The Construction (Design and Management) Regulations 2015 (CDM 2015) govern health and safety across every UK construction project. Understanding your role — and acting on it early — protects you legally, keeps projects on programme, and results in better buildings. This guide is written for clients, developers, and the design teams they appoint.
- Who CDM 2015 Applies To
CDM 2015 defines five duty holders. Every construction project has a client. Projects with more than one contractor must also have a Principal Designer and Principal Contractor, formally appointed in writing.
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The Five CDM Duty Holders Client: The organisation or individual commissioning the work. Has overarching responsibility for setting the right conditions. Principal Designer (PD): Coordinates health and safety during design and pre-construction. Must be appointed before detailed design begins. Designer: Any individual or organisation preparing or modifying designs — architect, structural engineer, M&E consultant, etc. Principal Contractor (PC): Manages H&S on site during construction. Must be appointed before the construction phase begins. Contractor: Any business carrying out construction work. Responsible for safe working practices on site. |
- How Designers and the Principal Designer Are Appointed
Appointments are one of the most commonly missed duties under CDM 2015. The regulations are specific: appointments must be in writing and made at the right point in the project.
Appointing Designers
Any organisation or individual preparing a design — structural engineers, architects, M&E consultants, interior designers — is a Designer under CDM 2015 from the moment their appointment begins. There is no formal HSE template: a standard letter of appointment, scope of services, or professional services contract is sufficient, provided it:
- Identifies the scope of design work being undertaken
- Confirms the designer has the skills and experience appropriate to the project
- Acknowledges CDM duties, including the obligation to eliminate or reduce foreseeable risk through design
- Names the Principal Designer for coordination purposes
Appointing the Principal Designer
The client must appoint the Principal Designer in writing before detailed design commences — ideally at project inception. The PD is typically the lead designer on the project: most commonly the architect on building projects, or the structural engineer where structural complexity is the primary design risk. The appointment letter must:
- Be made directly by the client (not delegated to a contractor or agent)
- Confirm the PD’s specific CDM responsibilities under Regulation 11
- Remain in place until the project is complete and the H&S File is handed over
- Be reviewed if the scope changes significantly or the PD firm changes
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Important • If no Principal Designer is appointed, the client assumes all PD duties by default — including coordinating design risk and producing the H&S File. • On notifiable projects, the absence of a written PD appointment is a criminal offence. |
Appointing the Principal Contractor
The client must appoint the Principal Contractor in writing before the construction phase begins. This is typically done at tender award or contract execution. The PC appointment triggers the obligation to produce the Construction Phase Plan before any work commences on site.
| Principal Designer — Must Have | Principal Contractor — Must Have |
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• Written appointment from the client • Relevant professional qualifications (IStructE, RIBA, ICE) • Experience of the project type and scale • Demonstrable CDM coordination capability • Organisational resource to manage design team |
• Written appointment from the client • SSIP/CHAS or equivalent accreditation • Construction Phase Plan before site start • Site induction and welfare arrangements in place • F10 notification displayed on site |
- Client Duties — What You Must Do
The client has more influence over project health and safety than any other duty holder. Budget, programme, and appointments are all client decisions — and CDM 2015 reflects that by placing clear legal obligations on clients from day one.
Make Suitable Arrangements
Before any design or construction begins, clients must ensure:
- Sufficient time is allocated — do not impose unrealistic programmes that compromise safe planning
- Budget reflects the true cost of safe design, welfare provision, and CDM compliance
- All duty holders have appropriate skills, knowledge, and experience for the project
HSE Notification — When It Applies
Projects lasting more than 30 working days with more than 20 simultaneous workers on site, or exceeding 500 person-days of construction work, must be notified to the HSE via the F10 form before construction begins. The client is responsible for this, though the PD can submit on their behalf.
Construction Phase Plan and H&S File
- Ensure the Principal Contractor provides a Construction Phase Plan before work starts on site
- Ensure the Principal Designer compiles and hands over a completed Health & Safety File at project end
- Keep the H&S File and make it available to anyone carrying out future construction, maintenance, or demolition on the structure
- Giving Designers What They Need — Client Brief and Site Information
One of the most practical ways a client fulfils their CDM duties is by providing complete, accurate site information at the point of designer onboarding. Gaps in this information create risk — and delay. The following should be assembled before the first design team meeting.
