I’ve seen the reference to The CDM Regulations mentioned a few times on this electrical forum and could write several pages on the subject but would initially at least appreciate clarification from the IET on the wording in IET Guidance Note 3 which has the following subsection under section 1, General Requirements in my 2018 version. I’ve highlighted the particular wording I’m interested in in red font.
1.6 Record keeping
132.13
It is a requirement that the appropriate documentation called for in Regulation 514.9, Part 6, and (where applicable) Part 7 is provided for every electrical installation.
Chapter 65 Appx 6- Guidance to recipients
Records of all checks, inspections and tests, including test results, should be kept throughout the working life of an electrical installation. This will enable deterioration to be identified, and could also be used as a management tool to ensure that maintenance checks are being carried out and to assess their effectiveness.
For non-domestic installations, Regulation 12 of the Construction (Design and Management) Regulations 2075 requires a record known as 'the health and safety file' to be prepared, reviewed, updated and revised from time to time to take account of the work and any changes that have occurred. This should contain any information relating to the project which is likely to be needed during any subsequent construction work to provide for the health and safety of persons. The CDM Regulations require that the health and safety file is passed on to the client on completion of the construction work.
The CDM Regulations also requires that once the construction work has been completed the health and safety file remains available for inspection by any person who might need it to comply with any relevant legal requirements. It also requires that the file is revised and updated as often as may be appropriate to incorporate any relevant new information.
Electrical installation certificates, minor electrical installations works certificates and electrical installation condition reports (as appropriate) would constitute relevant information in relation to this requirement.
For domestic installations the NHBC (National House-Building Council) guidance recommends that all instructions for services be passed to the building owner.
In both domestic and non-domestic cases there may also be insurance requirements that imply or specify records.
The Electromagnetic Compatibility Regulations 2076 are statutory and require that the client keep the information provided by the instal!er relating to compliance with EMC criteria for the life of the installation.
If the wording has changed in the later 2022 version The IET Shop - Guidance Note 3: Inspection & Testing, 9th Edition then please advise me.
Note that I'm referring to commercial installations here. The sentence I’ve highlighted in red font appears to suggest that electrical safety records should be viewed as part of a H&S file. However, it’s a single sentence within the supporting IET guidance note covering one chapter in the wiring regulations and I’ve never experienced anyone in the H&S field who agreed with that. Indeed, during past CDM training when I’ve asked about it I’ve been told that electrical records, whether EIC or minor works did not form part of a H&S File.
On a past web search for the contents of a CDM H&S file, the first result that came up was of a H&S training organisation ( The O&M Manual And How It's Different To The Health And Safety File - HASpod) and they document that an electrical installation report is part of an Operation and Maintenance (O&M) manual and not a H&S File. But as they also indicate on their web site ‘Unlike the O&M manual, the health and safety file just contains information specific to health and safety. What's safe, and what hazards they should be aware of’ .
In my own words, an O&M (operation and maintenance) manual which gets used by maintenance teams is largely a contractual delivery requirement, with its content largely based upon the quality of the specification written for such, along with performance of the contractor and the quality of its content verification. Almost all I’ve seen are poor at best. A H&S file on the other hand has at least some statutory clout behind delivering it.
The CDM Regulations themselves do not actively support that electrical records are part of a H&S file. Appendix 4 to the CDM Regulations themselves indicates the following, with the possible most relevant parts highlighted in red by me:
What is the health and safety file?
2 The health and safety file is defined as a file appropriate to the characteristics of the project, containing relevant health and safety information to be taken into account during any subsequent project. The file is only required for projects involving more than one contractor.
3 The file must contain information about the current project likely to be needed to ensure health and safety during any subsequent work, such as maintenance, cleaning, refurbishment or demolition. When preparing the health and safety file, information on the following should be considered for inclusion:
(a) a brief description of the work carried out;
(b) any hazards that have not been eliminated through the design and construction processes, and how they have been addressed (e.g., surveys or other information concerning asbestos or contaminated land);
(c) key structural principles (e.g., bracing, sources of substantial stored energy – including pre- or post-tensioned members) and safe working loads for floors and roofs;
(d) hazardous materials used (e.g., lead paints and special coatings);
(e) information regarding the removal or dismantling of installed plant and equipment (e.g., any special arrangements for lifting such equipment);
(f) health and safety information about equipment provided for cleaning or maintaining the structure;
(g) the nature, location and markings of significant services, including underground cables; gas supply equipment; fire-fighting services etc;
(h) information and as-built drawings of the building, its plant and equipment (e.g. the means of safe access to and from service voids and fire doors).
4 There should be enough detail to allow the likely risks to be identified and addressed by those carrying out the work. However, the level of detail should be proportionate to the risks. The file should not include things that will be of no help when planning future construction work such as pre-construction information, the construction phase plan, contractual documents, safety method statements etc. Information must be in a convenient form, clear, concise and easily understandable
Overall, the CDM Regulations don’t seem, to include much of a building services / mechanical and electrical subject that would actually go in a H&S file. If so, then what is meant by that wording in guidance note 3?
Paul