3.2 Construction (Design Management) regulations path safety systems
Why do I need a safety system?
By taking on the task of managing paths in the Scottish mountains you are also taking on the responsibility to minimise the risk posed by natural hazards, work activity and path design. This legal duty of care applies equally to all building work, including pathwork, and is set out in the Construction (Design and Management) (CDM) Regulations 1994. To work safely, and comply with CDM regulations, a path safety system must be applied to every site and every path management project.
Safe sites do not happen by accident, but accidents do happen on unsafe sites.
CDM regulations do apply to path construction activity. CDM applies to any commercial or public construction work that takes more than 30 days to complete or involves more than five workers on site. In practice, all access projects require risk assessment, careful design, well-supervised site work and some form of reporting back; therefore, a common path safety system is applied to all sites and projects. This system also meets the needs of CDM.
The effort and time spent on safety planning and preparation will obviously be less for regular tasks on a well-known site – such as a quarterly maintenance visit – and much more extensive and complex on the rebuilding of a new site – usually involving formal design work, competitive tendering and specialist path contractors. Whatever the project, a safe site requires thorough and constant application of a path safety system.
What are my safety objectives?
Having a safe access site involves many factors: a good design, the right materials, well-trained workers, the right tools for the job, a first-aider, the weather, not having visitors wandering about. The objective for the path manager is to bring all these things together by planning ahead, minimising risk, communicating, coordinating and reviewing:
- Plan the whole project in advance and look at the potential hazards and safety implications of each stage of the project.
- Look for changes to the project that will minimise the potential risks and build these in to the job.
- Tell each person involved what they have to do to work safely; report on progress and changes to the plan, and ensure that everyone understands and responds to changes that may affect safety.
- Ensure that the members of the team work together and do not put each other at risk; also ensure that the safety procedure in place when the path was built extend into the maintenance phase.
- Learn from experience by reviewing each path project, looking for ways to potentially improve safety, and applying lessons learned to future projects.
It is neither possible nor desirable to render a mountain path totally safe. Rather, the aim is to understand and predict the hazards inherent in working on a steep, remote and exposed hillside, and to fit into this testing environment by working at the right time, with good techniques and well-trained staff. Often, this involves working with the environment by using on-site materials, working only in the summer and not working in wet conditions. Safe working must largely respond to and work around natural hazards, and not try to eliminate them through overconstruction or heavily mechanised working.
Path management has generally a good safety record both for work teams building the paths and for the public using paths after they have been repaired. Most workers are motivated, considerate and attentive to safety.
Working on path repair is very different from going for a walk in leisure time. Whatever the terrain, when at work HSAW 1974 always applies. The employer is responsible for ensuring all work is carried out as safely as is reasonably possible; the employee is responsible for working safely and not putting others in danger. Under CDM Regulations, construction work carried out on a mountain requires a safety plan to be prepared and operated and overseen by a Planning Supervisor. There is no exception to this rule.
Compared with building work on a flat lowland site, mountain pathwork is a relatively simple type of construction, but takes place in a remote and uncontrolled environment. Pathwork tends to use few chemicals or power tools and has little subcontracting, but work takes place on steep slopes, in poor weather, in the middle of nowhere. Conventional safety planning often focuses on building materials and handling, whereas for mountains the focus is weather, fitness, remote communication and even navigation! Select the key hazards for your sites and concentrate most effort on understanding and minimising exposure to them.
The safety plan should focus on avoidance of risk. Once key hazards are identified and understood, think about the factors which increase or decrease risk. The weather is seasonally affected and changes daily, therefore it may be best for work to take place between May and September. The weather forecast can be faxed to the teams every morning and the tasks that are safe for that day can be decided. On wet days, borrow pits and surfacing will be safer than boulder moving on a steep slope.
Safety takes precedence
For work to start in May, tenders will have to go out in January, which may not fit well with the financial year starting in April. Such administrative arrangements will have to fit around safety considerations for both the organisation and the timing of work. This also extends to external organisations such a grant-awarding bodies, which will have to take decisions in time for safe working to commence. If decisions are delayed, the only additional considerations should be financial; there should be no attempt to complete work that season, and the risk should not be increased on site by work extending into winter.
Who does what
Working safely requires a team effort. CDM is targeted at improving communication among all those involved, and the regulations set out clearly defined roles, each with specific responsibilities. In pathwork, the key role of planning supervisor is usually taken on by the project manager – this is the most complex role and usually requires both training and supervision for it to be performed effectively and to prove ‘competence’ as required by the act. It is the norm in access project management for more than one role to be taken on.
|Title in CDM regulations||Key responsibilities||Who performs it in pathwork?|
|The client||Appoints competent designer/planning supervisor, maintains final build||Site owner or factor; Public body or charity|
|The designer||Assess and design a structure that is safe to use and safe to construct||Path surveyor; Path manager|
|The planning supervisor||Supervises project, prepares safety plans, communicates, notifies HSE||Path manager or in-house/consultant specialist.|
|The principal contractor safe working on site.||Prepares risk assessments and manages company leader||Team leader or contract|
|Health and Safety Executive||Receive Safety plans, ensure compliance, provide advice||Local HSE field office|
Devising your own safety system
There are many systems for managing safety, each adapted to the needs of particular industries, types of construction and administrative arrangements. In access and outdoor construction work there are three main approaches:
- Manage it directly: The manager acts as planning supervisor. The majority of pathwork is carried out this way. The advantage is direct control of safety on your own projects; the drawback is time and checking that the right decisions are made.
