any comments. I've not had a chance to look through it completely.

 

Could CDM for events be a good thing? I think it could be a good thing. The clients that we enjoy working with and generally are doing the better projects, with realistic budgets, are those working to CDM type arrangements already, so I think we'll see very little change in how we work on those projects. They've got a plan, they've got the right people in place to manage the work, and mean that as a contractor we have clarity of what we need to deliver, and how we need to deliver it.

 

So could it help to level the playing field and remove those people that cut corners, doing it on the cheap, putting peoples lives at risk? Maybe it will also help weed out those that assume H&S is evil, like the authors of the quote at the head of the topic.

 

For those that want to read the HSE Consultation, it is here.

[azlan]

One of the big changes they propose is removing the single ACoP and replacing it with industry specific guidance tailored to the specific needs and risks of different contractors.

 

To be honest, the actual act its self mostly seems to just be saying 'where people from lots of different companies are working together, someone has to overall take charge of the health and safety of all workers on the site' and that h&s should be planned across the whole job, and not left to individual contractors to make sure their little bit is safe.

 

It hardly seems that different to the usual way of doing things to me.

[kerry davies]

ACOPs are simply Codes of Practice that are HSE approved and therefore carry a little more legal weight than COPs. HSE has always said that those doing the job safely are the experts and that they should set the standards. They are removing just the "A" right across their remit where they see self-regulation working and good practice maintained. COPs stay in most cases.

 

The PSA approach (I am no longer directly involved) seems the sensible one. Please don't patronise the HSE with untruths like "theatre is exempt", it isn't. Please don't tell them that their whole raison d'etre, H&S at Work, is beneath your contempt. Do urge them to be a lot more specific about how any changes in enforcement will affect theatre and events.

 

If you are a chancer or a cowboy then be afraid, otherwise keep calm and carry on, you are already doing the business.

[top-cat]

My question is... what does this change? Anything? Surely, if it was dangerous to stage crew / performers / public, it was ALREADY illegal under the Health and Safety at Work Act?

 

Barrier'ing streets. Is that a new thing? Surely, already, the act of running a get-in from the open street should have been risk assessed? And if the risk assessment found that there was a danger to the public by such a get in, and that this risk could be mitigated by barrier'ing off the street, then it should be standard practice already?

 

Hi-Vis on stage? Surely you have an RA for scene changes on stage already? Is there enough visibility to ensure that a member of crew could not be injured in a change over? If not, would a hi vis mitigate the issue? If the answer is yes, then your stage crew should already be wearing hi-vis clothing, it shouldn't need the CDM regulations to change this. The HSE have been perfectly clear - they do understand our need to dress in blacks and keep theatre surreal, they do want to continue promote good quality theatre, but that no amount of theatrical quality can ever stand in front of the safety of the people involved.

 

Everyone is getting all hyped up about CDM, but my own interpretation is that if you are already running a safe operation, nothing will change; and if you are running a dangerous operation, then you were breaking the law already. Have I really misundestood all this?

[azlan]

 

Everyone is getting all hyped up about CDM, but my own interpretation is that if you are already running a safe operation, nothing will change; and if you are running a dangerous operation, then you were breaking the law already. Have I really misundestood all this?

 

From what I can tell, you are basically right, all CDM would mean is that there is a defined lead contractor and designer who is in charge of making sure all contractors and sub contractors (so in a theatre, potentially the venue, venue technicians, touring crew, rigging company, catering, talent, hire companies, electricians etc..) are all working to the same acceptable standards and following common method statements and risk assessments rather than leaving each individual supplier to look after their own h&s