Estates & Development Directorate

Title

PROCEDURAL ARRANGEMENTS FOR COMPLIANCE WITH THE CONSTRUCTION (DESIGN & MANAGEMENT) REGULATIONS 2015

Policy Number – Estates Operational Policy Authors /Reviewers–Issue date: TBA

To be reviewed:

CONTENTS

1. Scope of Policy Page 1

2. Policy Statement Page 3

3. Legislation and Guidance Page 3

4. Rationale for Policy Page 4

5. Management Page 4

Appendix 1 Procedure Summary

Appendix 2 Summary of changes from previous legislation

Appendix 3 Summary of roles & duties

Appendix 4 Non-notifiable Projects – Clients Checklist

Appendix 5 Keele University - CDM 15 Flowchart

Appendix 6 Aide memoire - (Procedure checklist)

Appendix 7 Aide memoire - (Pre-construction information)

1. Scope of Policy

1.1 The University has a policy which sets out it how will comply with the general requirements of the Health and Safety at Work etc. Act 1974 and the more specific requirements of the Construction, Design & Management regulations 2015 (CDM 2015).

The CDM Regulations 2015 came into effect on the 6th of April 2015.

These are an update from both the original regulations, which were introduced in 1994, and the subsequent update in 2007. The main change is to simplify the roles of those involved.

The Regulations apply to ALL construction and maintenance works, including domestic properties, and NOT just those which need to be notified to the HSE. However the extent of preparation and paperwork is related to the size of the “project” and the assessed risk.

The duties established within the regulations apply to all staff involved in construction work, including those who request or instigate that works are carried out on their behalf. Anyone who does instigate work, whether it be an individual or team representing a school or department, will be classed as the CLIENT and will be required to appoint people to specified roles. Where the necessary knowledge to carry out the role of CLIENT and skills are not available to the instigators, they should either seek specialist advice or request that the Estates & Development Directorate (E & D) take over the organisation of the project.

Failure of the instigator of a project, OF WHATEVER SIZE, to arrange the appointment of the specified roles, will result in them being LEGALLY RESPONSIBLE for ALL the duties.

It should be noted that temporary structures, such as marquees, are classed as structures and therefore subject to these regulations.

1.2 The university carries out works which fall within the scope of CDM 2015. In order that employees, students and other people who may be affected by construction works, both in the present day and the future, are protected, everyone will comply with the general requirements of CDM 2015. For the purposes of this procedure:

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1.3 Definitions:

The regulations provide definitions of both what is construction work and what constitutes a structure, in order that it may be assessed whether the regulations apply to an individual job. These are below:

1.3.1 Construction

“the carrying out of any building, civil engineering or engineering construction work and includes—(a) the construction, alteration, conversion, fitting out, commissioning, renovation, repair, upkeep, redecoration or other maintenance (including cleaning which involves the use of water or an abrasive at high pressure or the use of corrosive or toxic substances), de-commissioning, demolition or dismantling of a structure;(b) the preparation for an intended structure, including site clearance, exploration, investigation (but not site survey) and excavation, and the clearance or preparation of the site or structure for use or occupation at its conclusion;(c) the assembly on site of prefabricated elements to form a structure or the disassembly on site of prefabricated elements which, immediately before such disassembly, formed a structure;(d) the removal of a structure or of any product or waste resulting from demolition or dismantling of a structure or from disassembly of prefabricated elements which immediately before such disassembly formed such a structure; and(e) the installation, commissioning, maintenance, repair or removal of mechanical, electrical, gas, compressed air, hydraulic, telecommunications, computer or similar services which are normally fixed within or to a structure, but does not include the exploration for or extraction of mineral resources or activities preparatory thereto carried out at a place where such exploration or extraction is carried out;

1.3.2 A structure

(a) any building, timber, masonry, metal or reinforced concrete structure, railway line orsiding, tramway line, dock, harbour, inland navigation, tunnel, shaft, bridge, viaduct,waterworks, reservoir, pipe or pipeline, cable, aqueduct, sewer, sewage works, gasholder,road, airfield, sea defence works, river works, drainage works, earthworks, lagoon, dam,wall, caisson, mast, tower, pylon, underground tank, earth retaining structure or structuredesigned to preserve or alter any natural feature and fixed plant;

(b) any structure similar to anything specified in paragraph (a);

(Please note, that this will include temporary structures, such as marquees.)