- In-house specialist: This approach is suitable in larger public organisations. The specialist acts as planning supervisor throughout the project, sometimes combining this with the role of quantity surveyor. The advantages of having someone else do this for you needs to be weighed against lack of control and finding solutions that really are workable in a mountain environment.
- Safety consultant: The safety consultant is appointed specifically for the task and is usually a qualified planning supervisor. This approach has the advantage of specialist knowledge and an ‘objective’ opinion but is costly, 2–4% of project value. Several access charities use a safety consultant to provide training, advice and an overview while continuing to act as the planning supervisor.
- Quality of roles: It may be necessary, and even make sense, where one individual manages the contract to carry responsibility for design and planning supervision. It is well worth contacting your local HSE office for advice.
What to include
Safety planning does not have to be a complex or onerous task. The essential/minimum stages required in the process are:
- appointing a planning supervisor;
- preparing a pre-tender plan (or pre-work plan, if work is not going out to tender) and a safety plan with a risk assessment attached;
- informing the HSE of the project and monitor the project;
- producing a site safety file and handing it over to the owner on completion.
Several simple and very useful steps can be added, particularly if the main contract is let to a team that is separate from the managing organisation:
- Prepare a method statement describing the team’s experience and an analysis of the main jobs and the safety procedures to be used.
- Provide a common set of forms for each stage of the process. Everyone should be familiar with and trained to use the forms.
- Prepare generic risk assessments for the most common jobs and hazards. This will help standardise good practice in dealing with hazards. However, they must be modified for use on each particular site and situation.
Some things are unnecessary and overly complex in a safety procedure, for example:
- Very large safety plans: plans need only be 10–30 pages long, and all site workers should be able to read them easily. Anything larger will be too complex and is unlikely to be read.
- Previous safety plans: these are useful for looking at past experience; however, a new plan is needed for each project, and previous plans should not be kept on site.
- Support information: additional information, such as machinery logs and manuals, or design guides for particular features, is often needed and the relevant person should keep this; however, do not clutter the plan with extraneous information.
Whatever safety system you decide to develop and use, there are some pointers on good and useful practice which may help:
- Keep it simple: the best plans are short and readable.
- Be focused: spend most time on assessing the most prevalent problems, with the highest risk levels. Move on to routine hazards once you are sure that the key hazards can be managed.
- Be specific: produce a new plan for each site, starting from first principles each time. Learn from experience, but do not expect any two projects to be the same.
- Use a standard approach: a set of simple forms will speed the process up and make sure you do not miss out any of the steps.
- Keep records: keep a written record of all stages of the process – the law requires that a copy of the plan is kept on site, and that the site’s owners and long-term managers have a copy.
- Have clear responsibilities: any confusion over who does what could lead to omissions or duplication of effort. Planning supervisors should report and discuss project safety plans and any problems with their line manager or a safety specialist. The supervisor’s role is to coordinate activity and not to take sole responsibility for safety.
Training and support
Whoever takes on the duties of planning supervisor must be able to demonstrate their competence for the job. Competence includes factors such as experience, training and demonstrated ability. There are several ways to gain the knowledge needed and to keep it current and up to date:
- Short training courses such as:
- ‘Plant Operators Safety Awareness Training’: a 1-day Construction Industry Training Board (CITB) course that is mandatory for all planning supervisors.
- There are several 1-day ‘system’ courses about the practicalities of running your own safety system for outdoor and environmental work.
- Membership of one of the several trade associations, such as the Association of Planning Supervisors. This is not a requirement, but is very useful for keeping up to date.
- Update mailing from HSE, which provides useful general advice, but is not targeted at outdoor work. Unfortunately HSE does not give advice on specific projects.
- Specialist advice from an in-house or safety consultant.
- Meetings and training events through UPAG specifically tailored for pathwork.
- Work shadowing an experienced safety manager in the construction industry or through the network of UPAG members.
Example project timetable: Annat to Coulags
|ANNAT to COULAGS: the safety process from first survey to long term maintenance….|
|Date||Documents||Who was involved||See sub-section…|
|Survey||2.5 Red surveys|
|First site visit||4.2 Preparing a competetive tender|
|Design and spec||4.2 Preparing a competetive tender|
|Pre-tender plan||3.3 Safety assessment|
|Tender site visit||3.4 Risk, hazard and control|
|Method statement and risk assessment||3.4 Risk, hazard and control|
|Contract selection||3.6 Safety performance|
|Safety Plan||3.6 Safety performance|
|Work start meeting||3.7 Maintaining site safety|
|During the contract…site visits||3.7 Maintaining site safety|
|Close contract||3.7 Maintaining site safety|
|Safety file||3.7 Maintaining site safety|
|Maintenance and safety audit||3.7 Maintaining site safety|