CROSS Safety Report
Actively seeking to identify hazards
This report is over 2 years old
A reporter investigating a near miss incident raises concerns that an active prompt to seek out hazards is not being undertaken on innovative construction design and methods.
Key Learning Outcomes
For the design team:
Innovation always requires care, although it is not to be discouraged needlessly as it can be a driver for safety
Prior to the commencement of major innovative works or high risk activities, consider carrying out a joint risk review by designers, contractors, and others as appropriate at a suitably high level across all disciplines and organisations
The joint risk review can promote an active prompt to seek out hazards
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A reporter was investigating a near miss incident involving concrete construction in which precast and in-situ concrete were used in combination (see report 529 which discussed risks from offsite manufacture and hybrid construction in). This type of construction offers efficiencies and, as in this instance, can reduce the number of hours worked at height.
It does however bring its own risks, and these need to be understood. The design had developed from all in-situ construction to a hybrid precast/in-situ over a series of design meetings. It was the combination of precast and in-situ construction that led to the near disaster in which multiple fatalities were a real possibility.
Concerns raised during the investigation
During the investigation, the reporter was presented with a document developed from the 2007 CDM Regulations. This was a CDM coordinator’s standard agenda for a design review meeting. One heading was ‘Significant risks identified during design’ which then elicited the following two questions:
Since the last meeting have any significant hazards been identified that are likely to affect the works? (Yes/No)
If ‘yes’, please describe and confirm they have been added to the risk register
Space was then given to describe the new significant hazards. There was however no Q3 which might have been: If ‘no’ how do you justify that no new significant hazard has been introduced?
The absence of this question allowed for a passive negative. Such an approach is complacent. There are also behavioural implications: without Q3 the CDM coordinator and the design team has a much simpler life of it than if their answer to Q1 is ‘Yes’.
Secondly, if a significant new hazard had been introduced, surely this would be seen as a sign of failure, as design work should eliminate hazards? Third, the design team was innovating, and it was working outside its area of experience; with no active prompt to seek out hazards, and the requirement to commit this to record, why would they go seek them out?
Whilst the role of the CDM coordinator is now behind us, the duties to find hazards are not. Under CDM Regulations 2015, principal designers are asked to ensure that potential hazards are sought out diligently, and the industry is asked to apply a standard of active negative as a part of the process to assure that this is done.
Under CDM Regulations 2015, principal designers are asked to ensure that potential hazards are sought out diligently, and the industry is asked to apply a standard of active negative as a part of the process to assure that this is done
Expert Panel Comments
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Report 529 which discussed the risks from offsite manufacture and hybrid construction contains comments from CROSS on the issues of divided responsibilities. It also emphasises the fact that procedures on their own are not enough to provide safety. They are only a part of the process which demands clear thinking about what might and could go wrong, and the allocation of duties and responsibilities.
The present report raises some observations on the standard agenda that is quoted:
The heading ‘Significant risks identified during design’ should really have been ‘Significant residual risks arising from the design’ i.e. those where it was not possible to eliminate or significantly reduce a risk, and on which others would welcome information
The suggested Q2 should more correctly have been ‘What new hazards have been identified which have given rise to significant residual risk?’
Q3 as suggested may not be necessary. The emphasis should be on whether the designer has implemented an appropriate risk management process. If the designer has, then this would have identified any further hazard.
The above is now thought by some to be complicated by the fact that in CDM Regulations 2015 has removed hazards from the process, concentrating on risk alone. Innovation always requires care, although it is not to be discouraged needlessly as it can be a driver for safety.
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