Update on HSE evaluation of CDM 2007

Health and Safety Executive

Health and Safety Executive

Update on HSE

evaluation of CDM 2007

Andrew Maxey and

Anthony Lees

Introduction

Background

Process

Key findings

Next steps

Current environment

Recommendations

Conclusion

Background

CDM 1994 based on EU directive

New duties on specific duty holders

2002 started consultation to amend CDM

Baseline Study by BOMEL

CDM 2007 in force April 2007

Prayer debate May 2007

Agreed to evaluate after three years

HSE high-level aims

• Simplifying the regs to improve clarity

• Maximising their flexibility

• Making their focus planning and management to emphasise active management and minimise bureaucracy

• Strengthening requirements re co-ordination/co-operation to encourage more integration

• Simplifying assessment of competence of organisations

Process - Frontline research

• A large-scale survey of duty holders

• Face-to-face interviews with small and one-off clients

• Face-to-face interviews with small contractors

• Key stakeholder interviews

• Influence Network Workshops (provides detailed moderated views)

• Open forums (large informal events seeking key CDM issues)

• Review of CDM-related information and accident data

Key findings - Research

• CDM 2007 has gone long way to meeting objectives but still concerns

• level of agreement re HSE five aims far more positive than for CDM 94

• level of agreement re construction design, management and site practices more +ve

• Benefits rated as higher than costs

• Interpretation of ACoP causes problems

• Industry practice significant influence

Aim 1 - clarity

3.29

3.42

3.35

3.3

2.96

3.94

3.89

4.07

3.89

4.03

3.63

0 1 2 3 4 5

All

Clients

Coordinators

Designers

Principal contractors

Contractors

CDM 1994

CDM 2007

Mean level of agreement (1 = Strongly disagree to 5 = Strongly agree)

(0.0%)

(0.0%)

(0.0%)

(2.6%)

(1.8%)

(Statistical significance)

Aim 2 - flexibility

3.43

3.52

3.63

3.31

3.11

3.97

3.99

4.19

4.00

4.12

3.44

0 1 2 3 4 5

All

Clients

Coordinators

Designers


Contractors

CDM 1994

CDM 2007


(0.0%)

(0.0%)

(2.1%)

(15.0%)

(2.1%)


Aim 3 – planning/management

2.12

2.35

2.12

1.99

2.02

2.81

2.94

3.05

2.80

2.80

2.12

0 1 2 3 4 5

All

Clients

Coordinators

Designers

Principalcontractors

Contractors


3.47

3.59

3.57

3.48

2.98

4.04

4.03

4.26

3.89

3.97

3.88

0 1 2 3 4 5

All

Clients

Coordinators

Designers

Principalcontractors

Contractors


CDM assists in minimising bureaucracy CDM assists in managing health & safety

(0.0%)

(0.0%)

(0.0%)

(2.6%)

(1.8%)

CDM 1994

CDM 2007

CDM 1994

CDM 2007

(0.0%)

(3.7%)

(1.2%)

(0.4%)

(5.8%)


Aim 4 – coordination/cooperation

3.21

3.42

3.26

3.14

3.00

3.87

3.97

4.07

3.68

3.90

3.59

0 1 2 3 4 5

All

Clients

Coordinators

Designers


Contractors

CDM 1994

CDM 2007


(0.0%)

(0.0%)

(0.3%)

(4.4%)

(0.4%)


Aim 5 - competence

3.09

3.24

3.03

3.16

2.93

3.85

3.81

4.15

3.62

3.95

3.47

0 1 2 3 4 5

All

Clients

Coordinators

Designers


Contractors

CDM 1994

CDM 2007


(0.0%)

(0.0%)

(0.3%)

(5.7%)

(0.4%)


CONIAC WG terms of reference

• Review material prior to CDM 2007 to familiarise with background

• Comment on pilot findings re evaluation methodologies

• Provide industry-led stakeholder views (high level rather than detail) on:– degree to which aims of CDM 2007 met– perceived adequacy of existing HSE and industry

guidance and ACoP– need for amendments to existing regs, ACoP, guidance

• Provide interim reports to full CONIAC

• Members to consult stakeholders in the groups they represent and seek consensus of views from that group, reflecting differences where a consensus is not reached

Key findings – CONIAC WG

Agree clearer and flexible, narrowly agree over planning and co-operation, disagree that has simplified assessment of competence

Thus competency a strong theme

Improvement on CDM 94 but more guidance needed

Bureaucracy is still too much

Suggestions to improve co-ordination

Other significant concerns

Overall evaluation findings

Frontline research

CONIAC WG

Su

rvey

Sm

all

on

e-off

clie

nts

Sm

all

con

tracto

rs

Sta

ke

hold

er

inte

rvie

ws

Influ

en

ce

w

ork

sho

ps

Op

en f

oru

ms

All

du

ty h

old

ers

Tra

de u

nio

ns

Clie

nts

Desig

ners

CD

M-C

s

Con

tra

cto

rs

Pri

ncip

al con

tracto

rs

Aim 1 Clarity

++ + ++ + N - ++ + N + ++ + +

Aim 2 Flexibility

++ + + + N - + + N - ++ + +

Aim 3 Planning/mangt

+ ++ N - + - + + - + ++ - +

Aim 4 Coord/coop

++ ++ + + + - + + N + N N -

Aim 5 Competence

++ N + - N - - - N - + - -

++ Very positive N Neutral/mixed - Negative + Positive -- Very negative

Overall key findings

• CDM 2007 has gone a long way to meeting its objectives - improvement on CDM 1994

• Still concerns (competence, paperwork and co-ordination)

• Few calls to change the regulations - interpretation of ACoP, more guidance

• Industry practice a significant influence on how the construction industry implements CDM 2007

• Other significant issues (disconnect design/ construct, risks at design stage, late appoint)

• Whilst there was a cost impact of CDM 2007, benefits rated as being higher than the costs

Next steps

Paper to CONIAC July 2011

HSE Board October 2011

Timing constrained by external factors eg review of regulations

Implications for industry guidance

Current environment

Government regulatory policy

Uncertainty over EU position

Impact assessment

Managing industry expectations

Recession

Recommendations

No case for wholesale change

Focus on balance between ACoP/guidance

Focus on competence paperwork

Remit research report to CONIAC WG

Conclusion

Context of evaluation

Key findings of research and CONIAC WG

Recommendation to remit to CONIAC WG

EU and UK regulatory policy

Report to CONIAC in July

HSE Board in October

Update on HSE evaluation of CDM 2007

Documents

Transcript of Update on HSE evaluation of CDM 2007