Health and Safety Executive

Health and Safety Executive

John Underwood

HSE Construction Division

Construction Sector Safety Team

john.underwood@hse.gsi.gov.uk

CDM Regulations 2015

and 2 topical issues

30 mins

Geotechnica 9th July 2015 Warwick

Drilling – Current Issues

• Drill tubes – specification & quality

• Geological gas under pressure – flammable

/ toxic / asphyxiant

New tubular drill rod

with welded fitment

Magnetic particle

NDT examination

New drill rod

Magnetic particle NDT inspection

of new drill rod

• Weld between tube & fitment

cracked

• Alloy steel requires complex

welding & heat treatment

process

How can this happen?

• Off the shelf product -v- made to order

• Purchaser specification -v- leave it to

supplier

• Brand new tube direct from mill -v-

second hand oil industry tube

• Declared second hand material -v-

remanufactured tube (unused order

repurposed)

• Conclusion – buyer to specify

Have you come across this

issue?

Scope for industry guidance?

john.underwood@hse.gsi.gov.uk

Drill rod specification & procurement

Gas release under pressure

• Incident – gassing for several months

• Bored piling operation into sandstone at 20m

• Fire & explosion

• Nearby gas main

• Coal field with surface outcrops

• Nearby old workings (pithead > 1mile)

• Nearest seam +100m depth

• High organic strata

Gas release under pressure

• Piped gas - struck during drilling -v- leak

• Biogenic gas from high organic content strata

• Coal / Mine gas

• Gas in old workings

• Gas evolved due to underground

combustion

• Gas diffusing from unworked coal

• Oil bearing strata (unplugged borehole?)

Underground reservoir

Schematic borehole

Impermeable - eg clay

High organic content - eg peat

Porous - eg sand & gravel, sandstone or

fissures, faults, disturbed ground,

mine workings, etc

Organic – coal, oil, etc

Gas supply pipe (leak -v- strike)

Gas emission flow rates

• Size of reservoir

• Number of escape routes

• Proximity of escape routes

• Rate of recharging

• Change in water table

• Change in atmospheric pressure

• Applies to all drilling &

piling near coal assets

• Leans toward pit-head

works

• No direct application to

biogenic gases

• Scope for BDA / FPS

guidance ?

Coal Authority

Guidance 2012

Equipment & Systems of Work

• Desk study of area to be drilled

• Services location

• Coal Authority permission if drilling on their land OR

into their assets

• Gas monitoring for flammables & asphyxiants

(including methane / CO2 / CO)

• Rig suitable for zone = withdraw option

• Rig not suitable for zone = abandon

• (Design for gas handling / dispersion / collection)

Gas strikes during drilling

Have you come across this issue?

Scope for industry guidance?

john.underwood@hse.gsi.gov.uk

JUCDM 2015

Does the drilling industry have

anything to fear from CDM 2015 ?

Construction Design & Management

Regulations (CDM)

CDM 1994

CDM 2007

CDM 2015

CDM 1994

Const Health

Safety Welfare

Regs 1996

Prior to 1994 there were no

dedicated construction

management legal

requirements

EU

WAH

Revise to improve / simplify / align to EU

Consultation - 1400 industry responses

Outline of main changes

• Simplified structure

• Client – greater responsibility

• Domestic client exemption – removed

• CDM co-ordinator role – removed

• Principal Designer role (PD) – introduced

• ‘Competence’ – clarity added

• Notification is a stand alone requirement – not trigger

point for additional roles / duties

• Construction phase plan for all projects

• Threshold for appointments = more than 1 contractor

Guidance Package

• ‘L’ Series guidance (L153)

• Possible ACOP in due course

• 6 CONIAC industry guides –

endorsed by HSE

• New CDM 2015 HSE website

• ‘Have work done safely’ leaflet

for small commercial clients

• Template construction phase

plan

• Smartphone App – Construction

Phase Plan for small projects

Stress these changes:

• PC – PD symmetry

• Amended notification threshold

• 30 days + >20 workers / 500 person days• (Note 500 / 20 workers = notify >25 day project)

• Construction Phase plans on all projects

• Site Health & Safety File on all multi contractor projects

• Formal co-ordination threshold lowered

• More than one contractor = PD & PC

Stress this:

Client / Principal Designer / Designer

• Responsible for Pre Construction Information

Principal Contractor / Single Contractor Project

• Responsible for Construction Phase Plan

Project Start

Project End

Pre construction information

Construction phase plan

Domestic Clients:

A domestic client will only be liable under CDM

if they reject sensible H&S standards or

impose poor standards

Client duties automatically pass to the:

• First contractor, or the

• Contractor in charge

Alternatively the client may arrange by

agreement for the Principal Designer to take

on the client’s duties

CDM 2015 - The Drilling Industry 1

• Survey with tape measure is not construction

• Intrusive survey with spade, excavator, drill rig etc is

construction and CDM applies

• Be aware that first or main contractor on site could

be expected to take on Principal Contractor role

• Be aware that assessment of site, provision of

drilling plan, providing eg ground capacity data may

be classed as design work under CDM

• Be aware that the first or main designer involved

could be expected to become Principal Designer

CDM 2015 - The Drilling Industry 2

Be prepared to add to site Information:

• Pre construction information

• Construction phase plan

• Site health & safety file

Be prepared to work with and advise: the client,

principal designer, principal contractor

Better coordination = better organised project

and fewer problems. Please play your part but

don’t get taken for a ride – read the Regs !

Conclusions

• CDM 2015 is easier to understand

• May allow greater flexibility – who does what

• Guidance says small & simple = s&s paperwork

• The drilling industry should readily adapt to

significant changes that CDM 2015 introduces

• Simplifying CDM means guidance becomes

more important

• HSE encourages specialist sectors of the

construction industry to produce guidance

JU

Thank you for listening

john.underwood@hse.gsi.gov.uk

CDM 2015 in force from 6/4/15

Transitional arrangements to 6/10/15

For multi contractor projects starting before 6 April 2015 and

continuing beyond:

• Where no CDMC or PC already appointed the client

must:

– Appoint PD and PC if the construction phase not

started

– If construction phase started, appoint PC

• Where CDMC had been appointed:

– the client must appoint PD within 6 months of Regs

coming into force

– CDM-C’s duties (CDM2007) continue to apply until

PD is appointed

What makes things work?

• Sensible client

• Permanent works designer willing to engage

• Rigorous contactor

• Temporary works designer who understands

sequencing & systems of work

• Investment in understanding the ground, and

existing structure/s

• Sensible timescale, sequence and method

• And legislation that encourages all this

What stays broadly the same

• Application to all construction projects

• Role of the Principal Contractor

• Part 4 technical standards for construction

sites

• Schedule 2 – welfare requirements

• Co-ordinators for health & safety both

before and during the construction phase

Competence

Getting the right people for the job

• Individuals

– Skills, Knowledge, Experience and Training

– Not about card schemes

• Body corporate

– Organisational capability

– Policies, structures, safe systems in place

SKET KETS SNTE TESK SKTE TEKS Competence