Posted on Tue 12th Sep 2017 at 12:44pm
Note, this article contains public sector information published by the Health and Safety Executive under the Open Government Licence.
Face to face engagement with your customers at a trade or consumer exhibition is one of the most powerful ways to accelerate sales and affirm your brand. As with any organisational activity aiming to attract attention, interest and drive behaviour and decision making, there’s no better alternative than interacting with another human being directly and in person. Exhibitions offer the opportunity to do just that, in a physical sales environment designed to highlight your marketing messages, make your products and services look great and facilitate a comfortable and relaxed discussion.
The end results are tried and tested – exhibitions endure despite an increasing competition for a marketeer’s budget. But the operational and logistical effort needed to deliver a successful exhibition presence can be overwhelming at first and the safety and regulatory compliance required can be a source of frustration at times.
Everyone knows of course that health and safety is important and that they have a general duty of care to themselves and to each other. And we all want to “do the right thing” and make sure nobody is injured because of any work activity we commission or are involved in. The “open period” risk assessments at exhibitions, designed to help exhibitors prove they are sufficiently managing their “temporary workplace”, are seldom met with resistance and in general the logic behind the requirement is accepted by exhibitors as is the exhibition organisers’ genuine desire to help exhibitors fulfil their legal duties and not fall foul of easily avoidable accidents and the potential legal ramifications of those.
But in 2015 another layer of complexity was added to an exhibitor’s health and safety responsibilities in relation to exhibiting.
The Construction Design and Management Regulations 2015 simplified existing UK legislation that interpreted the European Directive concerning the management of construction sites. Intended as a pro-business move by regulators, to reduce regulatory burden on conventional construction companies, the revision led to a change in HSE enforcement policy. To-date the Executive had determined not to enforce “CDM” on temporary construction such as exhibition stands, theatre and film sets and outdoor temporary structures because it had been too complex – but the simplification of the legislation removed that barrier and the law was subsequently enforced across all of these following the publication of sector specific guidance in early 2016.
CDM now[7] applies to all construction projects, including all those undertaken across the entertainment industry. A “project” includes all the planning, design and management tasks associated with the construction work including the building, fitting out and taking down of the structure.
CDM essentially makes the general health and safety duties as documented in the Health and Safety at Work etc Act 1974 much more specific in relation to construction, complementing the general Management of Health and Safety at Work Regulations 1999 and applying its principles directly to the management of construction projects.
The HSE’s aim has been for conventional construction health and safety practices to become a normal part of an exhibition stand’s design, development and construction, not as it describes an “afterthought” or “bolt-on extra”. [8]
The overall objective of CDM is to reduce the risk of harm to those who build, fit out, use, maintain and take down structures. The key principles involve:
- Appointing the right people and organisations at the right time;
- Making sure everyone has the information, instruction, training and supervision they need to carry out their jobs safely and without damaging health;
- Eliminating or controlling risks so far as reasonably practicable;
- Ensuring work is effectively planned;
- Having systems in place to help parties cooperate and communicate with each other and coordinate their work; and
- Consulting with workers with a view to securing effective health, safety and welfare measures.
(It’s often useful to point out that “Reasonably Practicable” means balancing the level of risk against the measures needed to control the real risk in terms of money, time or trouble. You do not need to take action if it would be grossly disproportionate to the level of risk).
CDM refers to two main phases of an exhibition construction project. These are:
- The ‘pre-construction phase’, which is the period of time during which design or preparatory tasks for construction work is carried out. This may continue into the next (construction) phase.
- The ‘construction phase’, which is the period of time beginning when construction work starts e.g. the build phase of a structure/show and finishing when construction work is completed e.g. the breakdown of structures at the end of a show.
