CDM Regulations 2015: Duties of the Client, Principal Designer, Designer, Principal Contractor and Contractor

Definition

The Construction (Design and Management) Regulations 2015 (CDM 2015) are the principal set of regulations managing the health, safety and welfare of construction projects in Great Britain. They are made under the Health and Safety at Work etc. Act 1974 and are enforced by the Health and Safety Executive (HSE). CDM 2015 replaced the 2007 Regulations on 6 April 2015 and introduced the role of principal designer in place of the former CDM coordinator.

CDM 2015 creates five named dutyholder roles — client, principal designer, designer, principal contractor and contractor — with specific, non-delegable legal duties. The regulations apply to all construction work, with proportionate application to domestic projects.

Why this matters for Health and Safety

• Level 2 competence: candidates are expected to demonstrate active application of CDM 2015 on live projects, including preparing or reviewing pre-construction information, construction phase plans and health and safety files.
• CDM 2015 is a mainstay of APC interviews for Building Surveying, Project Management, Quantity Surveying and many other pathways.
• A breach of CDM duties can lead to prosecution under the Health and Safety at Work etc. Act 1974 — unlimited fines and imprisonment for individuals.
• Surveyors often occupy more than one role — e.g. employer's agent acting as designer for contract design changes — so understanding duty overlap is essential.
• RICS Rule 5 (competent service) requires members to comply with all applicable statutory obligations, of which CDM is a core example.

Key principles and dutyholder roles

1. The Client

The commercial client holds the ultimate responsibility for project safety. Specific duties under Regulation 4 include:

• Making suitable arrangements for managing the project and maintaining them throughout.
• Appointing a principal designer (PD) and principal contractor (PC) in writing where more than one contractor is involved.
• Providing pre-construction information (PCI) to designers and contractors.
• Ensuring a Construction Phase Plan (CPP) is in place before work starts.
• Ensuring a Health and Safety File is prepared and handed over at project end.
• Notifying the HSE (F10) where the project is notifiable.

Domestic clients automatically have most of their duties passed to the PC (single contractor) or PD (multiple contractors) unless they appoint in writing.

2. The Principal Designer (PD)

The PD is appointed by the client and leads pre-construction-phase health and safety. Duties include:

• Planning, managing, monitoring and coordinating H&S in the pre-construction phase.
• Identifying, eliminating or controlling foreseeable risks (the "hierarchy of risk control").
• Cooperating with other designers and the PC.
• Preparing and providing the PCI to designers and contractors.
• Preparing and compiling the Health and Safety File until project completion.

3. The Designer

Any organisation or individual who prepares or modifies designs. Designer duties include:

• Eliminating, reducing or controlling foreseeable risks arising from the design.
• Providing information to other dutyholders (e.g. maintenance strategies, unusual loads).
• Cooperating with the PD, client and other designers.

The designer's duty engages at concept stage — design review meetings, "buildability" workshops and risk registers evidence compliance.

4. The Principal Contractor (PC)

Appointed by the client to coordinate construction-phase health and safety. Duties include:

• Planning, managing and monitoring construction-phase H&S, including liaising with designers.
• Preparing, developing and implementing the Construction Phase Plan.
• Providing site induction, welfare facilities and preventing unauthorised access.
• Consulting and engaging with workers on H&S matters.

5. The Contractor

Any individual or business that carries out or manages construction work. Duties include:

• Planning, managing and monitoring their own work and that of their workers.
• Complying with the Construction Phase Plan prepared by the PC.
• Providing supervision, information, instruction and training.
• Not beginning work on site until the client's welfare arrangements and induction are in place.

6. Notification (F10) and key documents

A project is notifiable to the HSE when construction work is scheduled to last longer than 30 working days with more than 20 workers simultaneously, or exceed 500 person-days. The client submits Form F10 online before work begins and updates it if the scope changes materially.

Three documents sit at the heart of CDM:

1. Pre-Construction Information (PCI) — prepared/coordinated by the PD; shared with designers and contractors at tender.
2. Construction Phase Plan (CPP) — prepared by the PC; required before site work starts.
3. Health and Safety File — prepared by the PD (or PC on single-contractor jobs); handed to the client at completion for the life of the structure.

Relevant RICS guidance and legislation

• Construction (Design and Management) Regulations 2015 (SI 2015/51) — the primary statute.
• HSE Approved Code of Practice L153: Managing health and safety in construction (2015) — formerly statutory guidance; still the leading interpretive source.
• Health and Safety at Work etc. Act 1974 — the enabling legislation and source of general duties.
• Management of Health and Safety at Work Regulations 1999 — risk assessment duties that interlock with CDM.
• Building Safety Act 2022 — amends CDM duties for higher-risk buildings, introducing the Gateway regime managed by the Building Safety Regulator.
• RICS Professional Statement: Surveying Safely (2nd edition, 2018) — the mandatory safety standard for all RICS members.
• RICS Guidance Note: Management of Risk (1st edition) — supplements Surveying Safely.

Ethics and Rules of Conduct angle

CDM compliance engages Rule 5 (competent service) of the RICS Rules of Conduct. Surveyors Safely (the RICS professional statement) is mandatory — failure to follow it is a conduct matter in its own right. Where candidates act as designer or PD, they must have the skills, knowledge, experience and organisational capability (SKEO) required by Regulation 8 — advising the client honestly that you lack SKEO is itself an ethical obligation under Rule 3 (integrity).

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