Construction Design and Management Regulations 2015 (CDM 2015) – Frequently Asked Questions


How does CDM (2015) apply to  domestic clients and commercial clients?

As a commercial client your duties are to appoint – in writing – a Principal Designer (PD). If there is more than one contractor involved you are also required to hire a Principal Contractor (PC). If you do not make these appointments then these duties will fall to you as the client.

As a domestic client, you are not required to carry out duties placed on commercial clients.

Where the project involves:

  • Only one contractor, the client duties must instead be carried out by the contractor as well as the duties they already have as contractor for the project.
  • More than one contractor, the client duties must be carried out by the PC as well as the duties they already have as PC. If the domestic client has not appointed a PC then the duties of the client will be carried out by the contractor in control of the construction work.

When does a project become notifiable to the HSE?

A project is notifiable if construction work lasts longer than 30 working days and has more than 20 workers working simultaneously at any point in the project, or exceeds 500 person days. So, in practice it would be possible to have a project on site for 40 working days with the maximum number of persons on site not exceeding 12 (max possible 480 person days) or 60 days with 8 workers (max possible 480 person days).

Does the Principal Designer (PD) replace the CDM Co-ordinator (CDMc)?

A. The PD is not a replacement for the CDMc – the PD manages and co-ordinates the design stage of the project. Their role is to plan, manage, monitor and co-ordinate the pre-construction phase, and to ensure designers comply with their duties and co-operate with the client including the provision of Pre-Construction Information.

What role does the Principal Contractor (PC) have?

The PC manages and coordinates the construction stage of the project. The PC is also required to liaise with the PD, providing them with information which is relevant to the health and safety file, and engage and communicate with the workforce.

What duties do designers have?

Designer duties remain similar to those in CDM 2007 although they are also required to:

  • Reduce or control risks through the design process and provide risk information with design drawings
  • Refer risks that cannot be reduced or controlled through design to the PD and,
  • Set a clear hierarchy for design risk management.

What duties to contractors have?

Like the designer, the contractors’ duties remain similar to those in CDM 2007 although additional requirements include:

  • Plan, manage and monitor their construction work
  • Comply with directions given by PD or PC and,
  • Draw up a Construction Phase Plan (CPP) even if they are the only contractor.

What do all these duty-holders have in common?

Not accepting an appointment unless they have the skills, knowledge, experience and, (if an organisation) the organisational capability to perform the role for which they are appointed.

What would need to be done if a project started before 6th April 2015 and continued beyond this date?

For projects which involve more than one contractor and have started before 6 April 2015, and the client has not appointed a CDM co-ordinator, the client must appoint a Principal Designer as soon as it is practical.

If the construction phase has not started the client is not required to appoint a Principal Designer. If the construction phase has started, the client may appoint a PD if they wish. If they choose not to appoint a PD, the PC takes on the responsibility for the health and safety file.

Where CDMc has been appointed the client must appoint a PD within 6 months e.g. by 6 October 2015.