Do The CDM Regulations Apply To Manufacturing?

The CDM Regulations are pretty much common knowledge in the construction industry. Particularly for contractors and designers. Because if you work on construction projects regularly, then CDM becomes part of your day-to-day work. But for some clients and businesses working on a one-off project, CDM may not be something they are familiar with or have even heard of before.

Find out more about CDM and its requirements in our blog post - what is CDM in construction?

A common belief is that the CDM Regulations only apply to the construction industry, but other workplaces can also be affected by the regulations. It's important to understand that the CDM Regulations apply to all construction work, regardless of the industry. And the definition of construction work under CDM can be far-reaching.

There are often occasions when construction work needs to happen within the manufacturing industry. Sometimes, it will be obvious when construction work is getting planned. For example, if you are having part of the facility refurbished or demolished. You will usually get builders in to carry out this work. And when builders are involved, it's a clear sign that construction work is happening.

So, yes, if you have a new building constructed or a refurbishment, the CDM regulations will apply to that project. Often, the architects and builders involved in the project will brief you on the requirements and your client duties. After all, they will have experience working under CDM from previous projects.

Find out more about CDM duties in our free CDM 2015 duty holder guides.

But there are other ways in which the CDM regulations may apply within a manufacturing environment. Situations that might not involve builders or architects. Work you might not consider to be construction work at all.

It's not always obvious when a task comes under the definition of construction work for CDM. It might be work you have carried out in-house. It could be an activity that only takes days or even hours. Maybe it only involves one or two people. It doesn't matter. CDM applies to all construction work, no matter the size or duration.

1. the assembly on site of prefabricated elements to form a structure or the disassembly on site of the prefabricated elements which, immediately before such disassembly, formed a structure;

But what's all this got to do with manufacturing? Because many things can happen in a manufacturing environment that would come under the definition of construction work in CDM.

Here are several examples of manufacturing activities that can come within the scope of 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
• Repair, upkeep, redecoration and maintenance of the factory
• The building of, or dismantling of, an extension

As you can see, there are quite a few tasks and activities that can take place within a manufacturing environment where CDM can apply. I'm sure you can recall some of these happening within your workplace in the past.

Before 2015 the majority of CDM duties were triggered by notification thresholds. These thresholds being 30 days with 20 or more workers or 500 person-days. So smaller projects didn't have the bulk of requirements. But that's not the case any more. Your duties are the same whether or not the work is CDM notifiable.

As well as having client CDM duties, under CDM 2015 requirements, you must appoint additional duty holders. These are people with CDM duties. Every contractor and designer involved in the task will have CDM duties. And if you have more than one contractor working on a project, you need to select a principal designer and a principal contractor. This situation happens quite often, for example, if your team and one external contractor are involved in the work activity.

Check if your project complies with CDM, with the free CDM compliance checklist.

Most projects involve more than one contractor at some stage. It can be the case even if you only appoint one contractor. It's important to note that if they subcontract any of the work, for example, an electrician or a scaffolder, then the requirement to appoint additional duty holders has been reached. If your project only involves a single contractor, then that one contractor will have extra CDM duties.

If you are carrying out all of the work in-house, including planning and doing the task, then it's likely that you will need to take on all of the CDM duties. You will be the client, designer, contractor, principal designer and principal contractor. As the client in a workplace like manufacturing, if you don't appoint the principal contractor and principal designer roles, you automatically become them.

The CDM regulations don't just apply when the construction work is happening, but also when you plan and prepare for the work to start. CDM applies to design, planning and gathering information. To comply, you should make sure the work can go ahead safely and with minimal risk. Several duties need to get discharged before work begins, so planning ahead is essential to ensure your manufacturing activities comply.

If you need to know more about CDM, and your duties, check out our free CDM duty holder guides.