by Roland Finch
This article is based on an NBS webinar of the same title featuring Sarah Susman, Head of Technical Development at Scott Brownrigg Architects, and NBS Technical Author Roland Finch. To view the webinar, please visit theNBS.com/events.
The construction industry operates under a considerable amount of health and safety legislation – and for a good reason. Before the Health and Safety at Work, etc. Act 1974, the industry regularly had more than 300 health and safety-related worker deaths per year. Since 2015, we’ve averaged between 30–46 worker deaths annually; although, our fatal injury rate remains at three times the ‘all-industry’ rate. In 2018–2019, there were 54,000 non-fatal injuries, which is approximately 366/100,000 employees and significantly above the UK average of 254/100,000. There were also 79,000 work-related ill-health cases reported for that timeframe, with 69% being musculoskeletal disorders.
When looking at asset-related health and safety, one glaring example of construction and management negligence is the 2017 Grenfell Tower fire tragedy that cost 72 individuals their lives. The fire started in a fourth-floor flat and quickly spread, using the building’s envelope as a conduit. Within minutes, all sides of the 24-storey tower were in flames. The subsequent inquiry concluded that the main cause of the fire’s spread was the presence of aluminium composite material (ACM) cladding, which was installed as part of an ongoing refurbishment from 2012 to 2016. However, several non-compliant systems also contributed to the disaster, some which had been there since its original build in 1974. Later, when BRE performed tests on cladding samples from 34 high rise buildings across 17 different local authorities, all of them failed the combustibility test. These findings highlighted a significant fault in how we approach health and safety in construction.
In the wake of this information, the Government commissioned a thorough review of building regulations and how they address fire safety. Commonly known as the Hackitt Report, the Independent Review of Building Regulations and Fire Safety was issued in May 2018. In response to its findings, when the RIBA released its new Plan of Work 2020, it introduced new measures that bolster how it addresses health and safety to align with the report’s recommendations.
Key legislation and regulation
What kind of health and safety legislation applies to the construction industry?
The amount of construction-related health and safety legislation is extensive, with the key piece being the Health and Safety at Work, etc. Act 1974. No one can be an expert in all of it; however, if you are going to design and construct something that can be safely occupied and used, then you must at least be aware of it.
Who regulates health and safety, and where can I find guidance?
In the UK, we are regulated by the Health and Safety Executive (HSE), which provides information and guidance in all aspects of health and safety, placing the welfare of people at the core of everything we do in and with our built environment – at work, at play, at rest. Also, in response to the Hackitt Report, HSE will be overseeing a new building regulator that will focus on the safe design, construction and occupation of high-risk buildings. You can read more about that on their website under HSE, Guidance, Building Safety. While HSE serves as a vital source of information, instruction and guidance, it is ultimately up to you to ensure that your projects and buildings comply.
Pre-construction and Hackitt Report recommendations
What is pre-construction information and when should it be provided?
According to the Construction (Design and Management) Regulations (CDM 2015), ‘A client must provide pre-construction information as soon as it is practicable to every designer and contractor appointing, or being considered for appointment, to the project.’ CDM 2015 goes on to define pre-construction information as:
‘…information in the client’s possession or which is reasonably obtainable by or on behalf of the client, which is relevant to the construction work and is of an appropriate level of detail and proportionate to the risks involved, including–
- (a) information about–
- i. the project;
- ii. planning and management of the project;
- iii. health and safety hazards, including design and construction hazards and how they will be addressed; and
- (b) information in any existing health and safety file…’
What does the Hackitt Report recommend regarding specification?
In its recommendations, the Hackitt Report highlights the need for better specifications and testing around construction products and systems, improving information quality and providing more precise and transparent tracking.
These recommendations fall in line with the ‘golden thread of information’ promoted by the report. Simply put, the golden thread is living, accurate and up-to-date building information that is digitally housed and covers everything from design through operation and end of life.
The RIBA Plan of Work 2020
While the Plan of Work has been addressing health and safety for years, the 2020 version strengthens its language and requirements, taking a proactive approach and providing a roadmap for people to follow throughout the life of a project and building. It also includes the need for an identified principal designer to prepare a health and safety strategy, with the support of a knowledgeable adviser if necessary.