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Information Clients Should Provide at Designer Onboarding The Client Brief • Project scope, objectives, and programme • Budget parameters and key constraints • Operational requirements and future maintenance expectations • Planning or listed building constraints • Sustainability or energy performance targets
Existing Site Conditions • As-built drawings, original structural calculations, and O&M manuals • Ground investigation reports and borehole logs • Contamination surveys and remediation history • Drainage surveys and utility records (CCTV, service drawings) • Flood risk data and SuDS information
Health & Safety and Hazardous Materials • Asbestos management plans and refurbishment/demolition surveys (R&D Survey) • Previous H&S files from earlier construction phases • Records of structural modifications or remedial works • Known site hazards — buried structures, voids, previous industrial use • Fire safety records and existing means of escape information |
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Asbestos — A Common Gap • An R&D Asbestos Survey is a legal requirement before any refurbishment or demolition work. It must be provided to designers before they begin detailed design. • Providing only a management survey is not sufficient — management surveys do not sample all areas and are not suitable for design purposes. • If no survey exists, commission one before designer onboarding begins. |
- Structural Engineering and Asset Inspections
For most projects involving existing buildings or infrastructure, a structural inspection of the asset is not just good practice — it is a practical prerequisite for safe, accurate design. Structural engineers require verified information about what exists before they can design what comes next.
Why Inspections Are Required
Existing as-built drawings, where they exist, are frequently inaccurate. Buildings are modified over time, materials degrade, and loading patterns change. Designers who rely on unverified records risk producing designs that conflict with actual site conditions — creating safety risks and costly abortive work on site.
What a Structural Inspection Covers
A structural engineering inspection of an existing asset can typically assess:
- Overall structural form — frame type, material, primary load paths
- Condition of structural elements — corrosion, cracking, deflection, deterioration
- Foundation type and evidence of settlement or movement
- Floor loadings — slab thickness, reinforcement (where accessible via intrusive investigation)
- Roof structure and its condition — particularly relevant for plant additions or solar PV
- Any non-original modifications, extensions, or structural interventions
- Interface conditions where new works will connect to existing structure
Types of Structural Inspection
| Desk Study / Walkover Survey | Intrusive Structural Survey |
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• Review of available drawings and records • Visual inspection of accessible structure • Identifies areas of concern requiring further investigation • Suitable for low-risk or early-stage feasibility • Rapid and low cost |
• Opening up works to expose structural elements • Covermeter surveys and rebar scanning • Core sampling and lab testing of materials • Load testing where required • Required for refurbishment, change of use, or significant new loading |
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FBC’s Approach • Francis Bradshaw Consulting routinely carries out structural condition surveys and pre-acquisition inspections across retail, industrial, and housing stock. • Our reports are structured to feed directly into the Pre-Construction Information package, minimising duplication and programme delays. • We act as Principal Designer on projects where structural risk is the primary design coordination challenge. |
- Principal Designer Duties — Pre-Construction Phase
The Principal Designer is responsible for planning, managing, monitoring, and coordinating health and safety throughout the design and pre-construction phase. This is a design-led coordination role — not an administrative one.
- Identify and eliminate foreseeable design risk — before it reaches site
- Coordinate all designers: ensure no design discipline creates unmanaged risk for another
- Review and challenge design proposals that introduce unnecessary construction hazard
- Distribute pre-construction information to all relevant duty holders
- Prepare, develop, and hand over the Health & Safety File at project completion
- Liaise with the Principal Contractor on buildability, sequencing, and residual risk
The PD must have technical knowledge proportionate to the project — professional membership (IStructE, RIBA, ICE, CIAT) and relevant experience of similar project types are the practical benchmarks clients should apply.
