CDM2015 one year on sees a variety of approaches to meeting the requirement for the Principal Designer to control the pre-construction stages.
In the vast majority of cases the appointment is made within the project team; lead designers, design and build contractors, project managers and sometimes clients, all of whom can demonstrate the required control.
Where this becomes more difficult is in instances where the members of the team cannot provide the role due to the absence of the necessary skills knowledge and experience (SKE) or suitable professional indemnity insurance. In some cases cost managers are offering the service, even though it is doubtful they can demonstrate the control required to meet the requirements of the regulations.
Often the principal designer role is taken on reluctantly by one of these parties, and CDM advisors are appointed to provide the necessary SKE.
One disadvantage to clients of CDM 2015 is the removal of the opportunity to tender openly for this ‘coordination’ role as an independent appointment.
Far from being a cost saving stated as a presumed outcome in the original consultation, we have now seen instances where designers have asked for exorbitant fees for principal designer services as they are effectively the only option available to the client.
It is evident to me that there are circumstances in which the interests of health and safety on a project are definitely best served by appointment of an independent principal designer.
Of course an independent principal designer should only be considered when this is the most suitable option in terms of health and safety, and should incorporate within the project arrangements means for exerting control should the necessity arise. These arrangements should be part of the overall Project Execution Plan and should show how direct instruction, usually from the client, can be put in place to demonstrate the required control.
The Q&A briefs on CITB include Health and Safety Executive (HSE) information. Question three asks: ‘Does the Principal Designer need to be a member of the project design team?’ with the HSE answer being an unequivocal ‘No’. The subsequent wording of the answer emphasises that the control of the pre-construction stages and the timing of the appointment are key.
Some construction based clients still prefer the independence offered by the CDMC under CDM 2007 and have implemented bespoke systems to allow that type of appointment. There is evidence of such systems having been reviewed without adverse comment by the HSE.
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A very good and interesting article. We have certainly seen an increase in demand for CDM Consultant / Principal Designer services on a contract and interim basis from our client base.
With respect to the perceived benefits of an ‘independent’ CDM Coordinator/PD, the industry has had 20 years of that and the impact has been described in every review of CDM as ‘inadequate’. I think it is time we left the independent argument and give the ‘authority’ argument a go.
Hello Mark, Trust you are well.
Having worked with Mark and many others who have a passion for good design risk management during the pre construction phase of a project, I perceive the issue is not so much wanting to retain the CDM Co-ordinator role, we have clearly moved on.
It is more about the fact that that many former CDM-C’s experienced late appointment and hence inadequate involvement to make the required contribution to the health and safety management within the early stages of projects. However, now even now when appointments take place in good time and all duty holders work well together, there is still a need for the one undertaking ‘co-ordination of H&S during design review’ to be within the project team – yes, but independent of the specific design activity. This is what Mark was seeking to highlight and clearly Paul Armstrong has noted in seeing an increase in demand for CDM Consultant / Principal Designer services on a contract and interim basis from their client base.
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Margaret Sackey
Institution of Civil Engineers (ICE)
ICE Health and Safety Panel
ICE Health and Safety Register