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3rd October, 2019

CDM Guide For Developers And Housebuilders

CDM should be straightforward. But when it comes to knowing how the regulations apply to you, it can be confusing if you don't fit the client > architect > builder mould. And not every project does. What about if you are the client and the builder. You're developing your own plot, or doing up a house to sell? You're bringing in contractors but managing the project yourself?

The Construction (Design & Management) Regulations (often referred to as CDM) apply to every construction project in Great Britain. No matter how small or big. How short or long. Every project.

For developers, CDM can seem like a lot to handle. Often you might be taking on more than one CDM duty holder role. You might even be taking on them all! That's a lot of duties. But since each duty holder needs to share information, being the same person or business can make cooperating and coordinating a simple job. After all, you're communicating with yourself.

Let's take a look at how CDM applies to developers and housebuilders.

You're the client

The first thing you should know about CDM if you're a developer is, chances are, you're the client.

Every project has a client. The client is the person holding the purse strings. The person who the project is carried out for. If you are a developer, and you have purchased some land or a building to develop, the project is being carried out for you. You are the client.

“client” means any person for whom a project is carried out;

The Construction (Design and Management) Regulations 2015 Interpretation

Sometimes there can be confusion surrounding CDM domestic clients. Domestic clients have fewer duties under CDM, but if you are a developer you won't be classed as a domestic client. Even if you are building residential or domestic properties. Unless it's your own home, that you live in and don't plan to sell or rent, you're not a domestic client.

What does being the client mean? It means you need to complete the CDM duties of the client. This includes things like:

  • Allowing adequate time and resources
  • Preparing the client brief
  • Notifying the HSE
  • Appointments
  • Completion and handover arrangements

Get a free step-by-step guide on CDM client duties.

Some of the client duties might even be a little easier for developers. For example, appointing the principal designer and principal contractor is fairly straightforward when you are appointing yourself! And communicating and sharing information with yourself is also a simple process. Bonus!

cdm dutyholders
Developers can take on more than one CDM role

You might be the principal designer

We say you might be because this isn't necessarily the case. Sometimes as a developer, you may take on this role yourself. Either because you don't appoint an outside architect, e.g. a straightforward refurbishment where you handle the specification and design yourself. Or your design team is in-house.

A principal designer is required on any construction project with more than one contractor (including subcontractors). That's not more than one contractor on-site at the same time, that's more than one contractor throughout the whole project.

contractor
Most projects need a principal designer appointed

Most projects use more than one contractor. Groundworkers, scaffolders, electricians, plumbers and other specialists. So most projects need a principal designer appointed. If you're not appointing someone else, then you are the principal designer.

With this comes, you guessed it, more duties under CDM. Duties like:

  • Coordinate the pre-construction phase
  • Preparing the pre-construction information
  • Identify, eliminate and control foreseeable risks
  • Ensure designers comply
  • Prepare the health and safety file

Get a free step-by-step guide on CDM principal designer duties.

Again, as a principal designer, getting information from the client is much easier when you are the client.

You're the principal contractor

What, another CDM role? Yep, that's right. As a developer, you're probably going to be the principal contractor. Maybe you're doing most of the work yourself. Or maybe you're managing other contractors. Either way, if you're taking charge of things and running the show on the site, you're the principal contractor.

Like the principal designer role, a principal contractor is required on any project with more than one contractor. As a developer, you might bring in other trades as and when you need them. Or you might have contractors in from day one.

The principal contractor is the person or business in overall control of the construction phase. You're responsible for things like:

  • Preparing the construction phase plan
  • Organising contractors work
  • Providing welfare facilities
  • Managing the construction phase
  • Providing inductions and site security
  • Providing information for the health and safety file

Get a free step-by-step guide on CDM principal contractor duties.

A principal contractor is the organisation or person that coordinates the work of the construction phase of a project involving more than one contractor, so it is carried out in a way that secures health and safety. They are appointed by the client and must possess the skills, knowledge, and experience, and (if an organisation) the organisational capability to carry out their role effectively given the scale and complexity of the project and the nature of the health and safety risks involved.

refurbishment room
CDM applies to all construction projects

You might be a designer

In addition to the fact you might be the principal designer, you also might be a designer. If you are the principal designer, then you almost certainly will also have designer duties.

Every designer in a construction project has designer duties under CDM, including:

  • Identifying, eliminating and controlling foreseeable risks
  • Providing design information
  • Cooperating with other duty holders

Get a free step-by-step guide on CDM designer duties.

You're a contractor

If you're the principal contractor, you also have contractor duties. If you carry out construction work, you also have contractor duties. If you're a developer or a housebuilder, you are also a contractor under CDM.

And just like designers, all contractors have CDM duties. These contractor duties include:

  • Cooperating with other duty holders
  • Complying with the construction phase plan
  • Providing management and supervision
  • Providing information for the health and safety file

Get a free step-by-step guide on CDM contractor duties.


It might seem like a lot to cover, but you should find some overlap between each role. Use the free CDM checklist to help cover your CDM requirements. Being involved in all areas of your project can mean you can make a real difference in creating a safe construction site. Use our free step-by-step CDM duty holder guides for your projects.

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This article was written by Emma at HASpod. Emma has over 10 years experience in health and safety and BSc (Hons) Construction Management. She is NEBOSH qualified and Tech IOSH.

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