Teuchter, The articles that are referred to are the same buzz articles you referred to in your earlier post. Here are the links - they are quite good reading and very informative:
Brixton Arches: Network Rail set to break Lambeth council’s planning conditions
Brixton Arches redevelopment: Lambeth Council and Network Rail – Just Good Friends?
Network Rail and the Brixton and Herne Hill arches: it’s a shambles
Network Rail and Brixton Viaduct redevelopment – it’s going to be disruptive and chaotic
Brixton Arches: Network Rail told to move their hoardings back off the pavement
In connection with the Planning Officer's comments, I can advise you that I have had sight of the email sent by the Planning Officer where is it stated, quite clearly, in response to a query over the scope of Condition 4, that
"no development shall commence before this condition is discharged and this includes site preparation and clearance"
Regarding the safety aspect of managing a site during any kind of works, (enabling, main development, etc), with mixed occupancy, (including contractors, workers and the general public), the level of responsibility increases exponentially on the contractors to ensure a safe environment, which is why things like CEMP's are required in such a sensitive location and projects like this one, especially with the general public in close proximity. It is a simple and effective approach that is designed to maintain safety for everyone.
For Network Rail to commence unidentified enabling works within internal spaces, especially at the widest part of the viaduct, (for example the religious premises located in the centre of the viaduct and enclosed by other spaces), would not be safe unless the viaduct was fully under the management and control of the contractors. It is not.
Further reading of the planning documents show this was always the approach intended by the applicants as the entire planning process was conducted and approved with the pre-requisite of full and vacant possession of the entire viaduct. If they had achieved this and removed all of the tenants, then a full site compound would have been set up, contractor access throughout the viaduct would be possible and a uniform and comprehensive set of safety procedures would be in place. The necessary checks and documentation would also have been approved by the necessary authorities.
Instead, Network Rail are now approaching the project in an entirely different way, effectively attempting to commence works without wanting to assess and discharge the essential safety responsibilities that rest with them. If Network Rail are permitted to commence these enabling works without completing a CEMP, this will also mean that statutory consultees, such as the emergency services, will not be advised of these operations and the increased risks occurring. More importantly no measures regarding emergency access or site management will be in place, which is clearly a problem on Atlantic Road. Once again, within the CEMP the contractors are obliged to discuss these matters with all relevant parties, (TfL, Police, Ambulance & Fire Services, etc), and make the necessary preparations, which may include road restrictions, suspensions of bus services, etc.
I appreciate that to the uninitiated this all seems excessive and difficult, but health and safety regulations and other obligations that relate to safety within building operations have been developed from the experiences of the past and the horrors of disasters and avoidable accidents and incidents that can occur anywhere and at anytime.
Your own analysis of the risk is very cavalier and similar to that of Network Rail. Of course imagination is the exact reason why health and safety is so critical, the mere thought of an incident in an enclosed area, with passengers above the viaduct, tenants and the general public within the viaduct and contractor operating in any one of three separate, enclosed and interlinked premises is something that needs to be avoided absolutely.