An Examination of the Requirements of the Construction (Design and Management) Regulations 2007
This study focuses on the key requirements of Construction (Design and Management) 2007 (CDM 2007) and on its practical application. In particular, the demands and challenges faced by small and medium-sized enterprises (SMEs) are explored, in order to gain a clear understanding of how successful implementation may be affected by scale of operation, if at all.
The way in which SMEs operate generally is considered, as is the impact that CDM 2007 makes on their infrastructure, because of its legal and operational requirements.
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The experiences of the implementation of CDM 2007 by larger corporations provide indications as to whether some aspects of complying with CDM may cause difficulties for smaller-scale organisations. Acknowledged successes and existing difficulties are identified, and suggestions made as to the possible further development of CDM 2007.
Theme of the Study
This study focuses on the key requirements of Construction (Design and Management) (CDM) 2007 and on its practical application. In particular, the demands and challenges faced by small and medium-sized enterprises (SMEs) are explored, in order to gain a clear understanding of how successful implementation may be affected by scale of operation, if at all.
The way in which SMEs operate generally is considered, as is the impact that CDM 2007 makes on their infrastructure, because of its legal and operational requirements. The experiences of the implementation of CDM 2007 by larger corporations provide indications as to whether some aspects of complying with CDM may cause difficulties for smaller-scale organisations. Acknowledged successes and existing difficulties are identified, and suggestions made as to the possible further development of CDM 2007.
Definition and Description of SMEs
From 1st January 2005, the European Commission (Enterprise and Industry) has defined micro, small and medium-sized enterprises according to certain criteria:
“In addition to the staff headcount ceiling, an enterprise qualifies as an SME if it meets either the turnover ceiling or the balance sheet ceiling, but not necessarily both.” (European Commission, 2011).
Enterprise CategoryHeadcountTurnoverorBalance Sheet Total
medium-sized< 250? ˆ 50 million? ˆ 43 million small< 50? ˆ 10 million? ˆ 10 million micro< 10? ˆ 2 million? ˆ 2 million
It was important for the European Commission to lay down guidelines for SMEs that could be applied throughout the European Community as there are certain policies in effect within the European Economic Area that are beneficial to SMEs, such as exemption from some of the rules and regulations affecting large corporations. Statistically these smaller organisations constitute the vast majority of all European Union (EU) businesses:
“Micro, small and medium-sized enterprises are socially and economically important, since they represent 99 % of all enterprises in the EU. They provide around 90 million jobs and contribute to entrepreneurship and innovation. However, SMEs face particular difficulties, which the EU and national legislation try to address by granting them various advantages. The application of a common definition by the Commission, Member States, the EIB [European Investment Bank] and the EIF [European Investment Fund] ensures consistency and effectiveness of those policies targeting SMEs and, therefore, limits the risk of distortions of competition in the Single Market.” (European Commission, 2011).
The EU recognises that SMEs are a vital part of the economy and also that they face specific difficulties. It has introduced some schemes to provide extra assistance for smaller businesses, including access to Structural Funds and the Framework Programme for Research and Development, as well as exemption from some of the restriction attached to State Aid.
Summary of CDM 2007
The United Kingdom’s Health and Safety Executive (HSE) publishes a summary of the requirements of CDM 2007 on its website [http://www.hse.gov.uk/construction/cdm/summary.htm]. The rules came into effect on 6th April 2007 and are legal requirements. They include those that must be adhered to for all construction projects, excluding projects commissioned by domestic clients (Part 2), and those that apply to ‘notifiable projects’ (Part 3). Notifiable projects are defined as:
“… those lasting more that 30 days or involving more than 500 person days of construction work.” (HSE Legal Requirements, 2011).
The CDM 2007 requirements for all construction projects are as follows:
Clients (excluding domestic clients) must:Check competence and resources of all appointees
Ensure there are suitable management arrangements for the project welfare facilities
Allow sufficient time and resources for all stages
Provide pre-construction information to designers and contractors
Designers must:Eliminate hazards and reduce risks during design
Provide information about remaining risks
Contractors must:Plan, manage and monitor own work and that of workers
Check competence of all their appointees and workers
Train own employees
Provide information to their workers
Comply with the specific requirements in Part 4 of the Regulations
Ensure there are adequate welfare facilities
All workers concerned with a project must:Check own competence
Co-operate with others and co-ordinate work so as to ensure the health and safety of construction workers and others who may be affected by the work
Report obvious risks
Summary: the designer must ensure risks and hazards are eliminated at design stage, before construction work starts; contractors must check competences, provide training and comply with Regulations (Part 4), which contains practical requirements that apply to all construction sites; obvious risks, must be reported.
