The Construction (Design & Management) Regulations 2015 came into force on the
6th April 2015.
Now, all construction projects, both commercial and domestic, are bound by the CDM2015 regulations
In addition, any construction project
is notifiable to the HSE using form F10
The purpose of the 'CDM' regulations is to integrate health & safety into the management of construction projects. To this end, there are several key duty holders:
- taking more than 30 working days and having more than 20 contractors on site at any one time, or
- taking more than 500 person.days to complete
Set out below are the main duties of each of these duty holders.
- There is clearly always a client and s/he has great influence over all aspects of a project
- The is clearly always a Designer, or different designers, at different times and 'design' may be carried out any stage including during the construction phase of a project
- There will always be a contractor, or several contractors
- Principal Contractor (PC)
- If there is more than one contractor, one of them must be a Principal Contractor who is responsible for Health and Safety
- CDM Principal Designer (PD)
- There will always be one or more designers and, unless there is only one contractor, there must also be a CDM Principle Designer who is responsible for Health and Safety during the Pre-construction phase of the project (which, again may extend into the construction phase). The PD may be on the design team or not but s/he will need to have 'skills, knowledge and experience' of both design and health & safety.
Architectural Ideas can give advice on all these matters and the services provided are listed under 'Services'
Who does what when
The duties that the three main duty holders (Client, PD & PC) have are laid down in the regulations but the ways of implementing them can vary slightly depending on the size and nature of the projects.
You can see the HSE's Guide to Health & Safety in Construction (L153) here
||Duty holders' responsibilities
|Paperwork needs to be 'proportional'.
The brief, instruction or worksheet given to the operative(s) can act as the PCI and should contain any necessary risk assessments and safe working method statements - these can be selected from a set which has been pre-defined for all anticipated works.
When the job is done, the resulting information, which may include a signed and dated worksheet, a drawing, data sheets, etc., can be treated as the Health & Safty File and should be stored as such
|The Client's duties can be transferred to the PC, or the contractor if there's only one.
Or, the Client can choose to have a written agreement with the principal designer to carry out his/her duties.
So the PD may be acting purely as PD or may be carrying out the Client's duties as well.
The amount of paperwork should be 'proportional'
(with an Architect)
|The Client's duties can be transferred to the PC or the contractor, if there's only one.
If the Client doesn't appoint a PD, s/he becomes the PD
If the Client doesn't appoint a PC, s/he becomes the PC
Again, the amount of paperwork should be 'proportional'
|Design & Build
||The Contractor doing the Design and Build will be both PD and PC
||All duty holders' responsibilities apply as described below
In terms of CDM, the client has to ensure 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
For projects where there will be more than one contractor (e.g. general builder, plumber, electrician, tiler, etc), the Client is required to appoint, in writing, a CDM Principal Designer who becomes his/her chief adviser in matters relating to health & safety during the building project
It is useful if the Client either discusses and/or writes down a 'client brief'. The brief should:
- describe the main function and operational requirements of the finished building or structure
- outline your motivation for initiating the project
- give your expectations during the project
- explain the design direction you have in mind
- establish a single point of contact for any client queries or discussions during the project
- set a realistic timeframe and budget.
Who are Clients and what should they do?
|Organisations or individuals for whom a construction project is carried out||Make suitable arrangements for managing a project. This includes making sure that:|
- other duty holders are appointed
- sufficient time and resources are allocated
|Clients must also make sure that:|
- relevant information is prepared and provided to other duty holders
- the principal designer and principal contractor carry out their duties
- welfare facilities are provided
|People who have construction work carried out on their own home, or the home of a family member, that is not done in furtherance of a business, whether for profit or not.
||Domestic clients are in scope of CDM 2015, but their duties as a client are normally transferred to:|
However, the domestic client can choose to have a written agreement with a Principal Designer for him/her to carry out the client duties
- the contractor, on a single contractor project, or
- the principal contractor, on a project involving more than one contractor.
Client's Pre-construction check list:
- Are you clear about your responsibilities?
- Have you made your formal appointments?
- Have you checked that the principal designer or designer has the capability and
necessary skills, knowledge, training and experience to fulfil their duties?
- Have you checked that the principal contractor or contractor has the capability
and necessary skills, knowledge, training and experience to fulfil their duties?
- Have you checked that the project team is adequately resourced?
- Has a project or client brief been issued to the project team?
- Has the project team been provided with information about the existing site or
structure (pre-construction information)?
- Has project-specific health and safety advice been sought?
- Are suitable arrangements in place to manage health and safety throughout the
- Has a schedule of the key activities for the project been produced?
- Has sufficient time been allowed to complete the key activities?
- Where required, has an online F10 notification form been submitted to HSE to
notify them of commencement of work?
- Have you checked that a construction phase plan has been adequately developed
before work starts on site?
- Are you satisfied that suitable welfare facilities have been provided before work
starts on site?
- Have you agreed the format and content of the health and safety file?