Stage 0: Strategic definition
Despite the monumental importance of health and safety, too many people involved in specification still see it as a stage 4 activity, but it isn’t. Under CDM 2015, the client has ultimate responsibility for health and safety, so even the most basic information is essential to that strategy.
Drawings and other documents are a crucial source of data. They give you information on proposed construction methods, product choices and even the thought processes around how the building will be used. They can also provide you with information about things that are known to exist – e.g., lead, asbestos, contaminated land, services or nearby activities that might affect the work.
Stages 2 and 3 – Concept design and spatial coordination
When it comes to health and safety, there is a fair bit of overlap between the various stages. However, it is during stages 2 and 3 where you will do things like:
- Implement design risk management processes – identifying, recording and analysing any significant or unusual foreseeable health and safety hazards (like electricity or chemicals).
- Reduce or eliminate identified risks and record control measures, coordinating information from the architectural concept and outline specification and ensuring they align with other project strategies and the project brief.
- Update the pre-construction information.
- Initiate a health and safety file and update the design risk management process, if needed.
- Include the critical health and safety design decisions made and recorded during pre-construction in the stage report.
Regulations state that the information should be proportionate. You do not need to include things that a reasonably competent contractor would readily know about, but you do need to add anything that the contractor might not be aware of.
Stages 4 and 5 – technical design and manufacturing and construction
At this point, the information becomes even more detailed. You’re integrating pre-construction information, going through tender phases, and appointing the principal contractor who will be primarily responsible for creating the construction phase plan and updating the health and safety file. It is important to note that, at this stage, the client is responsible for notifying the relevant statutory authorities.
Essential at this point of the specification is determining how the contractor proposes to address the health and safety issues identified in stage 0. How are they going to build the asset? How are they going to do it safely? What is their site control plan, and how will they ensure the safety of workers and the public (visitors, etc.)?
Stages 6 and 7 – handover and use
During these final project stages, the RIBA Plan of Work 2020 says that you should:
- Implement a building management and maintenance plan that secures the health and safety of both users and the facilities management team.
- Conduct a post-occupancy health and safety evaluation around building maintenance and use.
- Conduct regular reviews and update the health and safety file throughout the building’s life and pass that file on to any future owners.
Every element in the Plan of Work and the specification process integrates vital health and safety information. This needs to be detailed and accessible at every stage, with a clear and transparent line of data from beginning to end to ensure continued compliance and a high level of accountability.
Final thoughts and take-aways
Every design decision has a potential impact on health and safety. Where is the site, and how does that affect your workers? Will you need multiple storeys to meet your needs, and what health and safety implications does that have? If you add this design feature, how will that impact the safety of other elements within the building or structure? Simple decisions can have an overarching effect on what happens next. So, we can’t emphasise enough how important it is to address health and safety from the beginning, interweaving it into every aspect of your project and building.
A few final, key things to remember are:
- Health and safety is everyone’s responsibility. It is not an isolated process; it is not somebody else’s job; it is not something to just be left to the contractor. You can’t just design buildings and leave health and safety up to somebody else.
- Read preliminaries and work sections together and, most importantly, prepare them together. Health and safety is part of an over-arching specification that outlines the methodologies used throughout the life of an asset from design to demolition. Therefore, the only way to ensure compliance is to treat it as a whole. It is your responsibility to effectively communicate with everyone who is producing any part of a specification that you’re involved with.
- Continuously feed and maintain the golden thread of information that shows that you consistently followed the rules set out at the start of the project. Keep thorough records of decisions made, including when they were made and signed off and by whom. Record every action you take and how you accomplished it, and maintain documentation on things like maintenance instructions, guarantees, certifications and compliance evidence, etc.
NBS Chorus can help to deliver specifications that are in line with the health and safety strategy defined in the RIBA Plan of Work 2020 through both performance and prescriptive specification and using editable clauses supported by technical guidance. Our content is continuously evolving, informed by research, user feedback and industry drivers, and we are continually reviewing it to improve clarity and usefulness.
Health and Safety and the RIBA Plan of Work is part of an NBS webinar series addressing various elements of the new Plan of Work 2020, including fire safety, sustainability, conservation and intelligent design. To see it or other parts in the series, please visit theNBS.com/events.