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2. Policy Statement

2.1 Keele University recognises and accepts its responsibility as an employer for providing, as far as reasonably practicable, a safe and healthy working environment for its employees. In addition, it will ensure, so far as is reasonably practicable, that persons other than employees, including students, visitors and contractors, are not exposed to risks to their health and safety.

The University also requires its staff to take reasonable care of their own health and safety, and that of other persons who may be affected by their acts or omissions at work. Employees are also required to co-operate with the University and any other person, to enable them to meet their own statutory obligations.

3. Legislation and Guidance

3.1 Statutory and Dedicated Legislation Applying to the Construction (Design & Management ) Regulations 2015

a. Health and Safety at Work etc. Act 1974

This Act is the “umbrella” legislation, under which all health & safety regulations operate. In effect the Act places an absolute duty on those affected by the legislation, and guidance documents specific to individual industries and risks, explains in detail how compliance with the Act is best achieved. Construction Industry Training Board ( CiTB ) guidance is in place to control the risk from construction work in circumstances where the CDM regulations apply. The management have a duty to ensure that the systems of work and control measures in place are at least as good as those in the CiTB guidance, in order to conform with this Act.

b. Management of Health and Safety at Work Regulations 1999

These Regulations provide a broad framework for controlling health and safety at work. To comply with them, the management must make a suitable and sufficient assessment of risks to health and safety for its employees and others arising from work activities.

c. Construction (Design and Management) Regulations 2015

The Regulations provide a framework of actions designed to control the risks from a range of construction projects, from very minor repairs to major building projects.The HSE has not produced an Approved Code of Practice (ACoP) for these regulations but The Construction Industry Training Board (CITB) has produced a number of guides which may be seen as best practice for compliance, although they do not hold full legal status.

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d. Other legislation relating to construction work (This is not an exhaustive list and all legislation relevant to the specific project must be followed.)

The Work at Height Regulations 2005 (as amended) Control of Asbestos Regulations 2012 Electricity at Work Regulations 1989 Provision and Use of Work Equipment Regulations 1998 Manual Handling Operations Regulations 1992 Workplace (Health, Safety and Welfare) Regulations 1992 Personal Protective Equipment at Work Regulations 1992 Chemicals (Hazard Information and Packaging for Supply) Regulations 2002 (CHIP)

(gives effect to EU Directive 67/548/EEC)[12] Control of Substances Hazardous to Health Regulations 2002 Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013 Lifting Operations and Lifting Equipment Regulations 1998 The Control of Noise at Work regulations 2005 Dangerous Substances and Explosive Atmospheres Regulations 2002 The Confined Spaces Regulations 1997

4. Rationale for the Policy

The University, particularly The Estates & Development Directorate (E & D), carries out a significant amount of construction work within the campus, as defined under these regulations, much of which may involve external contractors. This policy identifies our requirements under law, particularly with reference to the definition and duties of specific roles and the use of best practice. It aims to provide all those involved, whether Keele Staff or Contractors, with guidance as to how best to comply with the legislation.

5. Management

Roles within CDM 15

One of the main changes from the previous CDM legislation is the definition of roles and specific duties within those roles, to ensure the safe management of construction projects from the original consultation phase, through the construction phase, and subsequently the ongoing maintenance of the structure (where applicable), up to the final demolition (or removal for a temporary structure).

Appendix 5 provides a flowchart to offer guidance on who should carry out each role.

Appendix 1 gives a step-by-step summary of how to carry out each role. Appendix 6 is an aid memoire for those involved in the CDM process.

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5.1 Role

Each role has carried specific duties and it is the responsibility of all those involved to establish at an early stage which role or roles they hold. Once this has been agreed those involved should carry out the duties identified below:

5.1.1 The Client

There is no longer a CDM Co-ordinator ( CDMC ), as in the old Regulations but ALL projects and even minor works have a CLIENT, who will assume some of their duties.

CITB Guidance (see 3.1 c ) states:

CDM 2015 defines a client as anyone for whom a construction project is carried out. The regulations apply to both domestic and commercial clients. This guidance is aimed at commercial clients. A commercial client is an organisation or individual for whom a construction project is carried out in connection with a business, whether the business operates for profit or not. Examples of commercial clients are schools, retailers and landlords.

