CDM Regulations: CDM 2015 Training for Electricians

The Construction (Design and Management) Regulations 2015 (SI 2015/51) came into force on 6 April 2015 and set out how health and safety is managed on construction projects in Great Britain. They are made under the Health and Safety at Work etc. Act 1974. The definition of construction work includes the installation, commissioning, maintenance, repair or removal of electrical services fixed within or to a structure, so a consumer unit change is covered as much as a large commercial installation.

Many electricians assume CDM only applies to large or notifiable sites with several contractors, hard hats and site cabins. This is wrong. CDM 2015 applies to all construction work, including domestic projects, whether or not the project is notifiable. What you do is sized to the job, so a domestic rewire needs far less paperwork than a hospital installation, but the law applies whatever the size of the project.

Understanding CDM is about working safely and knowing which duties are yours: as a contractor, as a designer when you choose the layout or specification of an installation, and as the person carrying the client's duties on many domestic jobs. It also helps you work well with clients, principal designers and principal contractors.

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CDM 2015 places duties on five kinds of duty holder, shown below, and workers have duties too. HSE says one person or organisation can hold more than one role if they have the skills, knowledge and experience for each.

Where there is more than one contractor, or it is reasonably foreseeable that there will be, the client must appoint a principal designer and a principal contractor in writing. The trigger is the number of contractors, not notification, size or duration. If a commercial client does not appoint them, it must carry out their duties itself; on a domestic job the law fills the roles.

The principal designer plans, manages and monitors the pre-construction phase. It makes sure designers comply with their duties, coordinates health and safety during that phase, helps the client with pre-construction information and passes it on, and prepares the health and safety file. It must be a designer with control over the pre-construction phase, and the law names no qualification for the role. If your electrical work includes design, you must give the principal designer information about risks your design could not eliminate.

The principal contractor plans, manages and monitors the construction phase. It draws up and updates the construction phase plan with its site rules, organises cooperation between contractors (including your electrical team), makes sure there is a suitable site induction, takes steps to prevent unauthorised access, and makes sure welfare facilities are provided. HSE says it does not have to supervise each contractor's work in detail.

As an electrical contractor on a site with other contractors, you must follow the directions of the principal designer and principal contractor and the parts of the construction phase plan relevant to your work, cooperate with others on the site, and report anything likely to endanger anyone. The principal contractor may also ask to see your risk assessments and method statements before you start. HSE says method statements are not required by law, but they are an effective and practical way to help plan, manage and monitor construction work.

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Every construction project needs a construction phase plan before the construction phase begins, not only large or notifiable ones. Where there is more than one contractor, the principal contractor draws it up before the site is set up and keeps it reviewed and updated. Where there is only one contractor, that contractor draws it up (regulation 15(5)), so on a domestic job where you are the only contractor, the plan is yours to write.

The plan is sized to the job. HSE says a simple plan before the work starts is usually enough for small work, and its CIS80 leaflet gives a template. HSE also says the plan should not include generic risk assessments or detailed method statements, and should be as simple as possible.

As an electrical contractor, you will be expected to provide documentation to the principal contractor and, in some cases, directly to the client. The key documents are:

Risk assessments and method statements (RAMS) for your electrical work. The law requires a suitable and sufficient risk assessment under regulation 3 of the Management of Health and Safety at Work Regulations 1999, and an employer with five or more employees must record the significant findings. CDM does not require a method statement, although arrangements for demolition or dismantling must be recorded in writing before the work begins (regulation 20(2)). HSE says method statements are not required by law but are an effective way to plan, manage and monitor work.

Competence evidence. The law asks that the people you employ or appoint have, or are in the process of obtaining, the skills, knowledge, training and experience for their tasks (regulation 15(7)). CDM names no card, scheme or qualification, and HSE says sole reliance should not be placed on industry certification cards. Third-party assessment schemes are one way to show competence, but HSE says the law does not require them. Training records, such as safe isolation, asbestos awareness and working at height, help show what your team can do.

Information for the health and safety file on projects with more than one contractor. The principal designer prepares the file and it goes to the client at the end of the project. If you designed part of the installation, you must make sure appropriate information about it goes in the file, and the principal contractor passes relevant information to the principal designer. HSE suggests the file includes the nature, location and markings of significant services, including underground cables, and as-built drawings.

Reporting danger and incidents. Anyone working under another's control must report anything likely to endanger themselves or others to that person (regulation 8(5)). Under RIDDOR (Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013), an employer reports reportable injuries to its own employees; for a self-employed person, and for dangerous occurrences, the person in control of the premises reports.

Every electrical firm, sub-contractor, sole trader or self-employed electrician who carries out, manages or controls construction work in the course of a business is a contractor under CDM 2015. Contractor duties are in regulation 15, and Part 4 adds general requirements for every construction site. An employed electrician is a worker, who must cooperate with others and report danger (regulations 8(4) and 8(5)). The main contractor duties are:

These duties apply on every project, whatever its size. On a domestic project where you are the only contractor, you also carry the client's duties, sized to the job. On a site with other contractors, you work within the arrangements set by the principal contractor, but you remain responsible for managing your own work safely, and anyone working under another's control must report to that person anything likely to endanger their own or others' health and safety (8(5)).

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