Mike Packham, Partner of Bernard Williams Associates and BIFM member examines how the new CDM regulations are likely to impact the FM sector…
Like many Facilities Managers I suspect, my involvement with Construction, Design and Management (CDM) in the past has been fairly limited – essentially to those occasions when I have been involved with one of the capital expenditure budget funded construction projects that most organisations will have needed to undertake at some stage of their development. However, the scope of the new CDM regulations is such that this scenario is about to fundamentally change. In the future, FM’s are going to have to pay far more attention to this aspect of the regulatory framework than has previously been the case.
Why is this? Well, whilst the requirements for notification to the Health and Safety Executive (HSE) have been relaxed, the definition of what constitutes ‘construction’ has been broadened such that FM works are now clearly included. Thus, many of the minor works projects and maintenance activities which form a core element of the FM’s workload, will now fall within the scope of the CDM regulations for the first time. This situation is further complicated by an additional requirement of the new regulations, which also now relate to any works involving more than one contractor – something which I think we can all recognise as something that is fairly common in an FM context.
Alongside this, the regulations place new liabilities on the client in several areas – in particular they must ensure that their advisors are competent to carry out the required duties. Three distinct ‘advisor’ roles have been identified, ie Principal Designer, Principal Contractor and Client Advisor; these roles have been more than adequately explained in related articles and I do not therefore intend to reiterate them here. Suffice to say though, that where advisors are not appointed, then the respective CDM duties will fall to the client organisation.
For most organisations the logical choice for where all of these new client responsibilities should lie is with the FM department; this is regardless of whether any ‘advisors’ are appointed or not. Where there are no separate specialist advisor appointments, then the FM is likely to find themselves directly responsible for undertaking the CDM related project activities, perhaps being involved in the preparation of the construction phase plan. Even where separate appointments are made, the FM is likely to find themselves involved in the associated procurement and appointment process.
So what does all of this mean in practical terms? Firstly, I think we all need to recognise that all of this is not going to come without cost and we therefore need to make appropriate provision when we are putting our FM budgets together. Secondly, and more importantly, we need to recognise and understand our new organisational CDM responsibilities and ensure that we have access to an appropriate level of expertise – either through internal or external resources or, more likely, through a combination of the two.
British Institute of Facilities Management (BIFM)
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