G 10.001 practice policies
Rev 03 [Jan 09]

Preparing Practice Policies

1 Note that there is not a legal requirement to have a CDM policy but there is a duty to have a written statement of policy, organisation and arrangements written down if you have 5 or more employees in the organisation. If all or most of what you do is construction design then it makes sense to consider a formal statement of how you engage with the CDM requirements. This is particularly true because of the amount of information management that is required of you.

2 For advice on Health and Safety Policies you should go to the HSE website at http://www.hse.gov.uk/

3 A practice CDM policy should demonstrate that a design practice:

• a) Is committed to implementing the CDM Regulations;
• b) Is committed to an ongoing learning process;
• c) Treats CDM as part of the design process.

4 It should also contain concise practical advice for designers about how they can satisfy their duties under all the regulations that apply to them including, but not limited to, Regulations 4 to 7 and specifically Regulations 11 and 18. It will also need to deal with the duties of others, especially Clients, for whom designers are often the key resource in respect of health and safety management.

5 Like any other design aid, it should assist designers in acquiring an awareness of CDM, by the development of concise and user-friendly practice policies, containing information which will over time, by continued use, become a natural part of the design thought process.

6 This guidance note gives advice on what a practice policy should contain for it to be effective, ie, one that helps designers to discharge their statutory duties under the CDM regulations.

Content of Practice Policies

Preliminaries

1 It is necessary to demonstrate that the Practice Principals support the implementation of CDM. It could contain a statement to this effect, signed by the Principal with responsibility for CDM.

2 In addition, the policy could clarify:

• a) The level of CDM knowledge that it expects people at various levels in the company to have. For example, it may not expect a draftsman to have the same level of knowledge as a senior engineer; and
• b) Who is responsible for the CDM overview on projects.

Brief overview of CDM

3 There is not a lot to be gained by restating the regulations in the Policy. It is more important to ensure that designers understand the main principles behind the regulations, which are, in order:

a) to make the dangerous non-dangerous, i.e., remove the hazard wherever it is possible to do so; or

b) to make the dangerous less dangerous, i.e., reduce the chances of the hazard occurring; and then

c) to provide sufficient information about residual hazards, to help a contractor to manage the hazard on site;

This can be summarise by the mnemonic ERIC, which stands for Eliminate, Reduce, Inform, Control. Most of the control activity is the responsibility of the Contractor or Principal Contractor.

Technical content

4 The information in the General Guidance Series G 30.001 What Designers Should Know, provides a good starting point for the development of the contents in a practice policy.

5 To help designers gain an awareness of the issues dealt with in G 30.001, practice policies should contain a list of the hazards on construction sites, which a contractor has to control by law under the Regulations that apply to the kind of work that you do. You can find a list of the most usual ones that affect construction work in the INF section of this set of Guidance notes.

6 A simple statement of what hazards exist is of little use, unless designers understand where they could be encountered or how they could be created, because this is not always obvious

7 Within design, choices have to be made. Depending on the choices made, different hazards will arise. For instance designing out manual handling may require the designing in of mechanical handling. It will be necessary for designers to consider the merits of such alternatives.

8 Design includes specification. It is important to remember this when constraining the decisions of any of the project team by insisting on a particular product or process.

Unavoidable hazards

9 Unavoidable hazards are linked to a necessary process and workers can be exposed to single obvious hazards, eg: side slip in an excavation, or combinations of obvious and not so obvious hazards, depending on their work situation. For example:

• a) In an excavation workers are exposed to the obvious hazard of collapse of the sides of the excavation. But, depending on where the excavation is, they could also be exposed to hazards associated with:
  • i. Flooding, in excavations below the water table;
  • ii. Confined spaces in deep and narrow excavations;
  • iii. Hazardous material in contaminated land;
  • iv. Explosions, on sites containing methane, etc.
• b) Operatives installing pipe-work between beams are exposed to the obvious hazard of working at height. However, if the beams are sufficiently close together and are of sufficient depth, they may also be exposed to the hazard of working in a confined space.
  Practice policies should identify this matrix of hazards and present it in an easily understood form. Tabular layouts, which provide at-a-glance guidance are known to be effective.

Hazards created by design

10 When designers specify a construction process, they could be creating a hazard, because the specified process could expose workers to the harmful side effects that accompany it. For example:

• a) Scabbling concrete is accompanied by noise and vibration, which have a chronic effect;
• b) Pile driving, is usually accompanied by noise and vibration;
• c) Using solvent-based paints is usually accompanied by vapours, which may be harmful;
• d) Positioning pre-cast concrete units could be accompanied by workers working close to an unguarded leading edge;
• e) Hand breaking out of piles is accompanied by noise and vibration; etc.

To prevent, as far as it is possible to do so, the creation of hazards by a design, Practice policies should contain a list of proscribed activities, which should be implemented across the whole practice. A traffic light system can help where such processes are listed in the Red section as prohibited in design. Processes that could appear on such a list include:

• a) Continuous-flight augered piling in contaminated land;
• b) Lifting loads over a large radius;
• c) Scabbling concrete, unless it is absolutely necessary for the strength of a joint;
• d) Painting of steelwork on site;
• e) Not allowing adequate working space in an excavation; etc

11 However, it is not sufficient to proscribe processes. Alternative ways of achieving the end result should be provided. Therefore, for each proscribed activity, an alternative safer process should be specified. For example:

• a) Retarding and washing off as an alternative to scabbling;
• b) Using quiet pile driving techniques;
• c) Water based alternative to solvent based paints;

Management of the Policy