The client ensures that the construction project is set up so that it is carried out from start to finish in a way that adequately controls the risks to the health and safety of those who may be affected.

Within Keele, the Client may be a Head of Department, Dean, Director, Faculty Business Manager or more likely someone from within the Estates Directorate, who is the instigator of the work. CDM therefore does not just apply to the Estates Directorate and the “Authorisation-to-Proceed” form has been amended accordingly.

Every “Client” will therefore need to understand their roles & responsibilities.

Where a Head of Department, or similar, does not believe they have the necessary competence to carry out the duties of The Client, they must arrange for appropriate assistance from a competent third party ( E & D may be asked to advise on this ). Similarly, if E & D have been requested to carry out the works, the Estates Project Manager may be asked to fulfil the role of Client, on behalf of the Head of Department.

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One of the Client’s first duties is to appoint a DESIGNER, or PRINCIPAL DESIGNER for larger projects, involving more than one CONTRACTOR. (See 5.2.1 for other duties)

A checklist for non-notifiable jobs is available in appendix 4, to assist those acting as Client. For larger, notifiable jobs, the allocation of the Contractor/Principal Contractor should be arranged at the end of the tendering process.

5.1.2 The Principal Designer/Designer

The term “Designer” is a little confusing in some situations, particularly for very small works and often simply applies to the person who decides how the work proceeds.

An individual or group may hold the position of Client and Designer, simultaneously, for smaller jobs and it should be noted that this happens automatically when a Client does not formally appoint a Designer or Principal Designer, in writing, even for large projects.

5.1.2 (a) Principal Designers are designers appointed by the client in projects involving more than one contractor. They can be an organisation or an individual with sufficient knowledge, experience and ability to carry out the role.

5.1.2 (b) Designers are those who, as part of a business, prepare or modify designs for a building or product, or prepare or modify designs to systems relating to construction work. If there is only a single designer involved on a project then they may have additional responsibilities and should refer to the Industry guidance for Principal Designers.

5.1.3 The Principal Contractor/Contractor

The role of the Principle Contractor and Contractor have largely remained the same.

In essence they are still responsible for liaising with the Client and (Principal) Contractor, in order to manage the construction phase of the process. Part of this will involve the preparation of a CONSTRUCTION PHASE HEALTH & SAFETY PLAN.

Where more than one contractor is involved, the Client must appoint one of them as the Principal Contractor and they must accept their role and the associated responsibilities, in writing. They will then be responsible for ensuring that all other contractors operate in a safe manner.

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5.2 Duties and Responsibilities of the primary roles:

The roles identified above carry with them a number of specific roles and responsibilities. These are listed below and apply whether an individual is holds one or more roles:

5.2.1 Client

Any individual, or team of people, representing a school or department which proposes work to take place, automatically becomes the CLIENT under these regulations and is legally responsible to carry out the duties specified for this role.

One of the first duties is to ensure that the other roles specified in the regulations; DESIGNER & CONTRACTOR (Principal Designer & Contractor for projects involving more than one contractor) are allocated and accepted. Failure to do this will result in the Client taking on these responsibilities as well.

The Client must full provide details of the work proposed and all known information on the construction of any structure (above or below ground) to the Designer. For some projects, the Client may also be acting as the Designer.

Where the available information is not adequate for the work proposed, the Client must arrange for additional surveys to be carried-out. (The information required is available from the E & D Directorate and for smaller jobs is usually obtained by completing the “Authorisation to Proceed” form.

The Client is also responsible for completing and sending the “F10” form for projects which are notifiable to the HSE, i.e.;

Projects over 30 working days were always notifiable before, but this is not quite the case under CDM 2015.

The 30 day threshold still stands, but only if there will be over 20 workers on site at any one time. It is important to remember that this is at any point, therefore the requirement could be triggered on day one or day 27.

As under the previous regulations, 30 working days includes part-days and weekends if work is taking place on these.

Involve more than 500 “person days”.

This is not a change as such. However, the 500 person days was largely ignored previously because the 30 day trigger was usually activated before projects were even close to 500 person days.

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Not so anymore. Now, if it is planned to only have 10 people on site, the 30 day rule won't ever apply to the project, but that does not necessarily make it un-notifiable.

The 500 person-day rule now matters significantly beyond the 30 day timeframe, so it is more likely to get triggered under CDM 2015.

