This idea is important because the CDM Regulations represent a non productive burocracy which imposes unnecessary additional cost burden on the construction industry or at least that part of the industry which obeys the regulations. Furthermore it appears far from clear that the CDM Regs have had any positive effect on the reduction of injury and death in the construction industry.
The Construction (Design and Management) Regulations are now in their second iteration which was intended to make them more relevant to the construction industry and less concerned with producing a mountain of paperwork. The special role creatd by the CDM Regs – the CDM Co Ordinator – is in much of the industry seen as an irrelevance. It is however the only position in the construction team which is a legal requirement for most commercial projects; there is no legal requirement to employ a qualified architect or engineer but clients can face criminal charges if they do not employ a CDM-C.
What does he do? He advises clients on their responsibilities under the CDM Regs and on the competence of the design team which has generally already been appointed and probably worked for the client before. Most clients are not interested and resent having to employ him. He fills out online, an F10 form which notifies HSE of a project, in theory even before any real design work is done and by definition before there is even a live project with planning consent. (remember this form filling is a legal responsibility) This is a preliminary notification and there can be many further notifications (by the contractor) as the project progresses. He prepares pre contract information on matters such as site restrictions, clients special requirements, adjoining owners and uses, he should but rarely does take part in the design process to advise on health and safety implications of the design as it progresses. These functions generally duplicate the procedures which most competent professionals in the construction carry out normally. Later in the process the CDM C inspects and comments on the contractor's health & safety plan for the project; again not really relevant when an experienced and competent contractor is employed. Finally the CDM C is responsible for ensuring a health and safety file is prepared and handed over to the client. This responsibility is usually laid off to the contractor with the CDM-C merely acting as the postman.
It may come as a surprise that there are no recognised standards for carrying out this process. Nothing is submitted to HSE or any other body for approval (apart from the F10 form) so no designer, CDM-C or contractor really knows if he has complied with the regulations except of course in the event of some accident or event which might prompt an investigation by the HSE.
CDM-C's defend to the hilt their positions at trade meetings, using the undeniably proper aim of reducing death and injury in the construction industry as justification of their position. All construction professionals have a common moral interest in improving safety and working conditions on sites and they do not need the non productive efforts of CDM-C's. Professionals have a duty to undertake continuing professional development which can include health and safety, the legally imposed CDM-C does not even have to be professionally qualified let alone undertake CPD.
So what if we get rid of these largely derided regulations to which in most cases, lip service only is paid?
Make it a legal requirement for clients to employ professionally qualified designers on all projects (domestic and commercial) over a value of say £100,000. These designers will exercise professional judgement on health and safety considerations in their designs. Contractors taking on this size of project will generally by definition be properly set up and in compliance with workplace and construction site health and safety legsilation. Professionally produced design drawings and contract documentation will provide the relevant information so often duplicated and embroidered within the CDM procedures.
Most contracts under the threshold will not be subject to the current CDM regulations so at that end of the market the situation remains unchanged.
This proposal comes from a qualified designer who undertook Planning Supervisor training after introduction of the 1996 CDM Regs and subsequently upgraded to work as a CDM-C. I have become so disillusioned with the operation of the CDM Regs that I have let my membership of the Association for Project Safety lapse and now decline appointments as a CDM-C