CDM Regulations 2015 and 2 topical issues · CDM 2015 - The Drilling Industry 1 • Survey with...
Transcript of CDM Regulations 2015 and 2 topical issues · CDM 2015 - The Drilling Industry 1 • Survey with...
Health and Safety Executive
Health and Safety Executive
John Underwood
HSE Construction Division
Construction Sector Safety Team
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?
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?
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
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