The CDM 2007 requirements for ‘notifiable projects’ are as follows:
Clients (excluding domestic clients) must:Appoint CDM co-ordinator*
Appoint principal contractor*
Make sure that the construction phase does not start unless there are suitable welfare facilities and a construction phase plan is in place.
Provide information relating to the health and safety file to the CDM co-ordinator
(* There must be a CDM co-ordinator and principal contractor until the end of the construction phase)
CDM co-ordinators must:Advise and assist the client with his/her duties
Co-ordinate health and safety aspects of design work and co-operate with others involved with the project
Facilitate good communication between client, designers and contractors
Liaise with principal contractor regarding ongoing design
Identify, collect and pass on pre-construction information
Prepare/update health and safety file
Designers must:Check client is aware of duties and CDM co-ordinator has been appointed
Provide any information needed for the health and safety file
Principal Contractors must:Plan, manage and monitor construction phase in liaison with contractor
Prepare, develop and implement a written plan and site rules (Initial plan completed before the construction phase begins)
Give contractors relevant parts of the plan
Make sure suitable welfare facilities are provided from the start and maintained throughout the construction phase
Check competence of all appointees
Ensure all workers have site inductions and any further information and training needed for the work
Consult with the workers
Liaise with CDM co-ordinator regarding ongoing design
Secure the site
Contractors must:Check client is aware of duties and a CDM co-ordinator has been appointed and HSE notified before starting work
Co-operate with principal contractor in planning and managing work, including reasonable directions and site rules
Provide details to the principal contractor of any contractor whom he engages in connection with carrying out the work
Provide any information needed for the health and safety file
Inform principal contractor of problems with the plan
Inform principal contractor of reportable accidents, diseases and dangerous occurrences
All workers concerned with a project must:Check own competence
Co-operate with others and co-ordinate work so as to ensure the health and safety of construction workers and others who may be affected by the work
Report obvious risks
Summary: requirements are considerably more onerous; the CDM co-ordinator must look after health and safety concerns, and welfare facilities must be provided from the start and throughout the construction phase; a written plan and site rules must be in place; obvious risks must be reported.
What the study seeks to achieve
The research focuses on determining whether the key requirements of CDM 2007 are viable for all SMEs, or whether the steps required for its practical application constitute a burden to some. If the latter is the case, the reasons why this is so evidence of the difficulties faced by SMEs will be recorded and analysed. Further, the potential for making improvements to current requirements can be identified and described.
How the dissertation is structured
The Introductory chapter (Chapter 1) outlines the theme of the study and what it seeks to achieve; introduces the concepts of CDM 2007 and SMEs, and describes their parameters. The Literature Review (Chapter 2) examines how the responsibilities of CDM 2007 are divided between participants in construction projects, and how monitoring and evaluation takes place. It explains why CDM is needed and what the health and safety implications are. Key areas of research undertaken thus far are summarised and the research question is explained. The Methodology section (Chapter 3) details the secondary research and the advantages and disadvantages of CDM 2007 for SMEs. The limitations of the research are explained. Research findings are discussed (Chapter 4); conclusions are drawn and recommendations made (Chapter 5).
2.0 LITERATURE REVIEW
What the literature review considers
A number of research projects have been carried out into the reasons for injuries on construction sites and the impact of CDM 2007, and a number of examinations have been made into the reasons why there are deaths among construction workers engaged in building projects. One key document in this latter respect is the report by Rita Donaghy (2009) to the Secretary of State for Work and Pensions: One Death is too Many; her report looked at the underlying causes of construction fatal accidents. The HSE’s evaluation of CDM 2007 is studied for the feedback it provides from 565 construction professionals.
CDM (2007): who carries responsibilities?
All workers on construction projects are required to ensure their personal skills and competences are sufficient to the job they are doing. They must work collaboratively as a team, ensuring that the health and safety of all workers is never compromised. All obvious risks must be reported. In all cases, clients, designers and contractors must contribute relevant information to the health and safety file. None of this is particularly onerous or surprising – indeed it represents best practice in any place of work.
