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17th July, 2015

Do The CDM Regulations Apply To Manufacturing?

The new CDM Regulations "Construction (Design and Management) Regulations" came into force in April 2015, and it is no secret that these regulations apply to construction projects in the UK. But will these regulations impact on manufacturing, and if so, how?

A common belief is that the CDM Regulations only apply to the construction industry, but it is important to understand that the CDM Regulations apply to all construction work, regardless of the industry that it is carried out within.

There are often times when construction work is carried out within the manufacturing industry.

Sometimes, it will be obvious, for example, if you are having part of the facility refurbished or demolished.

You will usually get builders in to carry out this work.

So yes, if you are having a new building constructed, or a full refurbishment, the regulations will apply to that project, but there are other ways in which the regulations may apply within a manufacturing environment.

This might be work you have carried out in-house, and it might not be immediately obvious that it would come under the definition of construction work for CDM.

Here are several manufacturing activities that can come within the CDM Regulations:

  • Installing new machinery
  • Moving machinery within the factory
  • Dismantling a machine for repair or refurbishment
  • Dismantling existing machinery for decommissioning
  • Changes to work areas by installing (or removing) structures such as walls, additional levels or elevated walkways
  • Work involving mechanical, electrical, gas, compressed air, hydraulic, telecommunications, computer services including installation, commissioning, maintenance, repair or removal
  • Redesigning factory layout
  • Building, or dismantling, an extension

Under the new CDM 2015 Requirements, you need to be aware an appoint additional duty holders (specifically the roles of Principal Designer and Principal Contractor) if you have more than one contractor working on a project, for example, if your own team and one external contractor are involved in the work activity.

It is important to know that if the works are carried out entirely by an external contractor, and they subcontract any of the work, for example, an electrician or a scaffolder, this requirement will be reached and the additional duty holders will need to be appointed under CDM.

These additional roles are no longer triggered by the notification thresholds (30 days with 20 or more workers, or 500 person days), so even if the project is 1 or 2 days, you may need to consider the additional requirements under CDM 2015.

Remember, the CDM Regulations 2015 place a number of duties that need to be carried out prior to the commencement of the work on site, so planning ahead is essential to ensure your manufacturing activities comply.

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