CDM 2015: Where do construction projects commonly go wrong?
Construction projects often run into problems because responsibilities are unclear before work begins. A business may assume its contractor is handling everything, while the contractor may believe the client or designer has already dealt with the necessary safety arrangements.
The Construction (Design and Management) Regulations 2015, known as CDM 2015, apply to construction work of all sizes. This includes smaller projects such as office refurbishments, shop alterations, maintenance work, and extensions.
Getting the main responsibilities clear at the start can reduce confusion, delays, and unmanaged risk.
TLDR; what does a client need to do under CDM 2015?
A commercial client commissioning construction work must make suitable arrangements for managing the project safely. This includes:
Allowing enough time and resources for the work.
Providing available information about the site and known hazards.
Appointing suitable organisations and people.
Appointing a principal designer and principal contractor in writing when more than one contractor is involved or is reasonably foreseeable.
Making sure a construction phase plan is prepared before construction begins.
Checking that suitable welfare facilities will be available.
Making sure arrangements are maintained and reviewed throughout the project.
Appointing a contractor does not remove the commercial client's responsibilities
What is CDM 2015?
CDM 2015 is the main set of UK regulations covering health, safety and welfare during construction projects. The regulations define responsibilities for the organisations and people involved, including:
clients
designers
principal designers
principal contractors
contractors
workers
The requirements apply throughout the project, from early planning and design through to construction and completion. The arrangements should reflect the size, complexity, and level of risk involved. A small office refurbishment will not require the same level of management as a major development, but it must still be planned and managed properly.
Who is the client under CDM 2015?
The client is the organisation or individual for whom the construction work is being carried out.
On a commercial project, this will normally be the business commissioning the work rather than the contractor completing it. The client retains specific responsibilities even when a contractor is appointed to manage the project.
Example: office refurbishment
A business appoints a local contractor to refurbish its office. The business is the commercial client because it commissioned the work. Even if the contractor manages the activity on site, the client must still make sure suitable arrangements are in place for managing the project.
Example: warehouse extensions
A manufacturing business commissions a warehouse extension and appoints an architect and building contractor. If more than one contractor is involved or it is reasonably foreseeable that more than one will be involved, the client must appoint a principal designer and principal contractor in writing.
Example: alterations to a retail unit
A retailer appoints a contractor to remove internal walls and change the layout of a shop. The work appears straightforward, so nobody discusses CDM responsibilities. However, the retailer is still the commercial client. The project does not fall outside CDM because it is small or because the client was unaware of the requirements.
This is where confusion frequently begins. Paying a contractor to complete the work is not the same as transferring every legal responsibility to them.
What must a commercial client do before work begins?
Many CDM difficulties can be traced back to decisions made, or missed, before construction starts. A commercial client should address the following points.
1. Put suitable project arrangements in place
The client must make suitable arrangements for managing the project. These arrangements should include sufficient time and appropriate resources.
They should be proportionate to the work and should allow risks to be managed throughout the project, not only at the start.
2. Provide pre-construction information
People planning and carrying out the work need relevant information about the project, site and existing hazards.
Depending on the work, this could include:
Existing building information
Asbestos survey findings
Known structural issues
Underground or overhead services
Access restrictions
Occupied areas
Information about other activities on the site
Known hazards that may affect the work
Relevant information from an existing health and safety file
This information should be provided early enough for designers and contractors to take it into account.
3. Appoint suitable duty holders
The client should take reasonable steps to make sure the organisations and people appointed have the skills, knowledge and experience needed for their roles. Organisations should also have suitable organisational capability.
Where more than one contractor is involved, or is reasonably foreseeable, the client must appoint:
A Principal Designer to plan, manage, monitor and coordinate health and safety during the pre-construction phase
A Principal Contractor to plan, manage, monitor and coordinate health and safety during the construction phase
These appointments must be made in writing.
If the client does not make the required appointments, the relevant responsibilities may remain with the client.
4. Make sure a Construction Phase Plan is prepared
Every construction project must have a Construction Phase Plan in place before construction work begins.
The plan should set out how health and safety will be managed during the construction phase.
For a project involving one contractor, that contractor prepares the plan. Where more than one contractor is involved, the Principal Contractor prepares it.
The client should make sure the plan has been prepared. This does not mean the client must write the plan on the contractor’s behalf.
5. Check that suitable welfare facilities will be available
Suitable welfare facilities must be provided from the beginning of the construction phase and maintained throughout the work.
Depending on the project, these may include:
Toilets
Washing facilities
Drinking water
Changing facilities
Somewhere suitable to rest and eat
Welfare should be considered when the project is being planned, rather than after people arrive on site.
