G 10.003 - Health and Safety File

Design Guides

G 10.003 Health & Safety File
Rev 03 [Jan 09]

Change to CDM Documentation

1. CDM 2007 applies to all construction work. Construction work is widely defined in the Regulations at Regulation 2. The Regulations apply to demolition (which was treated separately under CDM 1994 but is now included in the general definition of construction work) and domestic work (which is a special case, see below)

2. There are three tests:

a) Test 1: Is it construction work? If it is then CDM 2007 applies. The definition is very wide so look out!
b) Test 2 Is it domestic work? If the answer is “Yes” and the project client is the owner or a near relative of the owner then they are not at work and CDM cannot apply to them because it is secondary legislation under an Act that only applies “at work”. The Regulations deal with this situation by stating that there is no CDM Client. All other duty holders who are at work for the householder must fulfil their CDM duties. If there is no CDM Client then there is no appointment of CDM Co-ordinator or Principal Contractor and consequently no statutory CDM Documentation. There is still a duty on those at work to work safely, so other documentation will be expected such as method statements, risk assessments, safe systems of work.
c) Test 3 “Will it last over 30 days or 500 person days?” (See Regulation 2 (3)). If the answer to this question is “Yes” the Client must appoint a CDM Co-ordinator and Principal Contractor. They in turn have duties. The CDM Co-ordinator must ensure the HSE is notified (See Schedule 1 to the Regulations or use Form 10 from the HSE website), manage the collection and communication of the preconstruction information and prepare a new or modify an existing Health and Safety File. The Principal Contractor must prepare the Health and Safety Plan. These duty holders have other responsibilities but it is in relation to the statutory documentation that they are introduced here.

The statutory documents in overview

Form 10

3. This form can be used and submitted to the HSE, or Office of the Rail Regulator for rail projects, or you can use your own format so long as the necessary information is included.

The Health and Safety File

4. The purpose of this document is to provide information for those working on the structure in the future. It will provide the core of the information provided to designers and contractors appointed by the Client on subsequent work carried out on a structure. This means it makes sense for it to reflect the content of the pre-construction information that has to be issued prior to any project. A helpful list of preconstruction information is to be found at Appendix 2 to the Approved Code of Practice to the Regulations.

Preparation of the File is the responsibility of the CDM Co-ordinator. Ownership rests with the Client who must keep the document updated, for instance following minor non notifiable modifications or events that could affect the structure such as floods or vehicle strikes. Designers must provide the necessary information for this document and should expect to ask to see an existing File for structures that have been built or substantially altered since 1994.

The Health and Safety Plan

5. The Health and Safety Plan is a Safety Management System (SMS) for the Project and is the responsibility of the Principal Contractor, who is in charge of the construction phase of work.
Designers must provide information via the CDM Co-ordinator (or other wise by agreement) to include in this management system.

6. When sorting out where information needs to be sent, remember:

The Plan is for the Present Project

The File is for the Future Facilities Management/Asset Management

Also consider that some information may need to go to both Plan and File.

Documents on all projects

Preconstruction Information

7. For all projects, notifiable or not, there is a duty placed on the Client to provide information to all designers and to contractors appointed by the Client. It is very common for the designer to be required to assist the Client in scoping out what is needed in this preconstruction information that will add value to the project.

8. Remember that it is not sufficient to state that a site investigation is needed. You must explain what it is that is being researched and why a practical site investigation is required. For instance you may need to have structural information about existing or adjacent structures or information about ground water or soil contamination. All this information will influence the design choices available to you. Better quality information at an early stage provides more cost and programme certainty for clients as well as reducing the risk of harm.

9. Remember, the Approved Code of Practice to CDM 2008 has a useful list of preconstruction information at Appendix 2.

Design risk management

10. Designers are required to eliminate hazards or reduce risks from hazards that cannot be eliminated. They will not be able to eliminate all risks and the choices they take to eliminate or reduce one hazard will probably introduce different hazards and/or different levels of risk. They should keep records of their thought processes relevant to the structure and project.

11. The competence and particular skills of contractors will be critical in respect of the level of information and the kinds of assumptions that it is reasonable for designers to make. For instance a designer will not need to tell a steel erector who will be constructing a steel frame building that work at height will be involved and is dangerous. Such information could bury important special information in too much detail. Designers will not always be able to be involved in contractor selection. This kind of assumption may need to be recorded and owned by the Client or others who have responsibility for later contractor selection.

12. Designers will need to be able to think forward to consider how structures are to be built, maintained, used, modified and demolished/dismantled. Asking questions such as “What will be difficult on this project?” or “How will access for maintenance be managed?” are likely to prove much more fruitful than any number of numerical spreadsheet of limited value.

The Health and Safety File and Designers

13. File preparation is a statutory duty placed on CDM Co-ordinators. Designers will be selecting, specifying and otherwise taking decisions on what is to be built by contractors. Much of the output of their decision making will be of importance to CDM Co-ordinator for inclusion in the File.

14. It is very important to clarify early on the content of the File and how information is to be shared between members of the Project Team. The following section lists some of the File elements that could be considered by designers. Remember that critical information needs to be presented in ways that those coming to the project or structure later would find it, even if they were not looking for it.

