If you own or run a domestic electrical installation business and haven’t created a construction phase plan in the last 9 months you might unknowingly be breaking the law!
In April of last year, the new Construction Design Management (CDM) Regulations were introduced to the help increase the standards of health and safety on domestic projects. For many of you working on domestic projects, the most significant change to your daily routine will be the requirement to create a construction phase plan for every project, no matter how big or small.
The main focus of the construction phase plan is to record the arrangement for managing significant health and safety risks onsite, and how you plan to communicate those arrangements and who is responsible for updating and delivering health and safety onsite.
Why have these laws been introduced?
The previous, 2007 version of the CDM regulations exempted domestic clients/homeowners from most CDM obligations. This meant that whilst you had an obligation to ensure safety of your jobs, there was no requirement from the homeowner to ensure you were working safely, and thereby checking you were managing risks onsite. As a result, whilst larger UK projects saw their incident rates fall dramatically since 2007, smaller domestic projects were now accounting for a majority of all accidents.
HSE have since implemented new CDM regulations, which removed the client/homeowner exemption for domestic projects, and transferred the obligations to the contractor. On top of this, they’ve also removed the role of the CDM coordinator and transferred this responsibility to a new role called the principal designer.
Why it’s critical to understand your role on each project
Under the new CDM regulations, your role will determine whether you need to create a new construction phase plan, a health and safety file or simply help to contribute to these documents.
Principal Designer:
A principal designer is a designer appointed by the client to take control of the pre-construction phase of any project involving more than one contractor.
Previously, the CDM coordinators role, this duty has now been handed over to the designer who needs to plan, manage monitor and coordinate health and safety in the pre-construction phase of the project.
Principal contractor:
By law, if there is more than one contractor on site, the client will need to appoint a principal contractor. This company or person will be responsible for managing the health and safety of all workers on site and expected to create a health and safety file for the project, which will include:
- Construction phase plan
- Risk Assessments of all contractors
- Equipment instructions for anything you or other contractors install
- As built drawings
- Site induction forms
- Site visit sheets
The principal contractor will also need to notify HSE of any construction work if:
- Your project lasts longer than 30 working days and have more than 20 workers working at the same time at any point on the project or
- Exceeding 500 person days
This notification called an F10, need to be included in the H&S file, along with any updated H&S file information introduced during the project and finally handed over to the client at project completion.
Subcontractor:
If there’s more than one contractor on site, and working under an appointed principal contractor, your work daily routine will essentially stay the same. The subcontractor will be expected to coordinate activities with others in the project team and comply with directions given by the principal designer or principal contractor. You may also be asked to help develop the construction phase plan, provide equipment instructions and develop your own risk assessments for the principal contractor.
Sole contractor:
This will be the biggest change for many domestic electrical installation businesses. If you’re the sole contractor on the job, you’ll now by law need to create a construction phase plan, no matter how big or small the job is. You don’t need to go overboard, but you do need to spend some time considering the risks onsite. The HSE provides some free resources on how to effectively manage this additional construction phase plan requirement, which you can see here.
If you haven’t considered Health and safety previously, now is the time to look into solutions for your business - new sentencing guidelines threaten maximum fines up to £20 million together with prison time for directors who fall short of these requirements.
This article is a contribution from Alex Green, CEO of HANDS HQ.