CDM Regulations 2015 and 2 topical issues

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1 Health and and Safety Executive Geotechnica 9 th July 2015 Warwick CDM Regulations 2015 and 2 topical issues John Underwood HSE Construction Division Construction Sector Safety Team john.underwood@hse.gsi.gov.uk 30 mins

2 Drilling Current Issues Drill tubes specification & quality Geological gas under pressure flammable / toxic / asphyxiant

3 New tubular drill rod with welded fitment

4 Magnetic particle NDT examination

5 New drill rod

6 Magnetic particle NDT inspection of new drill rod Weld between tube & fitment cracked Alloy steel requires complex welding & heat treatment process

7

8 How can this happen? Off the shelf product -v- made to order Purchaser specification -v- leave it to supplier Brand new tube direct from mill -vsecond hand oil industry tube Declared second hand material -vremanufactured tube (unused order repurposed) Conclusion buyer to specify

9 Drill rod specification & procurement Have you come across this issue? Scope for industry guidance?

10 Gas release under pressure Incident gassing for several months Bored piling operation into sandstone at 20m Fire & explosion Nearby gas main Coal field with surface outcrops Nearby old workings (pithead > 1mile) Nearest seam +100m depth High organic strata

11 Gas release under pressure Piped gas - struck during drilling -v- leak Biogenic gas from high organic content strata Coal / Mine gas Gas in old workings Gas evolved due to underground combustion Gas diffusing from unworked coal Oil bearing strata (unplugged borehole?)

12 Underground reservoir Schematic borehole Impermeable - eg clay Gas supply pipe (leak -v- strike) High organic content - eg peat Porous - eg sand & gravel, sandstone or fissures, faults, disturbed ground, mine workings, etc Organic coal, oil, etc

13 Gas emission flow rates Size of reservoir Number of escape routes Proximity of escape routes Rate of recharging Change in water table Change in atmospheric pressure

14 Coal Authority Guidance 2012 Applies to all drilling & piling near coal assets Leans toward pit-head works No direct application to biogenic gases Scope for BDA / FPS guidance?

15 Equipment & Systems of Work Desk study of area to be drilled Services location Coal Authority permission if drilling on their land OR into their assets Gas monitoring for flammables & asphyxiants (including methane / CO2 / CO) Rig suitable for zone = withdraw option Rig not suitable for zone = abandon (Design for gas handling / dispersion / collection)

16 Gas strikes during drilling Have you come across this issue? Scope for industry guidance?

17 CDM 2015 JU Does the drilling industry have anything to fear from CDM 2015?

18 Construction Design & Management Regulations (CDM) WAH CDM 1994 EU Prior to 1994 there were no dedicated construction management legal requirements Const Health Safety Welfare Regs 1996 CDM 2007 Revise to improve / simplify / align to EU Consultation industry responses CDM 2015

19 Outline of main changes Simplified structure Client greater responsibility Domestic client exemption removed CDM co-ordinator role removed Principal Designer role (PD) introduced Competence clarity added Notification is a stand alone requirement not trigger point for additional roles / duties Construction phase plan for all projects Threshold for appointments = more than 1 contractor

20 Guidance Package L Series guidance (L153) Possible ACOP in due course 6 CONIAC industry guides endorsed by HSE New CDM 2015 HSE website Have work done safely leaflet for small commercial clients Template construction phase plan Smartphone App Construction Phase Plan for small projects

21 Stress these changes: PC PD symmetry Amended notification threshold 30 days + >20 workers / 500 person days (Note 500 / 20 workers = notify >25 day project) Construction Phase plans on all projects Site Health & Safety File on all multi contractor projects Formal co-ordination threshold lowered More than one contractor = PD & PC

22 Stress this: Client / Principal Designer / Designer Responsible for Pre Construction Information Principal Contractor / Single Contractor Project Responsible for Construction Phase Plan Project Start Pre construction information Construction phase plan Project End

23 Domestic Clients: A domestic client will only be liable under CDM if they reject sensible H&S standards or impose poor standards Client duties automatically pass to the: First contractor, or the Contractor in charge Alternatively the client may arrange by agreement for the Principal Designer to take on the client s duties

24 CDM The Drilling Industry 1 Survey with tape measure is not construction Intrusive survey with spade, excavator, drill rig etc is construction and CDM applies Be aware that first or main contractor on site could be expected to take on Principal Contractor role Be aware that assessment of site, provision of drilling plan, providing eg ground capacity data may be classed as design work under CDM Be aware that the first or main designer involved could be expected to become Principal Designer

25 CDM The Drilling Industry 2 Be prepared to add to site Information: Pre construction information Construction phase plan Site health & safety file Be prepared to work with and advise: the client, principal designer, principal contractor Better coordination = better organised project and fewer problems. Please play your part but don t get taken for a ride read the Regs!

26 Conclusions CDM 2015 is easier to understand May allow greater flexibility who does what Guidance says small & simple = s&s paperwork The drilling industry should readily adapt to significant changes that CDM 2015 introduces Simplifying CDM means guidance becomes more important HSE encourages specialist sectors of the construction industry to produce guidance

27 JU Thank you for listening

28

29 CDM 2015 in force from 6/4/15 Transitional arrangements to 6/10/15 For multi contractor projects starting before 6 April 2015 and continuing beyond: Where no CDMC or PC already appointed the client must: Appoint PD and PC if the construction phase not started If construction phase started, appoint PC Where CDMC had been appointed: the client must appoint PD within 6 months of Regs coming into force CDM-C s duties (CDM2007) continue to apply until PD is appointed

30 What makes things work? Sensible client Permanent works designer willing to engage Rigorous contactor Temporary works designer who understands sequencing & systems of work Investment in understanding the ground, and existing structure/s Sensible timescale, sequence and method And legislation that encourages all this

31 What stays broadly the same Application to all construction projects Role of the Principal Contractor Part 4 technical standards for construction sites Schedule 2 welfare requirements Co-ordinators for health & safety both before and during the construction phase

32 Competence Getting the right people for the job Individuals Skills, Knowledge, Experience and Training Not about card schemes Body corporate Organisational capability Policies, structures, safe systems in place SKET KETS SNTE TESK SKTE TEKS Competence

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