Fit for the task

5 July, 2010

Since the introduction of the Construction (Design and Management) Regulations 2007 (CDM), there has been a greater emphasis on ‘clients’ to ensure that any third-party appointments are ‘competent’.

According to the CDM approved code of practice (ACoP), the key ingredients which make up an individual’s or organisation’s competence are having the necessary knowledge and experience to fulfil their duties. In addition, a competent individual should be adequately trained and have an appreciation of their own limitations and constraints. It is important that the client has an understanding of these barometers when making personnel appointments.

For a facilities manager who is required to engage third-party personnel, a common approach would be to use a generic health and safety pre-qualification questionnaire (PQQ). However, distributing and analyzing the responses can often be a time-consuming process involving a lot of paperwork.

The CDM ACoP states that assessing competency should be a two-stage approach. In stage one, the adequacy of the company’s organisation and arrangements for health and safety should be gauged. Stage two involves seeking reassurance that the potential contractor has gained an acquired level of experience and has a convincing track record in delivering projects of a similar size and scope.

Take, for example, a project involving working on a roof. You must understand the risks, then ask if your contractors meet H&S legislation requirements, are competent to undertake the work required, and if they ask the same questions of their subcontractors. The point here is that the onus is on the contractors to demonstrate to you that they are competent and compliant. You then need to assess what they provide.

If you outsource, check your assessment provider is also competent. They should do at least what you would do yourself, and hopefully more. Don’t forget, if they don’t, you, as the client, are still responsible.

Although appendix four of the CDM ACoP provides clarity on what the client can look for in order to make a ‘reasonable judgement’ about competency, the intention and spirit of CDM is to reduce the amount of paperwork which continues to plague the construction industry.

The Health and Safety Executive has given reassurance that if a company can confirm accreditation with an approved competency assessment scheme, in most cases it will be enough to meet the requirements of stage one. More time can then be spent examining how contractors will meet a project’s special requirements.

There is a proliferation of different schemes on the market, the most widely recognised probably being the Contractors Health and Safety Scheme (CHAS).

Others include Exor, Constructionline and Altius, to name a few. Although each scheme may have its unique features, there is general recognition that in order to become accredited a potential member must be able to satisfy an almost identical question set (based around appendix four of the CDM ACoP). The value of being associated with more than one scheme is, therefore, questionable.

In November 2009 the Safety Schemes in Procurement Forum was launched, funded by the HSE. Suppliers can be confident that using an SSIP Forum pre-qualification scheme is adequate to demonstrate the stage one assessment. In order to gain entry on to the forum the assessment schemes themselves are rigorously audited by the SSIP to ensure that its standards are maintained.

This scheme should be welcomed because as a practising CDM coordinator, I have seen, first hand, that even the most conscientious companies often struggle to carry out competency assessments that are adequately robust and do not generate an excessive amount of paperwork.