If a 10 person-a-day project lasts longer than 50 days, the 500 person day rule will trigger the notification requirement.

The Client should complete the checklist in Appendix 4 to ensure that all their duties have been completed and recorded.

(General Note: Estates Managers completing an “F10” must update the F10 cabinet in the Reception of The William Emes Building, as applicable, throughout the phases of the project.) (See 5.2.1)

5.2.2 Principal Designers/Designers

Principal Designers/Designers duties are closer to those of the old CDMC (See 5.1.1). CITB Guidance states:

Main duties of the Principal Designer’s role are to plan, manage and monitor the pre-construction phase, to co-ordinate health and safety.

The pre-construction phase is defined as any period during which design or preparatory work is carried out for a project, which may continue during construction.

The Principal Designer must:

assist the client in identifying, obtaining and collating the pre-construction information;

provide pre-construction information to designers, the Principal Contractor and contractors;

ensure that designers comply with their duties and co-operate with each other;

liaise with the Principal Contractor for the duration of the appointment;

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prepare the health and safety file. The Principal Designer’s duties apply regardless of the contractual arrangements for the appointment of other designers and whether or not the project is notifiable to the Health and Safety Executive (HSE).

If the Principal Designer appoints other designers, the Principal Designer is responsible for ensuring that they have the relevant skills, knowledge and experience to deliver.

Designers decisions can affect the health and safety of workers and others who will construct, maintain, repair, clean, refurbish and eventually demolish or remove the building or structure, as well as those who will use it as a completed workplace. Taking risks arising from the design into account can positively affect the project and make it easier for these risks to be managed by contractors and those who will maintain or use the structure. The design forms an important part of delivering a project safely and without risks to health.

Designers must: understand and be aware of significant risks that workers and users can be exposed

to, and how these can arise from their design decisions; have the right skills, knowledge, and experience, and be adequately resourced to

address the health and safety issues likely to be involved in the design; check that clients are aware of their duties; co-operate with others who have responsibilities, in particular the principal designer; take into account the general principles of prevention when carrying out their design

work; provide information about the risks arising from their design co-ordinate their work with that of others in order to improve the way in which risks

are managed and controlled.

5.2.3 Principal Contractor/Contractor Duties

The role of the Principle Contractor and Contractor have largely remained the same

The Principal Contractor is the contractor in overall control of the construction phase on projects with more than one contractor. They are appointed by the client and there should only be one Principal Contractor for a project at any one time. If there is only one contractor for the work, they have responsibilities to prepare a construction phase plan and prevent unauthorised access to the site.

Principal Contractor/Contractors duties are very similar to those in the old regulations and will require them to manage health and safety on the site, on a day-to-day basis. The CITB guidance states “The term manage in this guide also includes planning, monitoring and co-ordinating the construction phase so that health and safety risks are controlled.”

Key actions include: planning: preparing a construction phase plan that ensures the work is carried out

without risk to health or safety;

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managing: implementing the plan, including facilitating co-operation and co-ordination between contractors;

monitoring: reviewing, revising and refining the plan and checking work is being carried out safely and without risks to health;

securing the site: taking steps to prevent unauthorised access to the site by using fencing and other controls;

providing welfare facilities: making sure that suitable facilities are provided throughout the construction phase;

providing site induction: giving workers, visitors and others information about risks and rules that are relevant to the site work and their work;

liaising on design: discussing with the Principal Designer any design or change to a design.

Again, this role may merge with the Designer’s for medium sized projects and for very small works such as those carried out in-house by the Operations team, all three roles could be combined in one person or section. In the latter situation it is likely that generic risk assessments and method statements, backed up by the “Point-of-Work” assessment, will suffice.

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APPENDIX LISTINGS

Appendix 1

Procedure Summary:

The following general steps must be followed when any construction work is proposed:

1. The person within a department or school instigating the works, decides whether they want Estates (E & D) to complete it or whether they will be making arrangements themselves.

If Estates will be arranging the works the school/department should provide comprehensive details, appropriate to the size of the project. E & D will then take over the role of CLIENT

If arrangements for the work will remain within the school or department then those responsible within that school or department will take on the role & responsibilities of the CLIENT. It will still be necessary to obtain details of the construction of the building in question from E & D, particularly with regard to hazards such as asbestos or services. For small projects it may suffice to complete the “Authorisation to Proceed” form, which would be a minimum requirement.