Clients on non-domestic projects have responsibilities to choose contractors wisely, by checking the competence and resources of all appointees. They must also check that suitable facilities are in place to cater for staff welfare – for example, toilet facilities, washing facilities and adequate refreshment facilities. For notifiable projects these must be in place before building works start on site. Clients must not pressurise contractors or construction workers to undertake work to unrealistic deadlines or with insufficient or sub-standard resources; instead they must ensure that designers and contractors have received all the relevant information pre-construction. For ‘notifiable contracts’ of more than 30 days’ duration the client must appoint a CDM co-ordinator and a Principal Contractor, and must also provide health and safety information to the former.
For standard, short contracts, designers must check the client is aware of their duties and have reduced risks and eliminated hazards at the design stage. For notifiable projects, designers must check that a CDM co-ordinator has been appointed and provide any relevant safety information.
For standard, short contracts, contractors are obliged to train and manage their own workforce, as would be expected, and to ensure welfare facilities are available. The practical requirements they have to observe, detailed in Part 4 of the Regulations, are comprehensive, including duties that relate to health and safety on construction sites. Part 4 includes instructions covering items such as how to ensure a site is safe and that structures are stable; handling dismantling and demolition; site security; managing the use of explosives; conducting excavations; dealing with water and energy supplies; vehicles and routes for traffic; preventing, detecting and fighting fires; emergency procedures; temperature control, fresh air and protection from the weather; lighting and filing reports (The Construction (Design and Management) Regulations, 2007).
For notifiable projects there are responsibilities assigned to both the Principal Contractor and other contractors. The former must instigate written plans for the construction work to be distributed to contractors, carry out inductions and liaise with the CDM co-ordinator. Other contractors must ensure HSE has been informed before they start work, and co-operate and liaise with the principal contractor and the CDM co-ordinator. Contractors have to indicate any problem areas that they perceive with the planned design and report accidents, staff illnesses or any dangerous conditions to the Principal Contractor.
For notifiable projects only, the CDM Co-ordinator has the key health and safety role. They are guardians of the client – assisting and advising them of the responsibilities pertaining to their role; they must also notify HSE and co-ordinate all the safety aspects of the implementation of the design work in co-operation with others. CDM Co-ordinators are communicators who liaise between contractors, designers and the client. It is their responsibility to prepare and/or update the health and safety file.
How Well is CDM Managed and Policed?
It can be seen that Principal Contractors (or contractors on smaller, shorter contracts) theoretically carry the main burden of responsibility for what happens on site – although designers also have health and safety responsibilities, jointly with the contractor (Morrow, 2010). In her examination of the industry Rita Donaghy remarked:
‘The responsibility for safety already lies clearly with the contractor and this responsibility needs to be further clarified in order to raise standards and assist the courts when considering alleged breaches of health and safety’ (Donaghy, 2009, p. 11, Section 19).
One of the difficulties faced by the industry in the light of the safeguards apparently built in to CDM 2007, is how and why fatal construction accidents are still happening, a fact that Donaghy describes as the ‘regular toll of fatalities’ (p 11, Section 16). She notes:
‘It is a disgrace that we have such a low level of reporting serious accidents, let alone near-misses’ (p. 16, Section 40).
A further concern is the ‘built-in delays in the system leading to prosecution and conviction or other outcomes on construction fatal accidents’ (Donaghy, 2009, p. 14, Section 33). Prior to CDM 2007, the HSE had produced a report on the causes of construction accidents, which concluded that:
‘… achieving a sustained improvement in safety in the industry will require concerted efforts directed at all levels in the influence hierarchy’ (HSE, 2003, Summary).
However Donaghy’s definitive report, coming two years after the introduction of CDM, plus the ongoing fact of construction accidents, makes it clear that CDM may not be being either well managed or adequately policed in some sections of the construction industry.
Health and Safety Issues
The long list of areas where contractors have duties and responsibilities (Section 2.2 Contractors above) gives a clear indication of some of the kinds of accidents that can occur on a construction site, which is why the provisions outlined in CDM 2007 are needed. There are accidents recorded in the UK virtually on a daily basis – the more horrific ones make it to the headlines, for example:
‘Company fined after workers engulfed in electrical fireball’, Construction News, 9th December 2011
‘Plasterer in coma after 6ft ladder fall’, Construction Enquirer, 9th December 2011
‘Four die in accident at engineering firm’, The Telegraph, 22nd January 2011
Amongst those workers deemed to most vulnerable on construction sites are migrant workers, young workers – perhaps apprentices or casual labourers – and also more experienced workers aged 55–60 years who might be inclined to take more risks (Donaghy, 2009).
