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The Standards a CMP Is Checked Against

Swept path analysis for UK planning applications, answered in plain English.

Which HSE guidance applies to construction vehicles on site?#

HSG144, "The safe use of vehicles on construction sites". It is described as a guide for clients, designers, contractors, managers and workers involved with construction transport, and gives practical guidance on preventing on-site vehicle accidents, covering planning and management of vehicle operations and the selection, maintenance and safe driving of vehicles. Real submitted plans cite it.

Is HSG144 still current?#

It was published in 2009 and the HSE notes it is currently under review and contains some out of date references, while much of the content remains useful and practical advice not available elsewhere. So it is worth citing and worth reading, but check any specific cross-reference in it rather than relying on it blind.

What is HSG151?#

HSE guidance titled "Protecting the public: your next move". It deals with protecting people who are not working on the site from construction risks, which is precisely the interface a CMP or CTMP manages. Real submitted plans cite it alongside HSG144.

Does a CMP need to reference HSE guidance at all?#

It is not mandatory and a small scheme plan may not. But citing HSG144 and HSG151 signals that the vehicle and public-protection measures in the plan come from somewhere, and larger submitted plans do it as a matter of course. An officer reading a cited standard treats the commitment differently from an uncited assertion.

What is Chapter 8 and why do plans keep citing it?#

Chapter 8 of the Traffic Signs Regulations and General Directions covers temporary traffic management signing and layouts for works on the highway. It is cited because any signing a construction site puts on the public highway has to conform to it. The RBKC pro-forma requires blockage warning signage and footway closure signage to conform to Chapter 8, and real submitted plans reference it directly.

What is NRSWA and how does it relate to a CMP?#

The New Roads and Street Works Act 1991, which governs works in the street and the qualifications and standards applying to them. Real plans cite it alongside Chapter 8, and the RBKC pro-forma requires footway closure signage to be Chapter 8 conforming and NRSWA compliant. If your works touch the highway, both apply.

Where does the Highways Act 1980 come in?#

It is the primary legislation governing the management and operation of the road network in England and Wales. The TfL and CLOCS guidance describes it as the Act which most of the activities pertaining to construction logistics plans utilise, and real submitted plans cite it. Hoarding licences, skip licences, crossover licences and parking suspensions all ultimately derive their authority from highways legislation rather than from planning.

Does the Traffic Management Act 2004 affect my CMP?#

Indirectly but importantly. Part 2 places a duty on local authorities to manage the traffic network in their area, including making efficient use of it and taking measures to avoid contributing to congestion. That duty is why the highway authority has a view on how your site is served, and why a plan that ignores congestion is arguing against a statutory duty.

Is a CMP the same as a construction phase plan under CDM 2015?#

No, and this is the most consequential confusion in this area. A construction phase plan is required by regulation 12(1) of the CDM Regulations 2015 and must be drawn up by the principal contractor during the pre-construction phase and before setting up a construction site. It sets out health and safety arrangements and site rules. A CMP is a planning document required by condition. Different author, different trigger, different content, no overlap in who approves it.

Can my construction phase plan double as my CMP?#

Not safely. They answer to different bodies. The construction phase plan discharges a duty under regulation 12 and nobody approves it. The CMP discharges a planning condition and the local planning authority must formally approve it. Submitting a health and safety document against a highways condition is a common reason for a request for further information.

Who signs off a CMP?#

The local planning authority, by formally discharging the condition. That is a different act from the authority merely receiving the document. Until the condition is discharged, a pre-commencement requirement is not satisfied, and some authorities warn explicitly that starting work before discharge can lead to enforcement action.

What is a traffic management risk assessment?#

A risk assessment specific to vehicle movements and the traffic interface, as distinct from general site risk assessments. The ISG plan includes one as a numbered item in its framework and attaches it to the document. It is where the routing, segregation and marshalling decisions in the plan get justified against the hazards they address.

How do I assess the safety of a construction route?#

Real plans use published accident data. The ISG plan addresses last mile accident statistics by reference to CrashMap, a public source of recorded road collision data, as part of its vehicle routing and holding section. Using recorded collision data rather than a judgement about which road looks busier is both more defensible and more persuasive.