2. The CLIENT shall first appoint a designer. If a DESIGNER is not formally appointed, then the CLIENT, whether it be the

school/department or E & D, will assume the duties & responsibilities of the DESIGNER.

The DESIGNER will develop the design risk assessments, based on information from the CLIENT (these two roles may carried out by the same person/team) and arrange for further surveys where deemed necessary.

These design risk assessments will be made available and discussed with the CONTRACTOR, below. (For smaller jobs this may also be the DESIGNER and even the CLIENT too, particularly where E & D have been appointed)

3. The CLIENT shall also appoint a CONTRACTOR. The CONTRACTOR must liaise with the DESIGNER, in order to ensure that all

the reasonably foreseeable risks have been reduced to their lowest practicable level.(again, these are roles which may be carried out by the same person or team)

The CONTRACTOR will assume responsibility for the site and create a construction phase health & safety plan. For small jobs this may be as simple as a generic set of RAMS. For larger jobs they may be required to produce a Health & Safety File to hand over to the CLIENT, at the end of the project.

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4. Where more than one contractor will be involved, the CLIENT, must appoint a PRINCIPAL CONTRACTOR & PRINCIPAL DESIGNER.

All appointments, whether “Principal” or not, must be made and agreed in writing. (This may be done via e-mail)

The PRINCIPAL DESIGNER is responsible for co-ordinating the work of all the designers involved.

The PRINCIPAL CONTRACTOR, is responsible for ensuring that all sub-contractors are competent and qualified to carry out their duties and that they follow all Statutory Regulations, agreed methods-of-work and University procedures, when on site. Within the ring-fenced site, the PRINCIPAL CONTRACTOR is responsible for all aspects of health & safety, including access control and accident reporting under RIDDOR, although they must also inform the University of ANY accidents which take place.

5. Where the project is “Notifiable”, (see definition in section; 5.4 the CLIENT will inform the HSE as soon as possible, using the F10 form. A copy of this must be kept in the notice-board in the William Emes Building and another on-site.

6. For longer projects involving multiple duty-holders, the CLIENT will arrange for regular meetings between all relevant parties, throughout the project.

Appendix 212

Summary of changes from the previous legislation

Appendix 313

A summary of roles and duties under CDM 2015

Appendix 4

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Non-notifiable Projects – Clients checklist

Site Name

Description of Project

University Project Manager

Does the building Contain Asbestos

CDM Dutyholders InitialsClient (CL)

(Principal) Designer (P)D

(Principal) Contractor (P) C

Client Responsibilities

Date Commenced

Duty Initials Date Duty Initials Date Duty Initials Date

Ensure the roles, functions and responsibil ities of the project team are clear Client

Appoint a (Principal*) Designer that is competent and adequatly resourced

*Principal i f more than one contractor is to be used

Client

Appoint a (Principal) Contractor that is competent and adequately resourced

Client

(P) D

Client

(P) D (P) D

(P) C (P) C

Client Client

(P) D (P) D

(P) C (P) C

Client Client

(P) D (P) D

(P) C (P) C

Client Client

(P) C (P) C

(P) D (P) D

Client Client

(P) C

Client

(P) D

Client

Bold - refers to the main dutyholder

Ensure that the dutyholders have adequate levels of communication, co-operation and co-

ordination to carry out their required duties

Check that suitably advanced written Construction Phase Health and Safety Plan /

Risk Assessments / Method Statement are in place before the construction starts. On-going

checks throughout the construction phase

Confirm adequate welfare facilities are in place at the start and throughout the construction

phase

Produce a Health and Safety File (if more than one contractor used), or designer to revise

current site H&S file to incorporate any relevant information

Construction (Design & Management) Regulations 2015 (CDM) KU's Client Responsibilities Checklist

Yes / No R&D survey Required Yes / No

Confirm (where appropriate) the design complies with all Health and Safety

Legislation (using the principles of prevention)

Confirm with Dutyholders they have adequate time / resources to carry out their required

duties in each phase

Confirm with the dutyholders they have adequate information to carry out the required duties in each phase (The client has the main

duty for providing pre-construction information)

