FAME has responded to the HSE consultation on the review of the CDM Regulations. There was a deep division of opinion among members about the proposal to exempt ‘pre-construction archaeological investigations’ from the revised regulations.
Those in favour argued that CDM should not be triggered unnecessarily by pre-construction investigative work, and that exemption would provide greater clarity over the vexed question of archaeologists as Principal Contractors. Those against were concerned that exemption would marginalise archaeology from the construction process and potentially jeopardise health and safety.
We have eventually decided to support the proposal in principle, with the caveats that a clear definition of ‘pre-construction’ is required, and that archaeology should be cited alongside other pre-construction investigative works within the regulations.
We would like to see a clear statement that archaeological work during, or directly associated with, construction will fall within the regulations, and that in these circumstances archaeological organisations should be appointed as Specialist Contractors but not as Principal Contractors. We would also like to see greater clarity on health & safety training and accreditation, and on how archaeological documentation is included as part of the CDM design process, and would welcome the preparation of sectoral guidance on the regulations.
The full FAME response is here.
For those wishing to submit their own response, visit the HSE website.