Articles about all aspects of CDM 15 regulations.
The Construction Industry is worth around £65 Billion (Investment Per Annum) to the UK`s GDP. This is a significant contribution but what is not always appreciated is that the cost of maintaining and repairing the resulting asset base which is approximately around £26 Billion. It is vital for clients to be provided with assets that may be safely (and economically) maintained and repaired, and effort should be expended in the early stages of a project to ensure that design deliberations extend to a consideration of the whole-life requirements of the facility.
The obligation to consider these matters is already enshrined in law, but it is often poorly reflected, and there is a lack of practical guidance. For many clients and designers, the concept of considering and planning for work that will be done on a facility, often long after its construction, represents nothing less than a cultural shift in work attitudes and thinking. The need for safe access for maintenance and repair in the main stems from the interrelated consideration of the statutory responsibilities of those involved, the ever-growing need for containment of cost, the management of risk in a comprehensive way, and corporate social responsibility, which encompasses sustainability. Those with the responsibility for managing the maintenance and repair of facilities are likely to find that the organisations who carry out this work, will in future increasingly demand adequate provision of safe access, or will price extra for suitable mitigating and controlling measures to compensate for shortfalls in provision. They have their own statutory obligations, so it is in everyone’s interest to get it right first time.
A difficult topic to consider is the implementation of a mansafe system, which comes in all sorts of varieties and makes and is usually shown on a concept drawing by an Architect or Designer, but is this correct? Is it too early in the design to show this system and is the Architect the correct person to design this system?
So what is a mansafe system?
Personal Fall Prevention Systems are commonly known in the construction industry as ‘mansafe systems’ and are used to keep the operative safe by connecting them to the system using appropriate PPE. The system comprises cable, post and fixings that are tested to take the fall of the user. These usually take the form of a fall arrest system or a fall restraint system.
Some designers don’t always look at the whole picture i.e. the work at height hierarchy (see Fig 1),
There is PPE in the explanation of the meaning of a mansafe system but looking at the hierarchy system we have instantly jumped a number of steps. There should be a reason for that and when designing any building we have to design with safety in mind and therefore we have to look at these steps before we say yes to a mansafe system. So, imagine we have looked at the design and established we are going to design a mansafe system, what do we know or understand about the system?
There is a wide range of systems out in the market, but is it a one size fits all scenario? No of course not, there are lots of things to take into consideration.
Under CDM 2015 we should only engage competent designers and people who are experienced in the task at hand, and with all design work, there is a number of standards and legal documents to adhere to, but do you know what they are? There are a number of regulations that need to be considered before we put pen to paper, these regulations are:
- Construction (Design and Management) Regulations 2015
- Management of Health and Safety at Work Regulations 1999
- Health and Safety at Work Act 1974
- Working at Height Regulations 2005
- Workplace (Health Safety and Welfare) Regulations 1992
- Lifting Operations and Lifting Equipment Regulations 1998
- Provision and use of Work Equipment Regulations 1998
- PPE Regulation (EU) 2016/425 1stEdition April 2018
And then when we start the design, we need to refer to the following:
- BS8560:2012 +A1:2018– Codes of practice for the design of buildings incorporating safe work at height
- BS7883:2005 (soon to be 2019)– Personal fall protection equipment – Anchor systems – System design, installation and inspection – Code of practice
- BS EN795:1997 & 2012– Personal fall protection equipment — Anchor devices
- BS8610:2017– Personal fall protection equipment – Anchor systems – Specifications
- PD CEN/TS 16415:2013– Personal fall protection equipment — Anchor devices — Recommendations for anchor devices for use by more than one person simultaneously
- BS EN 365:2004– Personal protective equipment against falls from height – General requirements for maintenance, periodic examination, repair, marking and packaging
- BS8437:2005– Codes of practice for the selection, use and maintenance of fall protection systems and equipment for use in the workplace
- BS7985:2013– Code of practice for the use of rope access methods for industrial purposes – Recommendations and guidance supplementary to BS ISO 2284
- IRATA International code of practice for industrial ropeaccess– (Third Edition Published July 2014)
Considerations Associated With Installing a Mansafe System
There is an increasing amount of mansafe systems that are not fit for use when installed and these figures are on the rise. We must recognise that a mansafe system is not just a steel rope that attaches to the roof of a building where an operative can hook on and can walk around the building. So, what do we need to look at in regards to the design for a mansafe system?
A new British Standard is due to be released that will help clarify what is required, this new role will call for a System Designer. Regulation 9 & 10 of the CDM Regulations 2015 call for the following:
Regulation 9 and 10 set out the duties placed on designers. These include the duty to eliminate, reduce or control foreseeable health and safety risks through the design process, such as those that may arise during construction work or in maintaining and using the building once it is built.
System Designer: Person with overall responsibility for the design of the anchor system, including certification and handover documentation. This includes the initial risk assessment. The new BS Standard will be BS7883:2019
Personal fall protection equipment – Anchor systems – System design, installation and inspection – Code of practice
This document will list out more design checks and supporting documents to give full accountability for the designed system.
System design specification: Output documentation resulting from the design process which specifies the anchor system(s) to be installed, how and where they are to be installed and any criteria necessary for their safe access and use.
System technical file documentation:Supplied to the duty holder on completion of the installation by the system designer, to be retained for future reference for the life of the personal fall protection system(s) installed
When designing the configuration of an anchor system, the system designer should avoid over-complex systems whilst maintaining the appropriate level of safety and which:
- Give access to all required areas without the need:
- to disconnect and reconnect to the system;
- for adjustable personal fall protection equipment;
- for anti-pendulum anchor devices, if possible;
- requires an increased level of user training, competency and supervision (appropriate training is necessary for all users);
- c) uses the appropriate personal fall protection equipment to minimize the fall risk without adding complexity.
The system designer should:
- ensure that the anchor system is designed, assembled and installed so that it is safe and without risks to health at all times when it is being used, maintained or inspected;
- research and ensure that the testing of the products being used to assemble the anchor system is adequate for the intended application;
- carry out or arrange for the carrying out of such testing that may be necessary to ensure compatibility between assembled parts of the anchor system;
- carry out or arrange for the carrying out of such on-site testing that may be necessary to prove the integrity of the base material in which the anchor system is to be installed where such integrity is in doubt;
- not attempt to design an anchor system without knowing what PFPE is to be connected;
- take such steps as are necessary to ensure that the duty holder is provided with adequate information about the use for which the anchor system is designed and tested and about any conditions necessary to ensure that it will be safe and without risks to health, including when it is being dismantled or disposed of; and
- take such steps as are necessary to ensure that the duty holder is provided with all such revisions of information that would otherwise give rise to a risk to health or safety.
As well as the legal obligations the system technical file should contain a variety of details, the system technical file should as a minimum contain:
1 Companies involved and relationship
2 Manufacturers & Supplier List
3 Specification / Scope
4 Access Strategy
5 Risk Assessments
6 Delivery Notes
7 Certificate of Conformities
9 Product & Component List
10 Method Statements
11 Site Commissioning Documents
12 Quality Control Documents
13 Operating and User Instructions
14 Inspection & Maintenance Information
15 Modifications & Major Repairs
No matter what the project is the design stage is the first opportunity for early prevention and trough good design and provision of suitable access, cleaning, maintenance, and replacement strategy information the cost of future operation and maintenance of a building can be significantly reduced for years to come.