1.4 CDM 2015 Overview & Five Duty Holders (Client, Principal Designer, Principal Contractor, Designer, Contractor)

Introduction to CDM 2015

The Construction (Design and Management) Regulations 2015 (CDM 2015) are the primary statutory regulations governing health, safety, and welfare on construction projects in Great Britain. CDM 2015 replaced the previous 2007 regulations, simplifying the regulatory structure, replacing the former 'CDM Coordinator' role with the Principal Designer (PD), and extending statutory duties to domestic clients.

CDM 2015 applies to all construction projects, regardless of scale, contract value, or duration. Construction work is defined broadly under Regulation 2 to include building, alteration, conversion, fitting out, commissioning, renovation, repair, maintenance, high-pressure cleaning, dismantling, and demolition.

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The Five CDM 2015 Duty Holders

CDM 2015 establishes five primary duty holders, each holding specific legal duties across project lifecycle phases.

                 +------------------------+
                 |       THE CLIENT       |
                 | (Commercial / Domestic)|
                 +-----------+------------+
                             |
            Appoints in Writing (>1 Contractor)
                             |
        +--------------------+--------------------+
        |                                         |
        v                                         v
+-------+----------------+        +---------------+--------+
|   PRINCIPAL DESIGNER   |        |  PRINCIPAL CONTRACTOR  |
| (Pre-Construction Phase|        |  (Construction Phase   |
|  H&S Coordination)     |        |   Site Management)     |
+-------+----------------+        +---------------+--------+
        |                                         |
        v                                         v
+-------+----------------+        +---------------+--------+
|       DESIGNERS        |        |      CONTRACTORS       |
| (Architects, Engineers)|        | (Subcontractors, Trades|
+------------------------+        +------------------------+

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1. The Client

The Client is any organization or individual for whom a construction project is carried out. Clients have overall legal responsibility for ensuring that construction projects are structured and managed safely.

Key Client Duties:

• Make Suitable Management Arrangements: Ensure suitable arrangements are made for managing the project so that health, safety, and welfare are maintained throughout.
• Appoint Duty Holders in Writing: Where a project involves more than one contractor (or is reasonably foreseeable to involve more than one contractor), the Client must appoint in writing a Principal Designer (PD) and a Principal Contractor (PC) as early as possible.
• Allocate Resources and Time: Ensure sufficient time and resources are allocated for all phases of the project.
• Ensure Competence: Take reasonable steps to ensure that appointed duty holders possess the necessary skills, knowledge, experience, and organizational capability (SKEO).
• Provide Pre-Construction Information (PCI): Ensure that PCI is compiled and promptly provided to every designer and contractor tendering for or appointed to the project.
• Ensure Construction Phase Plan (CPP) Execution: Ensure that the PC prepares a suitable, site-specific CPP before construction work commences on site.
• Ensure Welfare Provisions: Ensure that suitable welfare facilities complying with Schedule 2 are provided by the PC from the start of site setup.
• Maintain the Health and Safety File: Ensure the PD prepares, updates, and passes over the Health and Safety File upon completion, retaining it for future works.

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2. The Principal Designer (PD)

The Principal Designer is an organization or individual appointed by the Client in writing on multi-contractor projects to take control of health and safety during the pre-construction phase.

Key Principal Designer Duties:

• Plan, Manage, and Monitor Pre-Construction: Coordinate health and safety during design, planning, and preparation.
• Eliminate and Control Design Risks: Assist designers to identify, eliminate foreseeable hazards, and reduce remaining risks using the General Principles of Prevention.
• Compile and Distribute PCI: Gather, organize, and provide Pre-Construction Information to designers, the Client, and the PC.
• Liaise with Principal Contractor: Share relevant design information and coordinate ongoing design changes during the construction phase.
• Prepare the Health and Safety File: Compile, update, and review the Health and Safety File during the project and hand it to the Client upon completion.

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3. The Principal Contractor (PC)

The Principal Contractor is the contractor appointed by the Client in writing on multi-contractor projects to take overall control of health and safety during the construction phase.

Key Principal Contractor Duties:

• Plan, Manage, and Monitor Construction: Coordinate all site work to ensure construction is executed without risks to health and safety.
• Prepare the Construction Phase Plan (CPP): Prepare, implement, update, and enforce a site-specific CPP before site setup or construction work begins.
• Organize Cooperation: Coordinate the activities of all contractors on site to ensure compliance with health and safety legal duties.
• Provide Site Inductions & Training: Ensure suitable site-specific inductions are delivered to every worker prior to starting work on site.
• Enforce Welfare Facilities (Schedule 2): Ensure adequate, operational welfare facilities (sanitary conveniences, washing facilities, drinking water, changing rooms, rest facilities) are available from day one.
• Secure Site Perimeter: Prevent unauthorized access to the site using suitable boundary fencing, hoardings, and access controls.
• Worker Consultation: Consult and engage with workers on site health, safety, and welfare matters.

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4. Designers

A Designer is anyone who prepares or modifies designs for a building, structure, or product used in construction (including architects, structural engineers, quantity surveyors specifying materials, or sub-contractors performing design detailing).

Key Designer Duties:

• Eliminate Hazards: When preparing designs, eliminate foreseeable health and safety risks to persons constructing, maintaining, or demolishing the structure.
• Reduce Residual Risks: Apply the General Principles of Prevention to reduce remaining risks.
• Provide Information: Include information about residual hazards in design drawings and notes provided to the PD and PC.

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5. Contractors

A Contractor is any business or self-employed individual who carries out, manages, or controls construction work.

Key Contractor Duties:

• Plan, Manage, and Monitor Own Work: Ensure work under their control is executed safely.
• Comply with Directions: Follow site rules set out in the CPP and obey directions issued by the PC.
• Provide Worker Training: Ensure their workers have received site inductions and possess required skills and qualifications.
• Report Hazards: Promptly report dangerous conditions or incidents to the PC.

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Special Rules for Domestic Clients

A Domestic Client is an individual who has construction work carried out on their own home (or the home of a family member) that is not in connection with a business.

Under Regulation 7 of CDM 2015:

• Domestic client duties are automatically transferred to the Contractor (on single-contractor projects) or the Principal Contractor (on multi-contractor projects).
• Alternatively, a domestic client may sign a written agreement transferring client duties to the Principal Designer.

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CDM 2015 Duty Holders Summary Table