What the Health and Safety File should contain

15. The file should contain enough information to allow future hazards to be identified and the risks from these hazards managed. Typically, the File should contain at least the following:

General details

16. This section is very basic and should form an introduction to the file. It should contain:

(a) The address of the premise;
(b) The name of the Building/Asset Owner1;
(c) The names and addresses of the CDM Team eg-
- (i) The Architect;
- (ii) The Structural/Civil Engineer;
- (iii) The Geotechnical or other specialist Engineers
- (iv) The Quantity Surveyor;
- (v) The Building Services Engineer;
- (vi) The CDM Co-ordinator;
- (vii) The Principal Contractor; and
- (viii) All sub-contractors.
- (ix) Any other party who has duties under the CDM
  - 1. Updated every time the building changes ownership.

17. In addition, there should be no confusion about whether the File is up to date, why it was revised and how many pages it contains.
General arrangement drawings

18. Sufficient general arrangement drawings should be provided, to ensure that subsequent designers are able to abstract information about:

(a) Location and footprint, especially in relation to adjacent features
(b) Architectural form;
(c) Structural layout [including foundations];
(d) Materials used: type, strength;
(e) Any retained features such as encapsulated material, existing structures etc
(f) Layout of building services, internal and external including:
- (i) Drains;
- (ii) Mechanical plant and ducting;
- (iii) Electrical wiring;
- (iv) Plumbing; and
- (v) Utilities: gas, electric, etc.

Basis of design statements

19. This information is intended to allow subsequent designers to identify and assess any hazards associated with the building form and its finishes, to allow them to design to minimise the hazards. It should, at least, contain the following:

Basis of civil and structural design

20. This is provided by the Geotechnical/Civil/Structural Engineer, to allow subsequent designers to specify processes, which will not release the potential for harm held in the existing structure. This should include information about:

(a) The basic structural form, eg, a pin-jointed steel frame with bracing;
(b) The methods of structural analysis, including the names of any computer programmes used;
(c) How the characteristic loads [occupancy and environmental, eg wind] were derived. List the British or European standards used;
(d) The wind loads: basic wind speed used and a brief resumé of how the building was defined for calculating wind coefficients;
(e) How the structural elements in the structure were designed. List all standards [with their date] that were used;
(f) Any deviations from the requirements in the listed standards;
(g) Critical components and how they work, eg, fixing of pre-cast walling;
(h) Requirements for and provisions for future maintenance, eg, repainting steel, resurfacing roads;
(i) How the calculations may be obtained, eg, file reference numbers;
(j) How the building could be demolished or dismantled.

Basis of design for external services

21. This is provided by the Designer of the services, to help designers to minimise the risks associated with working on or close to existing services. This should provide information about:

(a) The general form of the ground that the services were installed in, including any areas of significant hazard, eg, made ground;
(b) The location of services, referenced from a fixed point on the building;
(c) The average depth of the services and utilities and their maximum depths;
(d) Types of backfill used
(e) For drainage runs, the following additional information would be useful:
- a. The falls of the drains;
- b. The length, size and unit weight of the pipes;
- c. The location of any drains, which carry highly hazardous waste from, eg, pathology laboratories, petrol interceptors, etc;
- d. A manhole schedule giving diameters, depths and form of access arrangements, eg, mild steel ladders;
- e. Provisions for future maintenance.

Basis of architectural design

22. This is provided by the Architect, to allow subsequent designers to specify processes, which will not release the potential for harm held in the building fabric. This should, at least, include information about:

(a) Partitions: generally materials and finish 2;
(b) Fixtures and fittings: materials, eg, MDF;
(c) Ceilings: materials and type;
(d) Paint: generally type, location and CHIPS data sheets/COSHH risk assessments 2;
(e) Roof assemblies: materials and where applicable non-fragile life;
(f) Glazing: type, weight and its location;
(g) Adhesives: general type, location and CHIPS data sheets/COSHH risk assessments 2;
(h) Provisions for future maintenance, eg, cleaning of glass, gutters, external painting, including assumptions about how it would be carried out;
(i) Provisions for demolition and dismantling;
- 2. Including any deviations from the generality and their locations.

Basis of design for building services

23. This is provided by the Designer, to allow subsequent designers to minimise the risks associated with the work required to maintain/supplement existing services. This should include information about the following:

(a) The location of services, referenced from a fixed point on the building;
(b) The average height of the services in an area and their maximum and minimum heights;
(c) The general maximum length, size and unit-weight of service run components;
(d) A schedule of deviations from the generality of (c) and their locations;
(e) Significant hazards associated with pieces of equipment, eg, high voltages, high pressures, high temperatures, and their locations, etc;
(f) Provision for future inspections and maintenance and assumptions about how they would be carried out, eg, from a step-ladder; and
(g) How the services could be dismantled.

Other relevant information

24. Site specific hazards which existed when the project was executed and which will also be highlighted in the Health and Safety Plan, for example, this may include:

(a) Site constraints, eg, delivery times, vehicle size restrictions, limitations on working hours, restrictions on generation of dust, etc;
(b) Peculiar local permissions, eg, work close to railways, canals, trunk roads or on listed buildings;
(c) Stability of adjacent structures;

25. Drawing schedules listing the working drawings that were issued and the address from which they would be available. The drawings should be as-built drawings.

26. File revisions, which should be updated every time work is carried out, which changes either the fabric or the form of the building and its associated services. Superseded parts of existing files should never be left in a state which could cause confusion about their status.

Length and format of the File

27. The File is owned by the Client who will have responsibility for keeping it up to date. The Client will need to be able to use it for management of the structure for many years. Its length and format must be decided by the Client on advice from his expert Team.

28. For major retail parks it is sensible for the File to be a detailed, electronic structure management system. For small buildings it is more likely to be a paper based document that is quality controlled by nominated people on the Client team. For a small building the document should be about 24 pages.