Organisation Name of Duty Holder Date Appointed

NON-NOTIFIABLE PROJECTS - Client ChecklistProject Number

A - Pre Works Phase B - Works Phase C - Post Works Phase

Appendix 515

Start

Is work Construction(note 1) End

Is worksINSTIGATED

by E & D

E & D areCLIENT(note 2)

Faculty areCLIENT(note 2)

Has externaldesigner been

formally appointed

CLIENTis

PROJECT DESIGNER(note 3)

Is Externalcontractor to be

appointed

E & D areSINGLE

CONTRACTOR(note 6)

Is there morethan 1

contractor

CLIENTto appoints

PRINCIPLE CONTRACTORand

PRINCIPLE DESIGNER(note 4 )

no

no

no

no

no

no

yes

yes

yes

yes

yes

yesIs work

(>30 days and >20 men)or

> 500 man days

Not Notifiable toHSE

note 1The construction, alteration, conversion, fitting out, commissioning, renovation, repair, upkeep, redecoration or other maintenance, cleaning(which involves the use of water or an abrasive at high pressure or the use of corrosive or toxic substances), de-commissioning, demolitionor dismantling of a structure.

The preparation for an intended structure, including site clearance, exploration, investigation (but not site survey) and excavation, and theclearance or preparation of the site or structure for use or occupation at its conclusion.

The assembly on site of prefabricated elements to form a structure or the disassembly on site of prefabricated elements which, immediatelybefore such disassembly, formed a structure.

The removal of a structure or of any product or waste resulting from demolition or dismantling of a structure or from disassembly of prefabricatedelements which immediately before such disassembly formed such a structure.

The installation, commissioning, maintenance, repair or removal of mechanical, electrical, gas, compressed air, hydraulic, telecommunications,computer or similar services which are normally fixed within or to a structure.

note 2Client - Anyone who has construction work carried out for them.Ensure their project is suitably managed, ensuring the health and safety of all who might be affected by the work, including members of the public.

Client must provide as much information as possible to the Project designer including, location of services, asbestos survey, etc.

note 3Project designer is required to prepare the pre-construction pack and pass to the contractor/principle contractor.

note 4Single contractor / Principle contractor are required to produce the Construction Phase Health and Safety Plan, which addresses all risks and hazards

CLIENTmust ensure that designer

has all information(note 3 )

CLIENT to notifyHSE via F10 system

Appendix 616

You may find this checklist useful as an aide memoire.

1. Are you clear about your responsibilities?2. Have you made your formal appointments?3. Have you checked that the principal designer or designer has the capability and

necessary skills, knowledge, training and experience to fulfil their duties?4. Have you checked that the principal contractor or contractor has the capability and

necessary skills, knowledge, training and experience to fulfil their duties?5. Have you checked that the project team is adequately resourced?6. Has a project or client brief been issued to the project team?7. Has the project team been provided with information about the existing site or

structure (pre-construction information)?8. Do you have access to project-specific health and safety advice?9. Are suitable arrangements in place to manage health and safety throughout the

project?10. Has a schedule of the key activities for the project been produced?11. Has sufficient time been allowed to complete the key activities?12. Where required, has an online F10 notification form been submitted to HSE to notify

them of commencement of work?13. Have you checked that a construction phase plan has been adequately developed

before work starts on site?14. Are you satisfied that suitable welfare facilities have been provided before work

starts on site?15. Have you agreed the format and content of the health and safety file?

Appendix 7

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Please see below a generic (not exhaustive) list of surveys, searches, investigations and reports which could all form pre-construction information.

Client Brief Clients Site-specific Rules + Constraints Contractors Health and Safety Information and Compliance Document Key Programme Dates Management of Building Users Existing Health + Safety File Wayleaves / Easements within land boundary Structural Survey Report Topographical Survey Existing Services + Utilities Information / searches / locations Drainage Survey Service isolation points Ground Investigation Report Bathymetric Survey Ecological Survey Report Environmental Report Site Investigation

Survey reports for hazardous materials:

Asbestos Lead Contam Land Contam services Radon

Survey reports for hazardous areas:

Confined spaces Enriched Atmospheres

Site Constraints:

Access / Egress Adjacent land use Adjacent highways Planning conditions Noise / Vibration / Dust

Owners / Landlord's (E & D) Licence to Alter (Authorisation to Proceed) - Specifications:

Deflection Services Fixings Risers Lifts  Tennant / User plant space

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