Summary of research into effects/implications so far
Donaghy (2009) cites a long list of studies considered as background research for her report (pp. 90–94) including documents prepared by HSE. Studies have been undertaken by independent academics, for example Muddiman, A. (2001) and Deakin and Koukiadaki (2007). Work has been carried out by trades unions, such as UCATT (2006) and the TUC (2007). All of this research work has focused on the health and safety issues in construction workplaces. Some have investigated vulnerable workers, such as the Department for Business Enterprise & Regulatory Reform (BERR) (2008) and others have specifically studied migrant workers, including Irwin Mitchell Solicitors and the Centre for Corporate Accountability (2007).
Despite the breadth of the research and the abundance of safety regulations that apply to the construction workplace (Donaghy, 2009, p.95 gives examples but does not provide an exhaustive list) the key impression gained from participants in Donaghy’s research is that regulations are not always followed or enforced.
‘Many stakeholders, particularly trade unions, some academics and bereaved families, feel strongly that self-employment, whether genuine or bogus, adds to the risk in the industry because self-employment is such a high proportion of the total. In London it is approaching 90% … There seems to be more agreement that “the problem is particularly acute in the South and London where self-employment constitutes 89% of firms and migrants form 42% of the workforce”.’ (Donaghy, 2009, pp. 34–35).
Several research studies have looked into the effectiveness of CDM 2007, including a pilot evaluation conducted by HSE:
‘The pilot evaluation showed that there are positive signs in terms of CDM 2007 meeting its objectives, with evidence of three being met and two being partially met. However, some respondents have concerns about the effectiveness of CDM 2007 in: Minimising bureaucracy; Bringing about integrated teams; Bringing about better communications and information flow between project team members; and Better competence checks by organisations who appoint other duty holders’ (HSE, 2011).
In March 2010 Pye Tait Consulting carried out research into CDM 2007 from the client’s perspective (Pye Tait Consulting, 2010) and Susan Morrow presented a paper at an international conference in Paris about the impact of CDM 2007 from a designer’s point of view (Morrow, 2010).
Origins of the research question
The findings from Donaghy’s study, the HSE and the work of others, indicate that safety failures might be more inclined to occur in smaller firms where self-employment is the norm. This raises the important question as to whether, for all that CDM 2007 is important and should be supported at every level, it is meeting the needs of all SMEs – particularly those at the smallest end of the scale – and, if not, how it could be improved?
The principal documents that have been consulted in this assessment are the HSE’s RR845 – Evaluation of Construction (Design and Management) Regulations 2007: Pilot study (2011) and Rita Donaghy’s One Death is too Many (2009). Two studies were consulted for details and perspectives from specific professionals: Pye Tait Consulting’s CDM – The Client Voice (2010) and Susan Morrow’s Does CDM enhance the designer’s role to safer and healthier construction(2010).
The findings of Ben Williams’ dissertation The CDM Regulations 2007: the cost of health and safety management for small and medium enterprises in the South East (2010) was consulted in order to understand some of the cost implications of CDM 2007 for SMEs, albeit in a specific geographic area.
Advantages and disadvantages of CDM
From the studies already conducted it emerged that some of the HSE’s own evaluation criteria for CDM 2007 had been met, but not all. The joint responsibility of designers and contractors is an advantage of CDM 2007, in that it encourages good communication and co-operation, as there is joint liability. CDM 2007 works well for architects and engineers where they have a high level of training or experience in construction and where the Quality CDM Co-ordinator is involved at an early stage. Where this is not the case, however, designers may find it difficult to carry out comprehensive risk assessments and the amount of paperwork required by CDM 2007 can put a strain on the relationship between time (costs) and safety (Gambatese et al, 2009).
Project teams are encouraged by CDM 2007 to be competent and to work collaboratively, and this can only be good for safety. It also advocates the collection of data on safety and ongoing monitoring and evaluation of health and safety issues. CDM 2007 has had positive effects on the construction safety in the larger companies (Donaghy, 2009, p. 26) and the cost issues associated with implementation were felt to be modest enough to be acceptable (HSE 2011). At the same time, it has been acknowledged that CDM 2007 has been less successful among smaller companies – for example, there are reports that, even when a Principal Contractor is on site, many sub-contractors claim ‘they carry the burden of financial and health and safety risk even if the Principal Contractor still has legal responsibility for the project’ (Donaghy, 2009, p.29).
