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Applying 2015 CDM regulations to ground investigation: Jo Strange

The new 2015 CDM regulations arrived on 6 April but the result is a mixed outcome for ground investigation.

For example, there is no further clarity on the applicability of CDM. A ground investigation providing design data for a development or structure definitely falls under CDM. However, does ground investigation which is not associated with a structure, such as for due diligence or environmental regulation purposes, fall under CDM? This is a grey area.  

HSE guidance L153 Section 2 states: “‘construction work’ means the carrying out of any … civil engineering … work and includes — (b) the preparation for an intended structure, including … exploration, investigation (but not site survey) and excavation (but not pre-construction archaeological investigations)…”

Worst case this means that any excavation including trial pits could be deemed to be “civil engineering” under CDM, although it begs the question how different is a trial pit for contamination sampling from an archaeological one, which is exempt? Taking the “safe” default position that any excavated hole is civil engineering puts most ground investigations under CDM.

Fewer standalone investigations would become notifiable projects under the 2015 regulations due to the relative short period of work and the small teams involved. However, the notifiable or not question has less impact in the 2015 regulations, as it is no longer triggers a different level of management.

The principal contractor (PC) and contractor roles still exist under CDM 2015 but the PC role is not now triggered by the project being notifiable.

In many cases the company undertaking the ground investigation will be required to take on the role of PC, at least for the duration of the investigation (assuming more than one trade is involved). However, beware of this situation with a domestic client – which is increasingly the case for basement schemes – where the ground investigation contractor could also be taking on client duties by default. In this situation, I suggest requesting such clients to formally appoint the principal designer to perform these duties for consistency across the project lifetime.

The emphasis in the 2015 regulations is that health and safety planning is proportionate. Therefore, while a construction phase plan will be required for each investigation, it doesn’t need to be more than a few paragraphs or chapter, just specific, relevant and sufficient.

So what does CDM 2015 really mean for the ground investigation industry in terms of changes? Effectively, if site investigation works were being properly planned and managed before, then not a great deal. The message from CDM 2015, as I see it, is to integrate health and safety management so it is simple and keeps everything safe, and that compliance with the regulation is not an end in itself.

Jo Strange is technical director of CGL

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