The Construction (Design and Management) Regulations 2015 (CDM)

Everyone involved in a construction project has legal duties under CDM 2015. These ‘duty holders’ are defined as Client, Principal Designer, Principal Contractor, Designers, Contactors and Workers.

What are the CDM regulations?

The Construction (Design and Management) Regulations (CDM 2015) are the main set of regulations for managing the health, safety, and welfare of construction projects. CDM applies to all building and construction work and includes new build, demolition, refurbishment, extensions, conversions, repair, and maintenance.

What is the purpose of the CDM regulations?

CDM aims to improve health and safety in the industry by helping you to sensibly plan the work so the risks involved are managed from start to finish and ensure you have the right information about the risks and how they are being managed.

The CDM regulations apply to every construction project, even construction work that one might not consider to be a project, like maintenance activities. It does not matter what the duration of the work is, or the size of the task, if it is construction work then CDM applies.

CDM duty holders and their duties

  1. Clients

Organisations or individuals for whom a construction project is carried out that is done as part of a business.

Main duties

Make suitable arrangements for managing a project, including making sure:

  • Other duty holders are appointed as appropriate.
  • Sufficient time and resources are allocated.
  • Relevant information is prepared and provided to other duty holders.
  • The principal designer and principal contractor carry out their duties.
  • Welfare facilities are provided.
  1. Principal designers
    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.

Main duties

  • Plan, manage, monitor, and coordinate health and safety in the pre-construction phase of a project.

This includes:

  • Identifying, eliminating, or controlling foreseeable risks.
  • Ensuring designers carry out their duties.
  • Prepare and provide relevant information to other duty holders.
  • Liaise with the principal contractor to help in the planning, management, monitoring and coordination of the construction phase.
  1. Principal contractors

Contractors appointed by the client to coordinate the construction phase of a project where it involves more than one contractor.

Main duties

  • Plan, manage, monitor, and coordinate health and safety in the construction phase of a project.

This includes:

  • Liaising with the client and principal designer.
  • Preparing the construction phase plan.
  • Organising cooperation between contractors and coordinating their work.

Make sure:

    • Suitable site inductions are provided.
    • Reasonable steps are taken to prevent unauthorised access.
    • Workers are consulted and engaged in securing their health and safety.
    • Welfare facilities are provided.
  1. Designers

Organisations or individuals who as part of a business, prepare or modify designs for a building, product or system relating to construction work.

Main duties

When preparing or modifying designs, eliminate, reduce or control foreseeable risks that may arise during:

  • Construction.
  • The maintenance and use of a building once it is built.
  • Provide information to other members of the project team to help them fulfil their duties.
  1. Contractors

Those who carry out the actual construction work, contractors can be an individual or a company.

Main duties

  • Plan, manage and monitor construction work under their control so it is carried out without risks to health and safety.
  • For projects involving more than one contractor, coordinate their activities with others in the project team – in particular, comply with directions given to them by the principal designer or principal contractor.
  • For single contractor projects, prepare a construction phase plan.
  1. Workers

Those working for or under the control of contractors on a construction site.

Workers must:

  • Be consulted about matters which affect their health, safety, and welfare.
  • Take care of their own health and safety, and of others who might be affected by their actions.
  • Report anything, they see which is likely to endanger either their own or others’ health and safety.
  • Cooperate with their employer, fellow workers, contractors, and other duty holders.

Where we act as duty holder. We take on CDM duties on process plant, shutdowns and tie-ins across chemical, pharmaceutical, FMCG and energy sites, including live COMAH establishments. See all the sectors we work in.

How we approach it

The first conversation is about which role you need filling. Some clients need a Principal Designer, some a Principal Contractor, some both, and some just need support to discharge their own duties. We say plainly which applies, where our appointment starts and stops, and what stays with you. Getting that wrong at the outset is the most common cause of duties going unmanaged.

As Principal Designer we challenge the design against how the work will be built, operated and maintained on plant that is usually still running. Working at height, confined space entry, isolation, hazardous materials, lifting and tie-ins into live systems are worked through while the design can still change cheaply. Decisions and residual risks are recorded as they are made, so the Pre-Construction Information and the Health and Safety File build up through the project rather than in a rush at handover.

As Principal Contractor we run the construction phase itself – site rules, inductions, access control, permits, contractor coordination, temporary works, welfare and logistics – usually on operating sites, where our arrangements sit under the site’s own permit and isolation systems. Because engineering and site delivery come from one business, design intent and site reality stay connected. Work is delivered under our ISO 9001:2015 quality system.

What you get

  • A written statement of duty holder roles and where our appointment sits
  • Pre-Construction Information compiled and issued to the project team
  • A design risk register showing what was eliminated, reduced and what remains
  • Design reviews for buildability, maintainability and safe operation
  • A Construction Phase Plan, kept current as works develop
  • Site rules, induction, permit and access arrangements, and contractor coordination
  • Site monitoring, inspection records, and incident and near miss reporting
  • A Health and Safety File compiled through the project and handed over at the end

When clients typically call us

  • A capital project involves several contractors and there is no in-house duty holder
  • A shutdown or tie-in puts several contractors onto live plant at once
  • The client team is unclear what its own duties involve in practice
  • An existing appointment is not working and the role needs picking up mid-project
  • Maintenance, refurbishment or decommissioning work turns out to fall within scope
  • Handover documentation from an earlier project is incomplete and needs rebuilding

Frequently asked questions

Can you act as both Principal Designer and Principal Contractor?

Yes, and on integrated projects it works well because coordination between design and construction is direct. The appointment sets out how each role is resourced and how decisions are recorded, so separation of duties stays visible.

Can you take the Principal Designer role on someone else’s design?

Yes. We review the design, establish what risk information exists, and engage the original designers to close the gaps. Where the design basis cannot be evidenced we will say so before the appointment is confirmed.

How early should we appoint?

As early as you can. Appointing at concept or front end design is where the biggest risk reductions sit, because layout, access and maintenance strategy can still be influenced without a cost or programme penalty.

How does this work on an operating COMAH site?

Our arrangements are written to sit underneath your safety management system, not alongside it. Permits, isolations, area authorities and emergency arrangements remain yours, and construction controls interface with them.

Related: Part of our site and construction management services. See also Principal Designer and Principal Contractor duties.

Talk to us about your project. Request a call