The UK’s Construction (Design and Management) Regulations came into force during my career.
My interpretation of the latest Regulations (2015) has sometimes differed from that of EPCM contractors. Six examples come to mind:
1) The Client is usually the most suitable party to produce the “pre-construction information” as they hold the duty to provide it. It needs to be as much as possible specific to the project. Organisations that offer to write this document often lack detailed knowledge of the project and site, which leads them to fill it with generic text taken from other projects.
2) When an organisation is appointed the “Principle Designer”, it must coordinate all designers not just those within its own disciplines. This may include the Client’s process engineers and vendors responsible for designing specialist equipment.
3) The “Principle Contractor” as site manager, prepares the “construction phase plan” which describes the health and safety arrangements for the construction works. They should attach the pre-construction information rather than interpret or rewrite it within their own document. Otherwise key information for “Contractors” will be missed or presented incorrectly
4) Avoid referring to a fenced construction site as a “CDM site” with a “CDM boundary” as this suggests that the Regulations do not apply elsewhere. Instead, describe the site in terms of who manages it.
5) If the Client takes over the constructed assets for commissioning, they should formally end the appointment of “Principal Contractor”. At this point, the “construction phase” has effectively finished, along with the application of the “construction phase plan”. In my view, there is no need to appoint the Client as Principal contractor afterwards.
6) The “health and safety file” should contain only the information listed in the appendix to the Regulations. Many “Principal Designers” try to include all developed design information, which makes the file difficult to produce and use later. Information about operating the installed plant is not required unless it relates to future removal or dismantling. Construction MSRAs (method statements and risk assessments) are not included in the required content.