The CDM 2015 Regulations have had limited impact on the construction industry and no apparent impact on its accident rate.
That’s the key finding of a joint survey carried out by Construction Manager and Health and Safety at Work, the magazine of the International Institute of Risk and Safety Management.
The survey suggests that working methods established under CDM 2007 and CDM 1994 have proved remarkably resilient, and the principles of CDM 2015 are struggling to take root.
“CDM 2015 hasn’t led to a step change or resolved the issues in CDM 2007,” said Paul Reeve, executive director of the Electrical Contractors’ Association (ECA). “In terms of the principal designer, it seems to be business as usual.”
Recurring themes in comments from survey respondents were that:
Less than half (46%) of respondents rated today’s compliance with CDM 2015 as good or excellent, compared to the 53% who thought that about CDM 2007. Among the 106 members of the Association for Project Safety (APS) in the sample, there was more scepticism: the recalled compliance rate under CDM 2007 was 56%, while current compliance was put at 43%.
Overall, only one in four respondents (24.5%) thought today’s principal designers were following the CDM 2015 rules, such as coordinating other designers and subcontractors on safety issues; slightly more (28%) thought that CDM 2007 procedures were being applied on current projects, for instance the CDM adviser writing the construction phase plan; and 39% thought that aspects of both regimes were used in practice.
Respondents’ views on who had fulfilled the role of principal designer suggested that responsibility had been spread fairly widely, with architects, engineers, clients and contractors all taking on the role.
However, the professional group that emerged as most likely to take the role were “CDM advisers” acting on behalf of design teams – in reality, former CDM-Cs with a different job scope and appointment terms.
This combination was selected by 26% of the sample as occurring “most of the time”, while CDM advisers taking a slightly less hands-on role advising principal designers was viewed by another 19% as happening “most of the time”.
Commenting, Reeve said “about a quarter are behaving in the way the regulations intended, and three quarters are behaving in the way they did previously, by pulling in consultants from the safety arena”.
Martin Cox, head of CDM at construction consultancy Pellings, said the survey confirmed his view that CDM 2015 is business as usual. “I’m working for architects as a CDM adviser – in reality they don’t do very much [on safety]. Very few take on the role as intended
Reeve added: “The survey shows that the HSE can no longer leave the issue to ‘market forces’. It is saying that we’re not adding to health and safety performance. It might be helping some clients, but it’s not creating step change improvements in health and safety.”
The survey invited respondents to pick three aspects of CDM 2015 that were “working well”, although the feature that gained most support was “none of the above”.
In order of support, the principal contractor’s construction phase plan was seen as having a positive impact (29%), followed by clients’ compliance with F10 notification requirements (26%), and the client’s pre-construction information (17%).
Least support was given to the principal designer’s coordination of other designers or subcontractors (7%), the principal contractor’s duty to consult and engage with workers (12%), and liaison between the principal designer and principal contractor (13%).
On CDM 2015’s impact on projects in the domestic sector, where only those with experience of such projects responded, 62% suggested there had been little impact, although 38% thought there had been a positive effect.
Although presented as a less radical update than CDM 2007, the CDM Regulations 2015 amounted to a stealth revolution designed to re-write safety management on construction projects.
Foremost among the reforms was the HSE’s decision to challenge the way safety had been siloed into a specialism for CDM coordinators.
Instead, it sought to repatriate risk to where it belonged: to the designers who influence a project’s risk profile from the outset, and the clients who create the working conditions for everyone else. In the process, it undermined one professional group – CDM coordinators – transferring many of their responsibilities to “principal designers”.
It also declared war on “competence” and multiple safety accreditations, in part by removing the Approved Code of Practice (ACoP) which had also fostered a line-by-line approach to compliance.
It also dealt with a requirement to bring the UK’s regulations into line with the EU’s Temporary or Mobile Construction Sites Directive by explicitly creating duties for domestic clients by transferring these duties to the principal contractor.
Finally, it sought to ratchet up compliance on smaller sites by extending the need to draw up a construction phase plan.
There were 310 respondents to the survey, with the majority working in safety-related roles. They included 149 members of IIRSM, 212 members of IOSH, 106 affiliated to the Association for Project Safety, and 67 members of the Chartered Institute of Building.
In terms of day-to-day roles, 105 acted as CDM advisers or consultants, and 89 operated in general health and safety roles.
There were also 36 construction managers without a safety specialism, and 18 “designers”, members of the RIBA, Institute of Civil Engineers, and Institute of Structural Engineers. Most of the respondents had extensive experience of CDM 2015: 73% said that they had been involved in more than 10 projects in the past two years, while 16% had been exposed to five to 10 projects.
Main image: Sandra Cunningham/Dreamstime.com