4.1 Introduction
In the previous module, we looked at the first of the three key documents in the CDM Regulations 2015. We are now going to move on to the second document: the Construction Phase Plan, also known as the CPP. Just as with the Pre-construction Information, we're going to break down this document and then look at the specific responsibilities that each duty-holder has in regards to it.
4.2 What is a Construction Phase Plan?
A Construction Phase Plan (CPP) is a document that must record the health and safety arrangements for the construction phase and the site rules. Where relevant, it should also include specific measures required when the project falls into one or more of the categories listed in Schedule 3 of the CDM Regulations 2015.
The plan must detail the methods put in place to manage the health and safety risks associated with the construction part of the project. These should have already been identified by both the client and the principal designer in the Pre-construction Information. Essentially, the CPP is there to explain these methods to everyone who needs to be aware of them, so that the project stays within health and safety guidelines. As such, it should be clearly presented in a way that is easily understood.
Equally, the detail included should be proportionate to the size and complexity of the project, as well as the number of risks involved.
However, the plan should not include documents that get in the way of a clear understanding of what is needed to manage the construction phase, such as generic Risk Assessments, records of how decisions were reached or detailed Safety Method Statements.
The following list of topics should be considered when drawing up the plan:
(1) A description of the project, such as key dates and details of key members of the project team.
(2) The management of the work.
This includes:
1.The health and safety aims for the project
2.The site rules
3.Arrangements to ensure co-operation between project team members and co-ordination of their work
4.Arrangements for involving workers
5.Site induction
6.Welfare facilities
7.Fire and emergency procedures
(1) The control of any of the specific site risks listed in Schedule 3, where they are relevant to the work involved.
4.3 Duty-Holders' Responsibilities
The client
The client's main responsibility for this document is ensuring that the Construction Phase Plan is completed before the construction work begins. For projects involving more than one contractor, the principal contractor is responsible for drawing up the plan (or making suitable arrangements for someone else to); however, for single contractor projects, this responsibility falls on the contractor. It is also down to the client to make sure that the principal contractor (or contractor) is given all of the necessary information from the Pre-construction Information regarding health and safety, in order to complete this.
The client must also ensure that, once the CPP is drawn up, the methods to reduce or eliminate risks are arranged and in place and that the principal contractor (or contractor) regularly views the plan and modifies it, where necessary.
The designer
While the designer has no specific duty in relation to the CPP, they can still assist the principal contractor (or contractor) when it is created.
This could be by providing any relevant information that they obtained during the designing of the project in regards to health and safety and any risks that they identified. It is also the designer's duty to divulge any information regarding health and safety risks that they were unable to eliminate through the design process and any steps that they've implemented, in order to try and control these.
The designer must also ensure that they are in regular contact with the principal contractor (or contractor) during this phase in relation to any necessary design changes or alterations.
The principal designer
The principal designer must help the principal contractor to prepare the Construction Phase Plan by providing any relevant information that they hold. This includes the Pre-construction Information given to them by the client and for which they have an important role in pulling together and providing any information given to them by designers regarding the risks that have not been eliminated through the design process and the steps taken to reduce or control these risks.
Before the start of the construction phase, the principal designer should regularly check that the principal contractor (or contractor) has the information required to prepare the plan. They must continue to liaise with the principal contractor, as work progresses, to share any information that is relevant to the planning and management of the construction phase.
The principal contractor
For projects involving more than one contractor, the principal contractor must take the lead in preparing, reviewing, updating and revising the Construction Phase Plan. They must draw up the plan (or make arrangements for it to be drawn up) during the pre-construction phase and, most importantly, make sure that this is done before the construction site is set up. In creating the CPP, the principal contractor is usually assisted by both the client and the principal designer, as they can provide helpful information that they have. This includes the Pre-construction Information prepared by the client and information obtained by the principal designer during the design process regarding health and safety risks and what they have put in place, in order to eliminate them.
It's also important for the principal contractor to discuss the CPP with the contractors, who will have valuable opinions on the practicality of putting the measures into place. Where the plan includes site rules, these should be clear and easy to understand and brought to the attention of all those who are expected to follow them. This is also usually included in the site induction.
Rules should include aspects such as:
1.Personal protective equipment (PPE)
2.Parking
3.Use of radios and mobile phones
4.Smoking
5.Restricted areas
7.Hot works
8.Emergency arrangements
The principal contractor should also consider whether any special requirements are required.
For example
It may be necessary to have translations of the site rules available in different languages. The HSE explains in their reference document on the CDM Regulations 2015 that the principal contractor must also ensure that the Construction Phase Plan is appropriately reviewed, updated and revised from time to time.
It is because the CPP is an adaptable, working document that will need to be reviewed regularly enough to address significant changes to the risks involved in the work or in the effectiveness of the controls that have been put in place. This means that the principal contractor must monitor how effective the plan is in addressing identified risks and whether it is being properly implemented.
Ensuring that the plan remains βit for purpose must also involve co-operating with:
1. The contractors, who are most likely to see if the arrangements for controlling health and safety risks are working
2. The principal designer and designers when changes in designs during the construction phase have implications for the plan
The contractor
For projects involving more than one contractor, the contractor must follow the parts of the Construction Phase Plan prepared by the principal contractor that are relevant to their work. The contractor should also keep in regular contact with the principal contractor to pass on their views on the effectiveness of the plan in managing the risks.
For single contractor projects, the contractor has the responsibility for ensuring that a Construction Phase Plan is drawn up. They must either draw up a plan themselves or make arrangements for it to be drawn up as soon as practicable before setting up the construction site.
Just like the principal contractor, if they are responsible for creating the CPP, they must consult with the client and principal designer to obtain any relevant information that they have in regard to health and safety.
MODULE SUMMARY
In this module, we continued to look at the duty-holders who have legal responsibilities for enforcing the CDM regulations. We then looked at the second of the three key documents: the Construction Phase Plan and how the roles of the duty-holders specifically apply to this.
The duty-holders we looked at were the client, the designer, the principal designer, the principal contractor and the contractor.
In Module 5, we will discuss the duty-holders' responsibilities in regards to the Health and Safety File.
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