What is CDM 2015?
There has been a lot of discussion about CDM in the event industry press following the Health & Safety Executive (HSE) 2015 update of one of their key construction regulations and the stipulation that the events industry needs to ensure that they work in compliance with them.
Safety regulation is always a fluid process and the events industry has been working closely with the HSE to clarify and define exactly how the regulations should be implemented due to the practical differences between traditional construction sites and temporary event sites.
The Construction (Design and Management) Regulations 2015 (CDM) cover the management of health, safety and welfare when carrying out construction projects.
CDM aims to improve health and safety by setting a project management structure that allows people to:
- Sensibly plan the work so the risks involved are managed from start to finish
- Have the right people for the right job at the right time
- Cooperate and coordinate your work with others
- Have the right information about the risks and how they are being managed
- Communicate this information effectively to those who need to know
- Consult and engage with workers and contractors about the risks and how they are being managed
From 2015, the HSE stipulated that the build and dismantle phase of an event can now be classed as construction work if it meets the criteria set out in the regulations.
In regulation 2 the definition of ‘construction work’ is described as:
(a) the construction, alteration, conversion, fitting out, commissioning, renovation, repair, upkeep, redecoration or other maintenance (including cleaning which involves the use of water or an abrasive at high pressure, or the use of corrosive or toxic substances), de-commissioning, demolition or dismantling of a structure;
(b) the preparation for an intended structure, including site clearance, exploration, investigation (but not site survey) and excavation (but not pre-construction archaeological investigations), and the clearance or preparation of the site or structure for use or occupation at its conclusion;
(c) the assembly on site of prefabricated elements to form a structure or the disassembly on site of the prefabricated elements which, immediately before such disassembly, formed a structure;
(d) the removal of a structure, or of any product or waste resulting from demolition or dismantling of a structure, or from disassembly of prefabricated elements which immediately before such disassembly formed such a structure;
(e) the installation, commissioning, maintenance, repair or removal of mechanical, electrical, gas, compressed air, hydraulic, telecommunications, computer or similar services which are normally fixed within or to a structure.
In practical terms this means that most event projects will fall under one of these descriptions, with the exception of some small scale events where no set or rigging or any other item that could be considered a ‘structure’ is being installed. If your project falls under CDM legislation then your client, project management and production teams will need to ensure that their planning, paperwork and project organisational structure are in line with these regulations.
How is CDM applied in the events industry?
The HSE released CDM guidance for the events industry at the end of 2015 to enable better understanding of how CDM should be applied.
All event projects should now follow construction health and safety considerations laid out within CDM, including compiling the supporting documentation. This should be implemented from the initial project conception in order to ensure that every element is planned with safe working practices and welfare (of anyone affected by the works: crew, artists, clients, audience, visitors, the public, stakeholders etc.) in mind.
In many areas of the industry thorough H&S management and documentation has been a ‘bolt on’ consideration before going live, or carried out only at the request of certain venues or local authorities, however much of the information contained in a traditional ‘event bible’ or ‘event management plan’ is transferable into CDM paperwork.
The HSE want to make sure that:
- People with the sufficient skills, knowledge and experience are being employed for each role; no cutting corners for cost savings, suitable resources (i.e. time and money) allocated for each discipline
- Each project phase is planned carefully in advance
- There is clear communication between contractors and the project team during the planning stages; sharing of vital information, cooperation between each department to design and construct a safe event, consultation with contractors to ensure expert advice is shared and considered
- There is clear communication between contractors and the project team during the construction phase; sharing information, alerting each other to site specific safety issues, highlighting changes in process and amending method statements if needed
- The welfare of those working on and affected by the works is protected
- Risks are reduced or eliminated so far as is reasonably practicable
- Concise and relevant paperwork is written, rather than copy and paste from event to event and/or many pages of irrelevant information
“The objective of CDM 2015 is to reduce the risk of harm to those that have to build, fit out, use, maintain and take down structures.” – HSE
It is important to remember that structures can be anything from a small exhibition stand to a 4000m2 circus big top.
How do I run a CDM compliant project?
If your organisation already produces safety plans & risk assessments for the build & dismantle phases of your project then you are probably already well on the way to being compliant to the new regulations.
You will need to supplement your existing paperwork with a few additional pieces of information and ensure that you have nominated suitable people into CDM roles on the project.
- Is your project notifiable to the Health & Safety Executive?
- Are the following roles clearly defined on the project and is everyone aware of their duties & responsibilities?
- Principal Designer
- Principal Contractor
Alternatively are the responsibilities of the following roles clearly communicated and handed over to a project team by the client? See discharging CDM duties.
In many event and entertainment workplaces the same organisation may fulfil a few of these co-ordinating roles, for example when a client employs a production company with in house departments covering production, design and set build.
The HSE has provided a useful organagram showing how responsibilities may be determined for a green field festival project.
- Have you supplied your contractors with site and project specific pre-construction information ?
- Have you created a construction phase plan?
- Has the Principle Designer passed on the health and safety file to those that are running the ‘live’ phases of the event?
- Have you ensured that all of your contractors have the correct skills, knowledge and experience to carry out their roles (through training records, previous references etc.) and have submitted suitable, event specific risk assessments & method statements?
How do I use Event Safety Plan to write my CDM documents?
Event Safety Plan has templates available that can be used for both pre-construction and construction phase plans, and information about how to build a health and safety file, here is a step by step walk through creating your CDM paperwork.
- Start a New Project
- Check to see if your project is Notifiable, if it is then inform the HSE
- Prepare your Pre-Construction Information and circulate it to your contractors. Depending on the circumstances, time frame and information available this could be contained within a brief or tender document, or it may be a draft version of your Construction Phase Plan.
- Prepare your Construction Phase Plan.
- Navigate to the Safety Plan Sections templates page and the CDM Pre-Construction Information / Construction Phase Plan template.
- Add all the headings that you feel are relevant to your project
- Navigate to each heading and enter information about your project and how you intend to manage it
- Navigate to the Risk Assessments page and write or duplicate the risk assessments relevant to your project from a previous project
- Review each of your contractor’s safety information (that they have sent you in response to your Pre-Construction Information) and update your safety plan headings if necessary.
- Export the plan – this is your CDM Construction Phase Plan which should be shared with the client, your contractors and other relevant parties eg. the venue.
- Prepare your Construction Phase Plan.