CDM duties for a scaffolding contractor, in practice

CDM is the framework the rest of a scaffolding firm's obligations sit inside, and the practical question is rarely whether it applies. It is which role the firm is holding on this particular job, because that determines what is expected of it.

The role can change between jobs, and sometimes within one

On most work a scaffolding firm is a contractor, working to a principal contractor's arrangements. On a small domestic job with no other trades it can find itself holding more than that. And where it is producing a bespoke design, it is taking on design responsibilities in addition to construction ones.

Firms get caught out when the role changes and nobody notices — typically on small jobs, where the assumption that somebody else is co-ordinating turns out to be wrong. What the duties actually are for each role is set out in the current regulations and HSE guidance, which are the authority; what is worth doing operationally is establishing which role you hold, in writing, before work starts.

Information flowing both ways

The duty that scaffolding firms most often under-serve is information. A principal contractor needs to know what the structure is designed for, what it must not be used for, when it changes, and what the handover covers. Equally, the scaffolding firm needs information from them — other trades' programmes, site constraints, what the structure will actually be loaded with.

Where that exchange is informal, the predictable failure is a structure loaded beyond what it was designed for by a trade that was never told, and a scaffolding contractor who never asked what it would be used for.

In practice: the domestic job with no co-ordinator

A firm takes a small job on a private house — a roof repair, one other trade, a short programme. Everyone assumes the builder is co-ordinating. The builder assumes the homeowner arranged it. No one is, and when the roofer asks for a section of guardrail removed to get materials up, there is no mechanism for that request to reach anybody who should assess it.

The scaffold is fine. The arrangement around it is not, and the scaffolding firm is the only party on site with the competence to notice.

Common mistakes

• –Assuming the contractor role applies without checking what the job actually is
• –Not noticing that producing a bespoke design brings design duties with it
• –Small domestic jobs where everyone assumes somebody else is co-ordinating
• –Telling the principal contractor what the structure is, but not what it must not be used for
• –Not asking what the structure will actually be loaded with
• –No written record of the role held and the information exchanged

What to establish before work starts

Most of the difficulty comes from ambiguity that could have been removed in a five-minute conversation. Who is the principal contractor, what arrangements exist, who co-ordinates other trades, and what is the route for another trade to request a change to the structure.

On larger sites that is usually clear. On small and domestic work it frequently is not, and the scaffolding firm is often the only party present with the competence to notice that nobody is co-ordinating anything.

Getting this right

The information duty runs both ways and is the one most often under-served. Tell the principal contractor what the structure is designed for and what it must not be used for — the handover record is the natural vehicle — and ask what it will actually be loaded with, because that answer sometimes changes the design.

• –Establish in writing which role you hold before work starts
• –Notice when producing a bespoke design brings design duties with it
• –On small and domestic jobs, confirm who is co-ordinating rather than assuming
• –State what the structure may not be used for, not only what it is
• –Ask what it will be loaded with, and by whom
• –Check current duties against HSE guidance rather than a summary

Where this connects: information has to go both ways

The duty scaffolding firms most often under-serve is information, and it runs in both directions. A principal contractor needs to know what the structure is designed for, what it must not be used for, and when it changes. The scaffolding firm needs to know other trades' programmes, site constraints and what the structure will actually be loaded with.

Where that exchange is informal, the predictable failure is a structure loaded beyond its design by a trade that was never told, erected by a firm that never asked what it was for. The handover is the natural vehicle for half of it; the other half needs somebody to ask a question nobody is prompted to ask.

• –State what the structure may not be used for, not only what it is
• –Ask what it will actually be loaded with, and by whom
• –Establish in writing which role you hold before work starts
• –Confirm who co-ordinates on small and domestic jobs
• –Record the information exchanged, not just that it happened
• –Notice when producing a design brings design duties with it