The Construction Design and Management Regulations 2015 set out the legal framework for managing health and safety in construction projects in Great Britain. Understanding the requirements of CDM 2015 as they apply to RAMS documents helps both those producing the documents and those reviewing them.
Who CDM 2015 applies to
CDM 2015 applies to all construction projects. The specific duties it creates depend on the size of the project and the roles involved. For RAMS documents the most relevant roles are the principal contractor — the organisation responsible for managing the construction phase — and contractors and subcontractors carrying out the work.
The principal contractor's duties relevant to RAMS
Under CDM 2015 the principal contractor must plan, manage, monitor and coordinate the construction phase. Contractors must cooperate and provide relevant information about their work and risks. Principal contractors commonly require and review subcontractor RAMS as part of their site procedures; CDM 2015 does not impose a universal requirement for a document with that name from every subcontractor.
The principal contractor must also ensure that all workers are briefed on the matters covered in the RAMS before they start work. A RAMS that is approved by the principal contractor but never communicated to the operatives on site does not satisfy this requirement.
The contractor's duties relevant to RAMS
Contractors must plan, manage and monitor their own work to ensure it is carried out safely and in accordance with the construction phase plan. Producing a RAMS that accurately describes the planned work and the controls in place is how contractors demonstrate compliance with this requirement.
A RAMS produced after work has begun, or one that describes a different method than the one actually being used, does not satisfy the legal obligation. The document must reflect the actual planned approach.
Notifiable projects
Projects that will last longer than 30 working days with more than 20 workers working simultaneously, or that will involve more than 500 person-days of construction work, are notifiable to the HSE. Notification does not determine whether CDM duties apply: construction phase planning and risk management are required on non-notifiable projects too. The level of detail should be proportionate to the work and its risks.
What CDM 2015 does not specify
CDM 2015 does not prescribe a specific format for RAMS documents. It requires that the risks be assessed and controlled and that workers are briefed — but the format in which this is documented is not mandated by the regulations. Valify uses a 15-section review framework. This is not a prescribed legal format or a guarantee that all applicable requirements are covered; suitable RAMS can use different structures.
Competence requirements
CDM 2015 requires that all persons appointed to construction projects have the skills, knowledge, experience and training necessary to carry out their role. RAMS documents should reflect this by specifying the competency requirements for the work — relevant qualifications, certificates and training — not just listing job titles.
For the regulations as a whole rather than the RAMS-shaped part of them, CDM 2015 explained walks through every duty holder, the notification threshold and the three documents the regulations name. Who is responsible for producing a RAMS settles the question that causes most of the arguments. Which documents Valify can review covers what can be submitted together.
This article is general guidance on UK construction documentation practice. It is not legal advice, a compliance certification or a substitute for review by your own qualified health and safety personnel, who remain responsible for deciding whether any particular document is adequate. See our disclaimer.