As an exhibitor, commissioning a custom build or modular exhibition stand in a “space only” allocation, you will automatically assume the statutory role of “Client” under CDM. And since custom built stands always require third party “official contractor” involvement with respect to electrics and other services (and so will always involve more than one contractor) you should generally, as the CDM client, appoint in writing an organisation to plan, manage, monitor and coordinate each of these two phases of the work. These roles are called the CDM principal designer (PD) and principal contractor (PC) and are often the same contractor. Where a CDM Client does not appoint anyone, they will by default assume the duties of these roles themselves. Showlite is a well-respected contractor within the exhibition sector with over 25 years’ experience and has worked hard to equip itself with the knowledge required to provide both PD and PC functions to its exhibitor clients.
The HSE describes in some detail the way it would expect to see an exhibitor CDM Client fulfil its responsibilities and engage with its chosen contractor on an exhibition stand construction project.
In the first instance it recognises that, typically, an exhibition Organiser will have let a number of ‘space only’ plots out to exhibitors. Under CDM, each of these plots would be seen as a separate construction projects within the main site – or “mini-CDM sites”.
The exhibitor would be seen as the CDM Client for their own plot as they decide what to build and who will undertake the work. They will appoint a Stand Build Contractor, such as Showlite, on a design and build basis. The Stand Build Contractor will plan, manage, monitor and co-ordinate all the construction activity on the plot and so function as the CDM Principal Designer/Principal Contractor for the project.
The exhibitor will need to obtain “pre-construction information” from the exhibition Organiser including a build-up and breakdown timetable, plus an overall floor plan for the site. Arrangements for making the first point of electrical contact for the stand will also be obtained from the Mains Electricity Contractor and the exhibitor will pass this information onto the Stand Build Contractor, who in turn will share it with their subcontractors.
Examples of the type of information required will include floor loadings, a maximum permissible stand height, loading arrangements and other information normally found in the Exhibitor manual. Showlite can assist an exhibitor in the collation of this information if they are at all unclear of the requirements.
The Stand Build Contractor’s in-house design team will then take the exhibitor’s brief and design the stand, which the exhibitor will then approve. Following approval the Stand Builder will undertake the final detailed design work and make the wooden parts of the stand in their workshop and, perhaps, source metal and other components from preferred suppliers. The Stand Builder’s electrical subcontractor will undertake the electrical design work and install the wiring in the prefabricated components. The components will then be shipped to site for the first day of the build.
The Stand Build Contractor (and their sub-contractors) will agree safe access to the plot and ensure their health and safety arrangements for the plot are in line with the general site rules determined by the Organiser.
Once the Stand Build Contractor has planned the work, including devising a safe system of work to erect the stand within the perimeter of the plot, the Project Manager will draw up a construction phase plan, which will detail the arrangements for managing construction work on the plot.
The Site Foreman is the main supervisor on the plot and will make sure workers are briefed and the build is carried out according to the agreed design and safe work methods. The Foreman will coordinate the work of the Mains Electrical Contractor and onsite AV or any other suppliers (appointed by the organiser), to supply power and other services for the site.
The site Foreman and onsite Rigger will coordinate to ensure suitable work at height arrangements are in place during installation of any banners or other overhead features above the stand.
The Stand Builder will also liaise with contractors on adjacent sites (facilitated by the Organiser) to ensure work can be carried out safely.
The same team will later de-rig the stand at a pre-arranged date, following a safe system of work and agreed cooperation and coordination arrangements with others onsite.
Importantly, CDM requires that all designers and contractors (including individuals and sole traders) must be able to demonstrate to an exhibitor CDM Client that they have the health and safety skills, knowledge and experience to carry out the work for which they are seeking appointment.
The HSE’s official guidance on CDM explains that this competency can be assessed by the CDM Client alone or with consideration to a contractor’s achievement of an SSIP scheme accreditation such as Safe Contractor or CHAS – The Contractors Health and Safety Assessment Scheme.
Showlite is one of a select few exhibition contractors to have successfully achieved CHAS having taken significant steps to professionalise its on-site workforce and subcontractor network since the enforcement of CDM.
If you have any questions about CDM or health and safety in general please don’t hesitate to contact your Showlite representative and we’ll be very happy to help.