- Project Roadmap — Who Does What and When
| Stage | Who | Key Actions |
| Inception (RIBA 0–1) | Client |
• Define brief, programme, and budget • Commission asbestos, ground, and utility surveys • Appoint Principal Designer in writing • Begin assembling Pre-Construction Information |
| Inception (RIBA 0–1) | Principal Designer |
• Accept appointment, confirm competence • Review available site information and identify gaps • Agree design coordination process with team |
| Concept Design (RIBA 2) | Client |
• Supplement PCI as survey results arrive • Submit F10 notification to HSE if notifiable • Confirm PD has received complete site information |
| Concept Design (RIBA 2) | Principal Designer |
• Commission or review structural inspection report • Identify key design risks across all disciplines • Coordinate design team — challenge unsafe proposals |
| Developed Design (RIBA 3) | Client |
• Appoint Principal Contractor (if known at this stage) • Confirm budget reflects CDM compliance costs |
| Developed Design (RIBA 3) | Principal Designer |
• Finalise design risk register • Begin H&S File structure • Liaise with PC on sequencing and temporary works |
| Technical Design (RIBA 4) | Client |
• Confirm PC appointment and verify CPP is received • Ensure welfare and site set-up is planned |
| Technical Design (RIBA 4) | Principal Designer |
• Contribute to and review Construction Phase Plan • Issue all design information to PC promptly • Manage H&S implications of any design changes |
| Construction (RIBA 5) | Client |
• Monitor CDM arrangements — observe, do not manage • Ensure design change process remains CDM-compliant |
| Construction (RIBA 5) | Principal Designer |
• Manage post-contract design changes • Update H&S File as construction progresses |
| Handover (RIBA 6) | Client |
• Receive and store the H&S File • Ensure it is accessible for future maintenance |
| Handover (RIBA 6) | Principal Designer |
• Finalise and formally hand over the H&S File • Confirm all residual risks are documented |
- What’s Changing in 2026
CDM 2015 itself is unchanged — but the regulatory environment around it is shifting significantly. Every client and designer should be aware of the following.
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Building Safety Regulator becomes independent — January 2026 The BSR transferred from the HSE to a new independent body on 27 January 2026. It now has its own statutory enforcement powers and is expected to take a more assertive approach — particularly for higher-risk buildings (18m+ or 7 storeys+). Expect more targeted engagement and scrutiny on Gateway 2 and 3 applications. Consultation on a single construction regulator — closes March 2026 The government has launched a consultation on merging regulation of buildings, construction products, and professionals into one body. If enacted, this would be the most significant reform to construction regulation since CDM 2015. Response due Summer 2026. Duty holder regime review — report due Autumn 2026 A formal review of how CDM duty holder roles are defined and assessed for competence is underway, alongside exploration of a licensing scheme for Principal Contractors on higher-risk buildings. Wales — new duty holder regime from 1 July 2026 The Building (Higher-Risk Buildings Procedures) (Wales) Regulations 2025 introduce a new gateway-style building control regime for Wales. A separate duty holder framework — closely mirroring England — also comes into force, including an additional Domestic Client role. |
- How Francis Bradshaw Consulting Can Help
We have provided structural and civil engineering services across retail, industrial, housing association, and local authority projects for nearly 50 years. Our CDM services include:
✓ Principal Designer appointments — from RIBA Stage 1 through to H&S File handover
✓ Structural condition surveys and pre-design asset inspections
✓ Pre-construction information review and gap analysis
✓ Asbestos survey coordination and structural hazard identification
✓ CDM compliance audits for clients managing ongoing construction programmes
✓ Awaab’s Law structural assessments for housing associations
✓ Retainer-based CDM support for local authorities and facilities managers
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Speak to one of our Engineers T: 01625 548551 | E: team@francisbradshaw.co.uk Suite 1F, Dean Row Court, Wilmslow, Cheshire SK9 2TA | www.francisbradshaw.co.uk |
This guide is for general information purposes and does not constitute legal advice. CDM duties depend on the specific circumstances of each project. For project-specific guidance, please contact a qualified professional.
Find out more by chatting with one of our Engineers on 01625 548551 or email team@francisbradshaw.co.uk