6. Make sure the health and safety file is managed
A health and safety file is required for projects involving more than one contractor.
The Principal Designer prepares and maintains the file during the project. It should contain information that may be needed during future construction, maintenance, alteration or demolition work.
At the end of the project, the file is passed to the client. The client must retain it and make it available to people who may need it for later work.
What should a Construction Phase Plan contain?
A Construction Phase Plan does not need to be unnecessarily long. It needs to reflect the project and the actual risks involved.
For a smaller refurbishment project, it may cover:
A description of the work
Project contacts and responsibilities
Site access and security
Site rules
Significant hazards and control measures
Arrangements for protecting employees, visitors and members of the public
Welfare facilities
Emergency arrangements
Site inductions
Communication between contractors
Supervision and monitoring
How changes to the work will be managed
A concise plan that people understand and follow is more useful than a lengthy generic template that has little connection to the work.
The plan should also remain relevant as the project progresses. If the work, people or risks change, the arrangements should be reviewed.
Five common CDM mistakes
Assuming the contractor has taken over every responsibility
Appointing a contractor does not remove the client’s specific CDM duties.
Failing to appoint duty holders in writing
Where more than one contractor is involved, the appointments of the Principal Designer and Principal Contractor must be recorded in writing.
Starting work before a Construction Phase Plan is ready
The plan must be prepared before the construction phase begins.
Using a generic plan from another project
The document should reflect the actual work, location, people and significant risks.
Producing paperwork without applying it on site
Written arrangements are only effective when they are communicated, followed and reviewed.
When does a construction project require an F10 notification?
Some construction projects must be notified to the Health and Safety Executive using an F10 notification.
A project is notifiable if the construction work is expected to:
last longer than 30 days and have more than 20 workers on site at the same time at any point,
Or
exceed 500 person days of construction work
The client is responsible for making sure the notification is submitted. Another party may submit it on the client's behalf, but the client should check that this has happened.
A copy of the F10 should be displayed where workers can read it, and the notification should also be updated if relevant project information changes.
An F10 notification is not suitable for the other CDM arrangements. A project may be covered by CDM even when it does not meet the notification thresholds.
Why do CDM arrangements break down?
Common reasons include:
Planning begins too late
Responsibilities are not discussed
Required appointments are not made in writing
Important site information is not shared
Contractors do not coordinate their activities
Supervision is inconsistent
Site conditions change but the plan does not
Documents describe controls that are not being followed
The client assumes someone else has completed the F10 notification
The common issue is often a focus on completing documents rather than managing the work. A good plan should help people carry out the project safely. It should be clear, relevant and reflected in day-to-day site activity.
“One of the most common misconceptions we come across is that appointing a contractor transfers all responsibility. Many projects begin without a clear discussion about who is responsible for what, which can create avoidable problems before work even starts." Sam Neal, Orchard Safety
Practical CDM support from Orchard Safety
CDM 2015 is intended to make sure construction work is properly planned, coordinated and managed.
For smaller projects, effective compliance often comes from making the right appointments, sharing the right information and agreeing practical arrangements before work begins.
Orchard Safety supports clients and contractors with:
Understanding CDM responsibilities
Reviewing project arrangements
Construction Phase Plans
Pre-construction information
Duty-holder arrangements
Practical health and safety advice
Planning construction, refurbishment or maintenance work and unsure what applies? Contact us for clear, practical guidance before the project starts.
Frequently asked questions about CDM 2015
Does CDM 2015 apply to small construction projects?
Yes. CDM 2015 applies to construction work of all sizes. The arrangements should be proportionate to the project, but smaller work is not automatically exempt.
Does CDM apply to office refurbishments?
Yes. Refurbishment, alteration, maintenance and similar building work can fall within the definition of construction work.
Does every project need a Construction Phase Plan?
Yes. A Construction Phase Plan must be prepared before construction work starts. This applies whether the project involves one contractor or several contractors.
Who prepares the Construction Phase Plan?
On a single-contractor project, the contractor prepares it. When more than one contractor is involved, the Principal Contractor prepares it.
When must a Principal Designer and Principal Contractor be appointed?
The client must appoint them when more than one contractor is involved, or when it is reasonably foreseeable that more than one contractor will be involved.
Can a client transfer all CDM duties to a contractor?
No. Contractors and other duty holders have their own responsibilities, but appointing them does not remove the client’s specific duties.
Does every project need an F10 notification?
No. Only projects meeting the notification thresholds require an F10. However, CDM duties can still apply when a project is not notifiable.
Who is responsible for the health and safety file?
On a project involving more than one contractor, the Principal Designer prepares and maintains the file during the project. It is passed to the client at completion, and the client retains it for future use.
