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The Construction (Design and Management) Regulations 2015 (CDM 2015) make the role of CDM co-ordinator obsolete and introduce the principal designer (PD).
The associated, draft guidance (L153) offers no scenarios describing who might be PD under different procurement models nor the skills, knowledge, experience and organisational capability that they require. This ambiguous vacuum is being filled with speculation.
It is helpful to review what we definitely know. A PD must be appointed by the client if there is, or is likely to be, more than one contractor on a project. We appoint a decorator to spruce up a room (redecoration = construction so CDM applies) and they sub-contract work to an electrician: that is two contractors so someone needs to be PD.
Regulation 2 of CDM 2015 explains that the PD is the designer appointed to fulfil certain other Regulations (discussed later). So, who’s a designer? This is a person (an individual or organisation) who prepares or modifies drawings, specifications etc. (i.e. designs) relating to a structure. They can also be a person who arranges for or instructs any person under their control to prepare or modify a design, which is much broader in scope.
What does a PD do? Fundamentally, they “plan, manage and monitor the pre-construction phase and co-ordinate matters relating to health and safety during the pre-construction phase” (Regulation 11). L153 offers additional insights into HSE’s thinking. PD have “control over the pre-construction phase of the project”, essentially the design stage, and have the “technical knowledge of the construction industry relevant to the project” and “the understanding and skills to manage and co-ordinate the pre-construction phase.”
Two distinct functions are emerging: the PD controls the design process and they co-ordinate health and safety matters relating to design. The PD appears to be envisaged as a design-based role.
Let’s return to the subject of who is a designer and, by extension, who can be a PD.
With this in mind, I have developed ten questions for a prospective PD.
Do you have the technical knowledge, skills and understanding regarding the;
Because they already plan, manage and monitor (i.e. control) the design phase, lead designers (e.g. architects, engineers and surveyors) should be PD but may not have all these qualities. CDM co-ordinators who are not designers (myself included) lack the technical skills to control design work.
Perhaps one solution is PD = lead designer + ex-CDM-C support?
Until the HSE put their heads above the parapets, speculation will continue.