Al Dennis is a Principal Engineer at Empire Engineering. Here, Al shares his insight on The Construction (Design and Management) Regulations 2015 and their implications in offshore wind.
The Construction (Design and Management) Regulations 2015 (better known as CDM) should shape every aspect of offshore wind development, by ensuring that all designs are as safe as possible to produce.
The CDM regulations apply to our projects just as much as they do to building a primary school. I recommend this guide from Cairn Risk Consulting as a useful description of how CDM applies to the offshore wind industry.
Although CDM is a UK-only legal requirement, its main aim of promoting the production of the safest possible design could be applied to any project around the world.
G+ reports two offshore wind fatalities in the last five years, but they acknowledge that there have been more in fabrication facilities that are currently not part of their reporting, and they are working on how to share these fabrication incidents with us all. We would all like G+ to report zero fatalities for the next five years (including fabrication), so where do I see areas for potential improvement for the industry in producing safer structures through design?
I think our industry can learn and improve from safety cultures in other safety-critical industries. I have some ideas where we could improve performance. Maybe you are already doing what I suggest, or have other ideas to improve our design safety approach: if so, get in touch and let me know.
Every project stakeholder can be a ‘Designer’: so can a project have one Design Risk Register?
Proposal 1: A project should have a single risk register editable by all stakeholders, managed by the Principal Designer.
The benefits are:
- Increased cooperation and visibility of project risks.
- A single ‘source of truth’ for the project with, if carefully managed, no repetitions
- A streamlined process that would decrease management effort for both the developer and all their contractors.
Everyone in an offshore wind project is likely to make design decisions. Developer teams have experienced and technically excellent professionals who will often be an integral part of design decision making, so anyone on a project could become a ‘Designer’ under CDM.
A company will make design decisions from the start to the end of their involvement in the project. It is very unlikely that anyone can host a single Hazid, write that up and state that they have produced the safest-possible design. Our projects are full of surprises and changes at all stages, and designers have to continually react and manage these changes in terms of impacts on health and safety.
A company’s design risk management process is a continual and ongoing process until they complete their work, and they will likely use a design risk register to communicate residual risks to other companies.
A project’s culture of Health and Safety management and the contracts forming the project, should encourage openness and a spirit of cooperation to produce the safest possible design.
Supplying a mass-produced product? You will still be a ‘Designer’ under CDM.
Proposal 2: All suppliers need to be CDM literate and actively contribute to the project’s risk management process.
A product with a non-project specific design will typically have a generic risk register. For the majority of the product’s characteristics that could be sufficient, but what about at its interfaces where every project is different?
Using the wind turbine generator and tower as an example, the supplier of these elements will influence the layout of the supporting structure and the high-voltage cables within it. Especially if the switchgear is not in the tower.
The supplier needs to comply with the CDM regulations and engage with the Project’s safe-by-design processes.
Assume that fabrication yard workers will only read your drawings, not the risk register
Proposal 3: Every drawing with residual risks should have warning symbols and a SHE box.
Drawings and the BIM model are a designer’s primary method of communication to the people who are producing their design. This should be where residual risks are stated so the right people have the right information at the right time. Every drawing should have a ‘SHE’ (Safety, Health, Environment) box. This box should not repeat all the details on the risk register but should signpost to the reader the risks that are associated with the items on the drawing. Best practice would be to include a warning sign on the drawing in the area where the risk occurs. Network Rail specifies that the symbol for a hazard on all their project drawings is this:
For an example SHE box refer to this learning point from the London 2012 construction works (this is not a new idea)
And for projects working with BIM models, they include a H&S attribute in the model to link elements in the model with the risk register.
With these practical and easily applicable suggestions, we can foster a more collaborative and transparent approach to safety across the entire offshore wind supply chain. By breaking down silos between stakeholders, ensuring that safety information reaches the people who need it most, and learning from the proven practices of other safety-critical industries, we move closer to the shared goal of zero fatalities.
Reach out to Al on LinkedIn or read more about Empire Engineering’s offshore wind expertise.