Posted: 5th January 2017
Xenophon Project Services Limited/ Construction Team Technologies Ltd
CDM Differently* – Safety Culture Gap Management** A challenge for the Industry?
How has the UK Construction Sector responded to the more stringent requirements set out in the revised CDM Regulations which came into effect on 6th April 2015? After a pretty hectic first twelve months I get the sense that the Industry , in some respects, has lapsed back into its old ways.
I recently carried out some consultancy work for a large contractor, as part of their drive to understand the underlying and root causes of ‘near miss’ incidents which could have resulted in serious injury or potentially loss of life. This organisation has strong health and safety leadership and a positive culture that encourages everyone to influence how risks are managed on site. Although the incidents investigated were different in nature and potential outcome, my analysis suggested there was a common flaw in the way the project teams on the various sites addressed risk management. A lot of effort had gone into producing project documentation that covered generic risks, but the project teams had failed to recognise the particular combination of site factors and construction activities that represented ‘significant risk scenarios’. None of the incidents investigated had been adequately addressed in the pre-planning stage.
Rather than seeing this as a failure of individual teams or organisational weaknesses, I concluded that the approach to project risk management taken by this organisation was in accordance with the established, orthodox, document-led philosophy adopted throughout the industry.
Amongst the documents provided for each investigation were:-
- Company policies and procedures
- Construction phase health and safety plans
- Site induction presentations
- Task based risk assessments and method statements
When investigating the causes of different incidents it became clear that in each case the specific risk profile of the activity being undertaken had not been thought through in any detail. There appeared to be a presumption that everyone was working in accordance with established (written) procedures but there was no evidence that compliance (or lack of it) was being monitored.
The provision of excessive, generic documentation has been addressed in the revised CDM 2015 regulations. Regulation 8 makes specific reference to the need for health and safety information to be ‘comprehensible’. The guidance relating to this particular regulation (which applies to all duty holders) states ‘Any information or instruction provided should be in simple, clear English….Only information that is necessary to help prevent harm should be provided - unnecessary information can prevent the clear communication of key messages.’
The HSE is fully aware of the over- reliance on standardised documentation used ‘to demonstrate compliance’ with the regulations. Back in 2005 it was the HSE who devised the slogan ‘Teamwork not Paperwork’ in the consultation phase for the development of the 2007 regulations.
The problem of excessive paperwork does not simply reside with Principal Contractors. The failure to identify ‘significant risks ‘ often starts at the concept stage of a project when clients and their lead designers should be identifying and evaluating the ‘difficult to manage ‘ aspects of the project so that the whole project team can engage collaboratively in developing a risk reduction process that leads to safe construction.
If the Industry is to wean itself off excessive bureaucracy it will probably happen incrementally, project by project, as clients understand that they are accountable for the management arrangements put in place on their projects, ‘so that health, safety and welfare is secured.’
The role of the Principal Designer will be crucial in assisting clients to develop a strategic approach, at the outset, which addresses the need for practical, proportionate risk management, and a departure from the tick box mentality that has come to characterise health and safety in construction. Although the role of PD is new, the concept of developing a Project Strategy is not.
Sir Michael Latham’s report – Constructing the Team- published in July 1994, (around the time that the CDM Regulations were first coming into force) , had been commissioned by the UK Government following a series of poorly performing high profile public sector projects. The main focus of the report was on how projects were procured and the contractual arrangements being employed at the time. The report described the construction sector of that period as “ineffective”, “adversarial”, “fragmented”, “incapable of delivering for its customers”, and “lacking respect for its employees”.
The report does not address the Health and Safety agenda specifically, although it does outline the proposed CDM 1994 regulations (which eventually came into force in March 1995).Whilst some of the main recommendations around contractual arrangements have been adopted by clients , others have been largely ignored. Building the project team around a clearly defined strategy is a theme identified in both ‘Constructing the Team’ and CDM 2015, although different language is used.
‘ Formulation of a project strategy by the client is the first building block to a successful and cost effective scheme. Some believe that this project strategy stage should involve likely participants in the project itself, and in particular the leader of the consultant team.’ (Latham).
‘The client has a major influence over the way the project is procured and managed. CDM 2015 makes the client responsible for the impact their decisions and approach have on health, safety and welfare on the project. Clients could prepare a clear ‘clients brief’ as a way of setting out the arrangements.’ (CDM 2015)
Clients generally look to their professional advisers to guide them through the construction process. The creation of the Principal Designer role presents architects and engineers with an opportunity to facilitate the creation of well-directed, collaborative and motivated teams led by informed clients. The benefits to the project delivery will extend further than improving the health and safety aspects and clients need to understand this.
* CDM Differently – a CIC- led initiative that promotes a team based approach to risk management
** Safety Culture Gap Management – an ICE –led approach to understanding the root causes of failure in organisational health and safety performance.
Contributor: Tony Putsman a Director for Xenophon Project Services Limited/ Construction Team Technologies Ltd. and the Vice Chair of the Construction Industry Council's Health & Safety Panel
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