The IOSH Sports Grounds and Events Group networking event to discuss CDM took place on 12th November and attracted participation from the event safety community across the spectrum from festivals to theatres and a significant element from the exhibition world. The event was opened by the Chief Executive of IOSH, Jan Chmiel followed by a keynote presentation by Gavin Bull, the HM Inspector at the HSE responsible for implementing CDM 14. The meat of the event comprised presentations by the eGuide (exhibitions and conferences), A Guide (Arenas), Purple Guide (festivals and outdoor events) and the ABTT (theatres).
The implementation of CDM 14 is behind its original timetable so the HSE did not actually have anything new to say and did not present a case for change or highlight any benefits beyond compliance for its own sake. The various industry guides agreed to incorporate the changes as and when they come into effect without raising any of the issues that might arise. In fairness, since the consultation has not taken place it was difficult to get into specifics but it would have been helpful to get a view of some of the challenges perceived by the various event sector bodies at industry level. There was a prevailing view that we are all compliant anyway and all we need to do is role map across to the various CDM functions.
This view did not go unchallenged and there was some spirited questioning from the floor which highlighted that the HSE’s presentation raised more questions than it actually answered. Gavin Bull dismissed a question regarding Safety Advisory Groups (SAG’s) as ‘just licensing’ and gave a very opaque answer on who exactly the enforcing authority would be on site, thus ignoring the very significant potential conflict of regulatory oversight that could arise. The attendance list was a veritable who’s who of the big players but there was no consideration of the challenges faced by small events from conferences to country fairs that do not have the resources to conduct ‘role mapping’ exercises. Simplification is nominally positive but removing the ACOP does mean that a lot will be down to interpretation and that will pose challenges for all and disadvantage smaller concerns.
There were some significant absences from the debate. The aeo was not represented and with one notable exception (Reed Exhibitions) neither were any of the large exhibition organisers. Also absent were any of the larger players from the exhibition general contracting sector who will have a significant part to play in complying with these regulations. These voices need to be heard and must participate in the consultation when it is launched.
There was much discussion around the CDM roles of Client, Designer, Principal Contractor and the CDM Coordinator. One accepted view was that the event organiser could be all of these things. Then again so could a company building a large complex stand within an event. One glaring omission was the recognition that CDM was designed to be applied to building sites which could be in place for many months or years. An event transforms from construction to finished produce and back to construction activity in a matter of days and is in reality a collection of lots of different building sites with a plethora of clients and designers not just one. The HSE kept returning to the mantra of the definition of construction. The reality is, however, that whilst conceptually similar, the context at events is entirely different.
IOSH should be congratulated in in pulling together this forum and such a diverse group of serious event safety professionals. Whilst we may not have got the clarity of answers we wanted, it is to the HSE’s credit that they have engaged with the events industry across the spectrum. Many attending not hitherto familiar with this issue will have learned a great deal and there is no doubt that the 12 week consultation when it comes will be more robust for it.