The problem areas identified by HSE (2011) represent other disadvantages at the practical application stage of CDM 2007 – levels of bureaucracy, for example, and the fact that project teams are not always wholly integrated or communicating effectively; there is some doubt as to whether competence checks are fully carried out by all organisations, for example when employing migrant workers (Donaghy, 2009, p. 43).
4.0 FINDINGS & DISCUSSION
Industry Experiences of CDM 2007: What Works Well and What Causes Problems
The HSE (2011) evaluation derived its survey sample from across the range of construction professionals who were duty holders in the industry (total 565). These included 200 designers, 145 principal contractors and 46 sub-contractors, as well as 103 repeat clients and 16 occasional clients. Frontline Consultants, who carried out the research work on behalf of HSE, had derived five objectives and reported on these in terms of the extent to which each had been met. These are stated in the report as follows (Section 4.2, p. 13):
Simplifying the Regulations to improve clarity – so making it easier for duty holders to know what is expected of them
Maximising their flexibility – to fit with the vast range of contractual arrangements in the industry
Making their focus planning and management, rather than the plan and other paperwork – to emphasise active management and minimise bureaucracy
Strengthening the requirements regarding coordination and cooperation, particularly between designers and contractors – to encourage more integration
Simplifying the assessment of competence (both for organisations and individuals) – to help raise standards and reduce bureaucracy.
The findings of the pilot study suggest that Objective 1 is being met:
‘ … most of the respondents (87%) agreed that CDM 2007 was clearer than CDM 1994, and 96% agree that they clearly understand what their duties are under CDM 2007’ (HSE, 2011, Section 11.3).
Objective 2 is also deemed as being met as respondents confirmed they are using a number of contractual forms for CDM 2007:
‘ … most of the respondents (89%) agree that CDM 2007 can be used with the types of contract used in the construction industry’ (Section 11.3).
Results for Objective 3 were, however, less clear-cut: half of the respondents (46%) disagreed that the introduction of CDM 2007 was assisting them in lessening bureaucracy:
‘ … whilst most of the respondents (85%) agree that CDM 2007 assists in managing health and safety’ (Section 11.3).
Objective 4 was another instance where results were mixed, and the researchers concluded this objective, as with Objective 3, had only been partially met. Whilst half of the respondents agreed that CDM 2007 has helped bring about integrated teams (48%) plus better communications and information flow between project team members (50%):
‘ … a significant majority (ranging from 67% to 81% for the four relevant questions) of the respondents agree that CDM 2007 assists in facilitating coordination and cooperation’ (Section 11.3).
For Objective 5, three quarters of the respondents (76%) agreed that CDM 2007 was helpful in the assessment of the competence of duty holders:
‘ … most (83%) agreed that the client thoroughly assessed the competence of those organisations they appointed to work on the project; and most respondents (86%) agreed that the organisation who appointed them made a good job of assessing the competence of their organisation’ (see Section 11.3).
Impact of CDM 2007 on SMEs
Broadly, then, CDM 2007 was assessed by Frontline Consultants as more accessible than its predecessor, CDM 1994, and health and safety duties were understood; it is fit for purpose and can be used with most types of construction contract; it is assisting with improved health and safety; it helps with the facilitation of co-ordination and co-operation and methods of assessing competence were deemed to be proficient.
One of the less clear results relates to the degree of bureaucracy required to implement CDM 2007 – and although the HSE survey sample was not broken down according to scale of operation, it is likely that SMEs in particular will have found that extra paperwork and administrative systems have proved more onerous than the larger-scale, better-resourced construction companies. Also, the priorities of SMEs are often located in other areas of their business. Donaghy (2009) notes important differences between what affects larger and smaller businesses:
‘ … it is also important to note the disparity between large contractors and the significant number of small and medium sized enterprises (SMEs) making up the rest of the industry. While some larger companies have embraced the importance of tackling ill health issues it is often a matter of last resort for SMEs who are more focussed on the necessity to ‘make do’ and get the job done. For this group sometimes even the provision of adequate temporary welfare facilities proves a step too far.’ (Donaghy, 2009, p.46)
In the same way, although costs were not felt to be prohibitive by those participating in the HSE research: ‘the costs were viewed as moderate or lower’ (HSE 2011), Donaghy (2009) reported that some organisations had spent a great deal of money in order to comply. Further, she reported that although Principal Contractors might be seen to have the responsibility for CDM 2007, implementation was often passed on to sub-contractors:
‘… indeed there is more evidence of negative effects of price and delivery conditions being passed down to these levels [that is, second or third levels in the supply chain], the implication being that the further down the chain you go the more compromised the financial and safety considerations’ (Donaghy, 2009, p. 29).
