CDM2015 Client Observations

Previously the CDM coordinator acted as the ‘key project advisor’ to the Client in respect of construction health and safety, however under CDM2015, several of the previous functions of the CDM coordinator are now to be carried out by the Client directly, and the wording for these duties is more onerous. Clients that need help with their duties are advised in the HSE Guidance Document to seek competent specialist advice.

If Clients need help in making these arrangements, they could draw on the competent advice they are required to have under The Management of Health and Safety at Work Regulations 1999 (MHSWR99), Regulation 7. Although not required by CDM2015, many clients are appointing a ‘Client Advisor’ to advise them on their client duties under the Regulations.



CDM2015 reinforces the impact Clients can have on a project. Regulations 4 and 5 set out the Client’s duty to make suitable arrangements for managing a project and maintaining and reviewing them for its duration so that it is carried out in a way that manages the health and safety risks involved.

Under CDM2015, the client is exposed to a greater burden of having to check and review health and safety arrangements throughout the life of a project. Put simply, a Client can no longer appoint a CDM Co-ordinator (as it was under CDM2007) and a Principal Contractor, and assume they are performing their duties adequately.

CDM2015 places absolute obligations on the Client to:

  • Take reasonable steps to ensure that the Principal Designer and Principal Contractor comply with their relevant duties (reg 4(6));
  • Appoint (where there is more than one contractor) a Principal Designer and a Principal Contractor in writing. The appointments must be made as soon as is practicable, and in any event, before the construction phase begins (reg 5);

If the Client fails to appoint a Principal Designer, the Client must fulfil the duties of the Principal Designer in regulations 11 and 12. If the Client fails to appoint a Principal Contractor, the Client must fulfil the duties of the Principal Contractor in regulations 12 to 14.

  • Ensure a Construction Phase Plan (CPP) is drawn up before the construction phase begins (reg 4(5)(a)); and

Ensure the Principal Designer (where there is more than one contractor) prepares the health and safety file for the project (reg 4(5)(b)).

If you need competent CDM Advice contact Safety for Design here Contact Us

For your free copy of the L153 Construction (Design and Management) Regulations 2015 visit Here

We have used Safety for Design for all our site audits over the past 5 years and they have also carried out the Principal Designer role on numerous projects for us, as well as providing advice and support to ensure we are fully complying with the CDM Regulations 2015 on all our sites throughout the UK they also provide us with assistance to ensure all our documentation complies with current legislation and general advice to assist us in adequately managing the risks within our business

Scott Wilson - Director, IBO Construction

North Staffs Pipe have been pleased to be associated with Safety For Design for many years. Their support and professional guidance has been invaluable to the business. We would recommend to any company looking for support to get them on board. We look forward to continued association in the future.

Katie Parrish - Director, North Staffs Pipe Services Limited

Safety for Design have provided clear and pragmatic guidance to our client, design team and contractors. They have guided us through the CDM 2015 Regulations to ensure our projects achieve the best possible practice compliance.

Ryan Riches - Director, Artal

Over the past 4 and a half years, SFD have provided myself and my colleagues with an invaluable source of health and safety expertise and guidance. They have provided both the function of CDM consultants and principle designer, ensuring our team upholds the same level of safety conscientiousness, as within their own team. They are refreshing to work with, providing on tap support.

Webber Forbes - Site Transition Project Manager, Thales Group

Safety for Design have been worked closely with St Modwen for the past 10 years and have been instrumental in helping bring health & safety matters to the forefront of our agenda. Their competence, dedication, input and guidance has helped forge new initiatives and systems that ensure all Duty Holder obligations under the CDM 2015 Regulations are met

Richard Carter - Senior Director Construction, St Modwen Industrial & Logistics

“The Inglis Consortium LLP have worked with SFD from 2014 and they have become an integral part of the team delivering the infrastructure for 2240 residential units at Millbrook Park, Mill Hill. Their knowledge, commitment and pragmatism have led to a very safe multi developer site.”

Keith Hurford - Director, Millbrook Park

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