What are proximity hazards in a construction traffic plan?#

Hazards near the vehicle route and working area that vehicles or plant could strike or disturb. The ISG framework asks specifically about overhead electric power lines and underground services, and where underground services are present requires effective demarcation or controls to prevent accidental contact, committing that areas of excavation will be scanned under a safe system of work.

What counts as segregation on a construction site?#

Physically separating vehicles from people. In the ISG academy plan the measures are named: solid hoarding separating academy staff and students from site traffic and delivery vehicles, segregation barriers with dedicated access gates, a separate contractor pedestrian entrance, and the site vehicle entrance sited a minimum of five metres from the academy access points. Segregation by distance and barrier, not by instruction.

What is a traffic marshal and is it different from a banksman?#

The terms overlap in practice. The ISG plan commits to a qualified traffic marshal controlling traffic movements on site and a qualified gateman. The RBKC pro-forma requires trained banksmen whenever vehicles are manoeuvring into or out of the site, with a Site Access Traffic Marshal qualification as the minimum. The common thread is a trained person controlling the movement, named in the plan.

Does a CMP have to address school arrival and departure times?#

Where a school is nearby or on the route, yes, and real plans do it with specific times. The ISG academy plan applies restrictions from 07:00 to 09:00 and 14:30 to 16:30 during peak student drop off and pick up, and commits that vehicles must wait at hold points until delivery restrictions are lifted. The RBKC pro-forma separately restricts deliveries to 9.30am to 3pm where there is a school on the route during term time.

What is a hold point?#

A location away from the site where a vehicle waits until the site can receive it. The ISG plan identifies hold points and states that vehicles must wait at them until delivery restrictions are lifted. The TfL and CLOCS guidance treats holding and call off areas as a planned measure, and notes they can only be used if approved by the relevant authority, and that inclusion in an approved plan does not remove the highway authority's right to suspend their use.

What security arrangements belong in a CMP?#

Enough to show the site is controlled. The ISG plan names secured hoarding and gates, a biometric security entrance cabin controlling site operatives, a gateman controlling vehicle security during working hours, and 24 hour CCTV with night lighting. On a school site that level of control is proportionate; on a rural single dwelling it would not be.

How are vehicle types classified in a CMP?#

Real plans band them by weight. The ISG plan uses 3.5 tonnes and under, 3.5 to 7.5 tonnes, and 7.5 tonnes and over, and shows the number of each band at the peak of each phase. The RBKC pro-forma instead asks for capacities and maximum dimensions per type, both with and without wing mirrors, plus maximum dwell time. Both approaches answer the same underlying question: what is actually turning up, and how big is it.

Does a CMP need to say who is responsible for implementing it?#

Yes, and by name or role rather than by company. The RBKC pro-forma asks you to identify who is responsible for the day to day implementation of the plan and to provide their details. The TfL and CLOCS guidance includes implementing, monitoring and updating as one of its seven required sections. A plan with no named owner cannot be enforced and officers know it.

Does a CMP need monitoring and controls?#

Larger plans include them as a distinct section. The ISG framework has monitoring and controls as a numbered item. The RBKC pro-forma asks you to confirm that if directed by the council you will monitor site accesses or loading areas. Monitoring is what converts a commitment into something checkable, which is the difference between a plan and a statement of intent.

Do I have to coordinate with other nearby construction sites?#

Where an authority asks, yes. The RBKC pro-forma requires you to make all reasonable efforts, and always when specifically directed by the council, to coordinate the scheduling of construction traffic with other nearby developments and those on the specified routes, and to identify the relevant sites. It notes that where more than one development occurs on a narrow street or constrained cul-de-sac, deliveries must be coordinated to maintain access at all times. The TfL and CLOCS guidance also lists collaboration as a planned measure.

What happens if my CMP is approved but I cannot comply with it?#

Submit a revision rather than depart from it. Real plans are dated and given revision numbers precisely because they change, and the RBKC pro-forma asks for both. Operating to an unapproved arrangement while an approved plan says something else is a breach of the condition the plan discharged.

What is the single best thing I can do to get a CMP approved first time?#

Answer the condition, clause by clause, in the order it is written, and say who is responsible for each commitment. Every approved plan read for this section does that, whether it runs to two pages or twenty-three. The plans that get returned are the ones that describe a construction site in general terms without ever addressing the specific words the council used.

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