1.2 Risk Assessment, Hierarchy of Controls & CDM 2015 Regulations
Key Takeaways
The Management of Health and Safety at Work Regulations 1999 (MHSWR) mandate proactive risk management through the 5 Steps to Risk Assessment, requiring written records where 5 or more persons are employed.
A hazard is anything with potential to cause harm, whereas risk is the combination of the likelihood that harm will occur and the severity of the consequence.
Risk control follows the General Principles of Prevention in MHSWR Schedule 1: eliminate first, then substitute, engineer, organise and train, with PPE as the last resort.
Construction (Design and Management) Regulations 2015 (CDM 2015) apply to all construction and electrotechnical installation projects, defining distinct legal duties for Commercial Clients, Principal Designers, Principal Contractors, Contractors, and Workers.
Key CDM project documentation includes Pre-construction Information (PCI), the Construction Phase Plan (CPP) required before site work begins, and the post-completion Health and Safety File.
1.2 Risk Assessment, Hierarchy of Controls & CDM 2015 Regulations
The Management of Health and Safety at Work Regulations 1999 (MHSWR) translate HASAWA principles into an explicit duty of proactive risk management. Under Regulation 3 of MHSWR, every employer and self-employed person must carry out a suitable and sufficient assessment of risks to employees and others affected by their operations.
The Five Steps to Risk Assessment
The Health and Safety Executive (HSE) establishes a structured five-step framework for carrying out risk assessments:
- Identify Hazards: Inspect work areas, review manufacturer guides, study incident records, and consult operatives to identify sources of harm.
- Decide Who Might Be Harmed & How: Identify exposed groups, including electricians, apprentices, lone workers, other trades, and visitors.
- Evaluate Risks & Decide Precautions: Assess likelihood and severity, check existing controls, and apply the hierarchy of controls SFARP.
- Record Significant Findings: Employers with 5 or more employees must record findings in writing (hazards, controls, and vulnerable groups).
- Review and Update: Re-evaluate periodically, and immediately after accidents, near-misses, or process changes.
Hazard vs. Risk
Understanding the distinction between hazard and risk is central to electrotechnical safety:
- Hazard: Anything with intrinsic potential to cause harm (e.g., exposed 400V busbars, work at height, silica dust, or trailing leads).
- Risk: The combination of the likelihood of harm occurring and the severity of the consequences:
Sites use risk scoring matrices (e.g., 3×3 or 5×5) to categorize residual risk as Low, Medium, or High, ensuring adequate precautions are implemented before work begins.
The Hierarchy of Controls
Schedule 1 of MHSWR sets out the General Principles of Prevention: avoid risks, evaluate the risks that cannot be avoided, combat risks at source, adapt work to the individual, adapt to technical progress, replace the dangerous by the non-dangerous or less dangerous, develop a coherent overall prevention policy, give collective protective measures priority over individual ones, and give appropriate instructions to employees. In practice these are taught as a hierarchy, with elimination first and PPE last. Site trainers often use the memory aid ERIC PD (Eliminate, Reduce, Isolate, Control, PPE, Discipline); HSE describes the same order as follows:
- Elimination: Remove the hazard completely (most effective). Examples: Prefabricate containment off-site at ground level; isolate supplies upstream to eliminate live work.
- Substitution: Replace the hazard with a safer alternative. Examples: Use 110V RLV tools instead of 230V mains; use water-based adhesives instead of solvent cleaners.
- Engineering Controls: Isolate workers with physical barriers. Examples: IP2X terminal shrouds, lock-off devices on switchgear, LEV on wall chasers, and 30mA RCDs.
- Administrative Controls: Adjust procedures, scheduling, and training. Examples: Permit to Work (PTW) systems for high-voltage testing, site inductions, toolbox talks, and warning signs.
- Personal Protective Equipment (PPE): Protect individual workers (helmets, eye protection, dielectric gloves). PPE is the absolute last resort: it protects only the wearer, relies on compliance, and leaves the hazard present.
Safe Systems of Work (SSoW), RAMS & Dynamic Risk Assessment
SSoW and RAMS
A Safe System of Work (SSoW) is a formal, documented procedure detailing how a hazardous task must be conducted safely. On commercial sites, this is documented in RAMS (Risk Assessment Method Statements):
- Risk Assessment: Identifies hazards, exposed persons, initial risk scores, hierarchy controls, and residual risk ratings.
- Method Statement: A step-by-step narrative detailing execution sequence, tool specifications, access gear, PPE ratings, worker competencies, and rescue plans.
Dynamic Risk Assessment
A Dynamic Risk Assessment is the continuous mental evaluation of hazards carried out by operatives in real time. If unforeseen conditions arise—such as uncovered live services, water leaks near distribution boards, or overhead crane lifts—operatives must stop work immediately, make the area safe, and notify supervision to update the RAMS.
Construction (Design and Management) Regulations 2015 (CDM 2015)
CDM 2015 applies to all construction work in Great Britain, including commercial, industrial, domestic, and electrical installation, alteration, repair, and commissioning.