Ben Williams (2010) expands on this in a study of SMEs in the south east of England, which investigates the implications of CDM 2007, and whether the current recession is having detrimental effects on their management of health and safety. Williams notes the disproportionate number of safety injuries and deaths on sites operated by SMEs, but did not find any ‘significant’ cost implications, nor any evidence that the economic situation had adversely affected health and safety management. Rather, he opined that investing in health and safety on construction sites for all workers is of the utmost importance, and that there is a lack of training and knowledge on heath and safety issues among SMEs (Abstract, p1).
Another problematic aspect of the implementation is that, whilst overall companies thought CDM 2007 assisted with co-operation, only up to half thought it had made an impact on improving communications and integration within teams. This is a disappointing finding, as Donaghy noted in 2009 that:
‘Another feature of the construction industry, with a few exceptions, is the absence of pre-planning and integrated teams before work starts on site – points constantly raised by Lathamb and Egan’ (p. 22).
Donaghy felt team working was important, particularly because of the high level of self-employed construction workers, which she believed was a factor
‘ … in low levels of training, job security, the likelihood of reporting serious accidents or unsafe practices or of encouraging team-working in the industry and all these factors are linked to the underlying causes [that is, fatalities at construction workplaces]’ (p. 36).
The research projects examined to provide secondary data were limited by the scope of the studies. Donaghy (2009) conducted research into 26 recent fatal accidents, Williams (2010) studied SMEs in the southeast of England and HSE (2011) evaluated the opinions about CDM 2007 of 565 construction professionals. In considering these three reports, therefore, the individual limitations of each one has to be acknowledged, and as yet no research into the impact of CDM 2007 on the whole of the construction industry in the UK has been undertaken. The research into fatal accidents is most useful for its qualitative data, as statistically it is a small sample. The HSE research does not differentiate between SMEs and larger companies, and the investigation into the costs of CDM 2007 is limited to one geographical region and not, therefore, representative of the UK as a whole.
5.0 CONCLUSIONS & RECOMMENDATIONS
CDM 2007 is a suitable and appropriate vehicle for those construction companies that have sufficient resources to deliver it, that is knowledge and understanding of the key requirements, skilled employees who are adequately trained and inducted into the health and safety procedures, and a desire and capacity to work collaboratively with others.
In particular, architects and designers need to have experience and/or knowledge of the construction industry to carry out an effective risk assessment at the design stage; and Principal Contractors must not seek to offload an inordinate level of responsibility for health and safety to sub-contractors.
There are some costs involved, and the consensus of opinion is that these are not prohibitive, although Williams (2010) warns of the need to monitor the selection of contractors by SME clients – where tender prices might have dominance over considerations of competency, and health and safety. Also, the additional costs of appointing a CDM Co-ordinator on notifiable projects may place a genuine burden on either or both of the smaller SME clients and SME contractors.
Scale of Operation
‘Small’ SMEs can have up to 50 employees, which is considered to be a sizable company in the construction industry and it is most likely to be at micro level (less than 10 employees) that difficulties with the implementation of CDM 2007 will be most keenly felt amongst the companies that Donaghy (2009) referred to as ‘those below the Plimsoll line’ (p. 11). These companies are unlikely to be able to afford to release employees for training courses, for example, even where grants for training are available (p. 48), or to afford the welfare facilities that are necessary for notifiable contracts. In the same way, competence checks may prove onerous for smaller organisations, and simplified competence procedures could be devised for micro enterprises, in line with the scale of the work they are undertaking.
One of Donaghy’s recommendations was that the construction industry should renew its efforts ‘to establish genuine consultative frameworks to encourage greater worker participation’ (2009, p. 18). This is one route to improving the lack of communication reported by the HSE (2011) survey, and it would also address the isolation of the micro companies and serve to rebalance their priorities so that health, safety and competence feature alongside profitability, or, indeed, economic survival.
There are grounds to be concerned about migrant workers, young workers and experienced workers aged 50 years and over. Special provision for the mandatory training – and re-training in the case of older workers – should be given some consideration and it may be that grants currently available would reduce accident and injury rates significantly, if specifically targeted at these groups, at least initially.
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