You can see the CITB CDM2015 Guidance for Clients here
The Design team
For all projects, the Designers should:
In carrying out these duties, designers need to consider the hazards and risks to those who:
- make sure that they are competent and adequately resourced to address the health & safety issues likely to be involved in the design
- check that the client(s) are aware of their duties
- when carrying out design work, avoid foreseeable risks to those involved in the construction and future us of the structure and, in doing so, they should eliminate hazards (so far as is reasonably practicable, taking account of other design considerations) and reduce risk associated with those hazards which remain
- provide adequate information about any significant risks associated with the design
- co-ordinate their work with that of others to improve the way in which risks are managed and controlled.
You can see the CITB CDM2015 Guidance for Designers here
- carry out construction work including demolition
- clean any window or transparent or translucent wall, ceiling or roof in or on any structure or maintain the permanent fixtures and fittings
- use a structure designed as a place of work
- may be affected by such work, for example customers or the general public.
The CDM Principal Designer (PD)
- give suitable and sufficient advice and assistance to Clients
- to ensure that the appointed designers and contractors are 'competent' in health & safety matters
- to ensure there are suitable management arrangements for the project including welfare facilities
- to allow sufficient time and resources for all stages (including preparation and lead‑in)
- to notify the HSE about the project †
- to co-ordinate H&S design work and planning
- to assemble Pre-construction Information identifying any surveys needed
- to give relevant PCI data to designers and contractors
- to manage the flow of H&S information between clients, designers and contractors
- to advise the client on the efficacy of the HSP and the arrangements made for welfare facilities
- to produce and update a relevant HSF ††
Where jobs are very small (e.g. s or simple domestic jobs) it is appropriate to apply the regulations in a 'proportional' way. For instance:
- A minor maintenance job
- The brief to the operative (which might be a drawing or even just a work ticket) could be regarded as PCI and a signed-off work ticket could be regarded as the HSF
- A small domestic job
- The brief to the contractor (e.g. a drawing with notes) could be regarded as the PCI and little more than an as-built drawing (and possibly some data sheets, etc.) could be regarded as the HSF
|†||A project is notifiable to the HSE using form F10 if the construction phase:
- 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
|††||The Health & Safety File is an end-of-project collection of relevant facts, data sheets, instructions and residual health & safety issues
You can see the CITB CDM2015 Guidance for Principal Designers here
The Principal Contractor (PC)
The duties of the Principal Contractor include:
For 'notifiable' projects
- Satisfy themselves that:
- the client(s) are aware of their duties
- a CDM Principal Designer (PD) has been appointed
- the HSE has been notified
before they start work.
- Make sure they are competent to address the likely H&S issues
- Ensure that the construction phase is properly planned, managed and monitored by adequately resourced site management
- Ensure that every contractor is told how much time they have for planning before working on site
- Ensure that all contractors are given the information they need for safe working
- Ensure safe working, co-ordination and co-operation between contractors
- Ensure that a suitable H&S Plan is:
- produced before work begins
- developed in discussion with contractors affected by it
- kept up to date.
- Satisfy themselves that any designers and contractors they engage are competent and adequately resourced
- Ensure suitable welfare facilities are provided from the start
- Take steps to prevent unauthorised access to the site
- Prepare and enforce any necessary site rules
- Provide copies of the H&S Plan to contractors in time for them to plan
- Liaise with the PD on any design carried out during construction
- Provide the PD with information for the H&S File
- Ensure that all workers are provided with induction, information and training
- Ensure that the workforce is consulted about H&S matters
- Display the notification (F10)
PC's Construction Phase Plan risk check list:
- C - collapse
- The collapse of excavations, scaffolding, temporary structures, all/part of the works, adjacent buildings, etc
- E - electricity
- Electric shock from faulty equipment or from touching live, overhead or underground cables
- F - fire
- Fire occurring in flammable parts of the structure, debris, raw or waste materials, gases, adhesives, solvents, etc
- H - heights (falling from over 2m)
- Risk of falling from ladders, scaffolding, towers, roofs, fascias, gutters, catwalks, steelwork, etc
- M - manual handling
- Personal injury through handling awkward or heavy materials without adequate lifting equipment; or the handling of dangerous materials without adequate protection such as masks, gloves, etc.
- N - noise (and vibration)
- The protection of operatives and the public from noise, noise pollution and vibrations caused by vehicles, plant, equipment or machinery, etc
- O - objects (dropping from a height)
- Injury from materials, plant or equipment falling from the building, cranes, scaffolding, etc
- P - plant
- Being hit/injured by mobile plant, etc
- S - substances (hazardous)
- Protection from and/or storage of toxic/dangerous substances such as glues, adhesives, gases, asbestos, radioactive substances, poisons, metal chaff, airborne dust, etc
- T - tripping
- Tripping or slipping on wet/slippery surfaces during construction, cleaning, etc
- W - working in confined spaces
- Installation, modification, maintenance, cleaning, etc., in spaces where there is inadequate access, lighting or air quality
You can see the CITB CDM2015 Guidance for Principal Contractors here