Five Key Duty-Holders Under CDM 2015
- Commercial Client: Commissions project. Allocates resources, ensures welfare, appoints PD and PC in writing (multi-contractor sites), and issues Pre-construction Information (PCI).
- Principal Designer (PD): Coordinates health and safety during pre-construction. Eliminates design risks, assists with PCI, and compiles the Health and Safety File.
- Principal Contractor (PC): Coordinates health and safety during construction. Prepares and manages the Construction Phase Plan (CPP) before site work begins, delivers inductions, and coordinates trades.
- Contractors: Manage their own work, comply with the CPP, verify worker competence (SKTE), and provide site-specific RAMS.
- Workers / Operatives: Take care of self and others, report hazards, and comply with site rules, inductions, and RAMS.
Core CDM Documentation, Inductions & Consultation
- Pre-construction Information (PCI): Assembled by the Client/PD before tendering (surveys, asbestos records, utility drawings).
- Construction Phase Plan (CPP): Produced by the Principal Contractor before site work begins; sets safety rules and controls for high-risk hazards.
- Health and Safety File: Compiled by the Principal Designer and given to the Client upon completion for safe future maintenance.
- Inductions & Toolbox Talks: Mandatory site inductions cover rules, evacuation, and welfare. Regular toolbox talks reinforce task-specific safety.
- Operative Consultation: Employers must consult the workforce on safety arrangements under the 1996 Consultation Regulations.
Summary Comparison Tables
Hierarchy of Controls Applied to Electrotechnical Hazards
| Tier | Control Method | Practical Electrotechnical Site Application |
|---|---|---|
| 1. Elimination | Remove hazard completely | Prefabricate containment off-site at ground level; fully isolate upstream supply |
| 2. Substitution | Replace with safer alternative | Use 110V RLV tools instead of 230V mains; use water-based solvent cleaners |
| 3. Engineering | Physical isolation/containment | Install IP2X terminal shrouds; fit lock-off hasps; use LEV on wall chasers |
| 4. Administrative | Procedures, training, signs | Implement Permit to Work (PTW); deliver site inductions and daily toolbox talks |
| 5. PPE | Individual worn equipment | Provide Class 0 insulating gloves, arc-flash face shields, and BS EN 397 helmets |
CDM 2015 Duty-Holder Responsibilities
| Duty-Holder | Phase of Control | Primary Statutory Responsibilities |
|---|---|---|
| Commercial Client | Entire Project Lifecycle | Appoints PD and PC in writing; allocates time/resources; ensures welfare; issues PCI |
| Principal Designer | Pre-construction / Design | Coordinates safety in design; eliminates foreseeable risks; compiles Health & Safety File |
| Principal Contractor | Construction Phase | Authors Construction Phase Plan before work starts; manages site safety; coordinates trades |
| Contractors | Construction Phase | Plans and manages own work; complies with CPP; verifies worker competence; provides RAMS |
| Workers / Operatives | Construction Phase | Takes care of self and others; reports hazards; adheres to site rules, inductions, and RAMS |
ECS Exam Focus: Risk Assessment Facts
- Risk assessment must always be done: there is a legal requirement for all work to be suitably risk assessed, and an assessment of risk must be made before any work begins.
- It must be carried out by a competent person, not a visiting HSE inspector or the designer.
- A risk assessment is a means of analysing what might go wrong and deciding the practical measures that prevent harm; it is not just a piece of paper.
- A hazard is something with the potential to cause harm, such as a drum of acid, blocks on an elevated plank or a cable across a floor. Risk is the likelihood that harm from a hazard will occur.
- Your supervisor asks you to read the method statement and risk assessment because they explain how to carry out the job safely; supervisors must keep workers informed of significant risks and the control measures.
- CDM stands for the Construction (Design and Management) Regulations, which cover managing construction projects, physical safeguards and welfare facilities.
When writing a method statement for work near a switchboard, which control measure is an engineering control rather than elimination, an administrative control or PPE?
Fitting temporary insulating barriers and shrouds over the exposed busbars
Isolating and locking off the supply so that no live working is needed at all
Issuing a permit to work and holding a toolbox talk before energisation
Requiring Class 0 insulating gloves and an arc-rated face shield for testing
Under the Construction (Design and Management) Regulations 2015 (CDM 2015), which duty-holder is legally responsible for preparing and updating the Construction Phase Plan (CPP) prior to the commencement of any site work?
The principal designer
The principal contractor
The local authority building control officer
The client
An approved electrician arrives on a commercial refurbishment site to install containment above a false ceiling. While reviewing the generic RAMS, the electrician discovers that recent demolition work by another contractor has left uninsulated live sub-main cables sagging near the proposed metal conduit route. Which immediate action represents a correct dynamic risk assessment response?
Stop work, keep clear of the cables and report the new hazard so the RAMS can be reviewed
Re-route the conduit around the cables yourself and record the change after the shift
Carry on with the generic RAMS because hi-vis vests and safety boots are being worn
Finish the conduit run quickly before the other contractor's shift ends to limit exposure
Sections you finish are checked off in the contents.