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CDM why wasn't an audit responsibility in the regs

Bill Sowerbutts 3 months ago   Reply

I was thinking about CDM in all its formats - from 1995 to the present day. One omission that seems glaringly obvious is that there has never been an audit responsibility so that the senior advisor on competence - Planning Supervisor, CDM Coordinator or Principal Designer - could make a declaration that the health and safety provisions declared in the Safety Plan/Conbstruction Phase Plan were indeed sufficient and in situ.   

As I have said in the past - "anyone can write down anything"! I'll tell the police Im driving from here to Plymouth and won't go over 70mph.  But they aren't so silly as to believe me without checking wioth cameras. It would be so easy to include the requirement for a third party auditor - not the PC's own personnel or in this pay - but paid for by the Client - to check actual provision.  It wouldn't cost much  and needs only to be a "sign off" against declared intent. 

Such a simple thing would take pressure off the HSE to inspect sites and indeed be pre-emptive rather than reactive in reducing incidents.  Besides informing the management team, it would do one more great service. It would give the Client an "informed" picture of provision that wouldjustifiably make the Cleint responsible for the level of provision. What do I mean by this? Well simply that if the Client battered the contractor down so much on tender that corners were cut on quality and health and safety ("value engineering" as it is euphamistically called). then this could be independently assessed and the Client couldn't claim that he didn't have the knowledge to know that there was a shortfall between declared and actual provision and that the reason why X was 20% cheaper than all the others  was because he didn't provide a flush toilet or a hygienic canteen. 

Why - when accounts require auditing- has such a requirement not been mandatory on health and safety?


Tim D 3 months ago   Reply


Whilst there can be much to learn from the past.. let’s not dwell too long there and stick with CDM2015, the now and the future.

The PC has a duty under Reg 12 (4)

The Client has a duty under both Reg 4 (3) & (6)

Some Clients take ‘reasonable steps’ to discharge their duties by arranging for others to carry out Site Audits and Site Inspections. Much depends on them, who they are, what they like, the project scale and what they see or hear. Sure this is easier on 8, 9 or 10 figure projects.. the approach on a 5 or 6 figure project needs to be proportional.. possibly the less formalised walkaround.

The scalable framework of CDM2015 is a blessing and for some refreshingly not overly prescriptive. You have to decide what it is you have to do.

Audits, Inspections these are snapshots in time… much like my MOT due soon and yes, I’m afraid no shiny new car on my driveway; where did that go wrong (.. no reply sought).


Liz Bennett 3 months ago   Reply

In my view a range of audits and checks are required. The Client at Regulation 4 has very extensive duties including but not limited to: To ensure health and safety is delivered, SFARP; To ensure the PD and PC carry out their roles properly.

If that is not enough for you I would add to that the Regulation 2 definition of Pre Construction Information requires at information about (a)(iii) health and safety hazards, including design and construction hazards and how they will be addressed. This is a Client duty, supported by the PD under Reg 11. 

These hazards will be address by a proper Design Management Plan and a proper Construction Phase Plan. 

All three of the top table duty holders have reciprocal duties in respect of delivering success. Regulation 8(4)(5) and (6) put statutory duties on all to behave in a way which can otherwise be described as collaboration.

Liz Bennett