CDM - Construction (design and management) regulations have been a pet subject of ours for a long time. Their application, their enforcement, what they are, what they are not and who enforces have all been covered. We've always been supportive of the theory - identify certain roles and responsibilities and make sure the people with those roles create a safe workplace. We've also maintained that, if you do it right, you've nothing to worry about. Things are about to change....but maybe they're not.
As previously reported, CDM has always applied to our sector but HSE policy has been to not enforce it, instead enforcing the Health and Safety at Work Act, allowing our sector to manage responsibilities. That approach has worked.
As recently reported, CDM has been reviewed, and HSE are consulting on changes. The changes look good; they're designed to comply with EU directives (to avoid big EU fines) and simplify things to better engage SMEs. But that's in Construction; there's nothing to say how it will actually apply to entertainment and events. All it says is that its rules willl apply to 'projects' with 2 or more contractors. Stage, light, sound, video, crew, catering, power....that's 2 or more; DJ and magician setting up a kids' party....does that count?
Needless to say, our response reads similarly to other organisations in the sector. Please be less vague, please assess the potential impact. Construction already work with the regulations, any simplification will decrease the regulatory burden. For entertainment, any decision to introduce without any word of guidance, any measure of where it should apply or any assessment of its financial impact will be seen as a huge increase in the regulatory burden - not something Government want to see. Very recent developments have seen a slightly different direction from HSE. CDM changes are being overseen by HSE Construction, their Entertainment division is looking now at the policy to not enforce CDM. The impact of changing that policy can and should be assessed...and it will. It goes without saying that we'll be helping with that work.
In the nmeantime, we urge you to view the consultation and respond before the deadline. If you would like a copy of our response, email firstname.lastname@example.org.
The HSE consultation and response details can be found here