CDM2015 applies to ALL construction work, no matter who the client is, how long the work will take or how many workers will be involved, including where the work is performed by client employees.

The definitions of construction contained within CDM2015 regulation 2(1) most relevant to facilities management are:

“construction work” means the carrying out of any building, civil engineering or engineering construction work and includes—

(a)  the construction, alteration, conversion, fitting out, commissioning, renovation, repair, upkeep, redecoration or other maintenance (including cleaning which involves the use of water or an abrasive at high pressure or the use of corrosive or toxic substances), decommissioning, demolition or dismantling of a structure;

(e)  the installation, commissioning, maintenance, repair or removal of mechanical, electrical, gas, compressed air, hydraulic, telecommunications, computer or similar services which are normally fixed within or to a structure,

To remove any doubt as to whether CDM2015 applies to the work, regulation 2(1) also contains the definition of a structure, as follows:

“structure” means—

• any building, timber, masonry, metal or reinforced concrete structure, railway line or siding, tramway line, dock, harbour, inland navigation, tunnel, shaft, bridge, viaduct, waterworks, reservoir, pipe or pipe-line, cable, aqueduct, sewer, sewage works, gasholder, road, airfield, sea defence works, river works, drainage works, earthworks, lagoon, dam, wall, caisson, mast, tower, pylon, underground tank, earth retaining structure or structure designed to preserve or alter any natural feature, and fixed plant;
• any structure similar to anything specified in paragraph (a);
• any formwork, falsework, scaffold or other structure designed or used to provide support or means of access during construction work,

and any reference to a structure includes part of a structure;

This extends the normally understood definition of construction from new build and major refurbishment work to ongoing maintenance and repair of buildings, building services and other fixed plant and systems

The majority of the CDM2015 regulations apply to all construction work, including the preparation of a “construction phase plan” by the contractor.

The following extract from Q&A Briefings – Construction Division – Construction (Design and Management) Regulations 2015 further explains the Health and Safety Executive’s interpretation of what is construction.

Q1.   Does CDM 2015 apply to all maintenance work?

The definition of maintenance work has not changed. If the task in hand looks like construction work, requires construction skills and uses construction materials, it is construction work. General maintenance of fixed plant which mainly involves mechanical adjustments, replacing parts or lubrication is unlikely to be construction work…

e.g. changing a lamp in a light fitting would not be construction, but repairing or replacing the light fitting would be construction.

How to manage maintenance and repair tasks

CDM2015 requires the client to provide information regarding the project, site and other relevant issues to the designers and contractors on all projects (tasks/jobs). This information will be included within the ‘pre-construction information’. This will include where the contractor can park his vehicle and store materials, what welfare facilities are provided and existing rules and procedures.

The contractor must produce a ‘construction phase plan’ for all construction work; and the client has a duty to ensure that it is produced and used.

The pre-construction information has always been required to be supplied, but it would be useful to have some evidence of this. The construction phase plan is a new requirement on the smaller jobs; under CDM2007 it was only required on notifiable projects.

These documents do not need to be overly complex, as can been seen from the above example, produced by Callsafe Services Limited for the Facilities Manager of an office complex.

It should be noted that the requirements placed on the client with regards to the pre-construction information and the construction phase plan are only two of the duties placed on the client, and therefore the Facilities Manager.

If you have any questions on CDM2015, then please do not hesitate to contact Dave Carr on:

01889 577701
enquiries@callsafe-services.co.uk

Visit his website at:
www.callsafe-services.co.uk