23rd May, 2018

Does CDM Apply To Painting And Decorating?

Painters and decorators are often familiar with CDM from working on larger construction projects, perhaps under a principal contractor. But what about smaller projects, like painting a hallway or a room in someone's house? How does CDM apply to painting and decorating work?

Does CDM Apply To Painting And Decorating? header image

Painters and decorators are often familiar with CDM from working on larger construction projects, perhaps under a principal contractor. But what about smaller projects, like painting a hallway or a room in someone's house?

Does CDM apply when you are working in occupied buildings or someones home? Let's take a look.

CDM stands for the Construction (Design & Management) Regulations. As the name suggests, CDM applies to construction work. In fact, CDM is a set of health and safety regulations that apply specifically to construction projects.

What CDM says about painting and decorating.

It's not unusual for painters to think that if they are working on their own, in a customers house, that no construction work is being carried out. But actually, it is.

The CDM regulations set out information for what is classed as construction work.

2. Interpretation.

construction work means the carrying out of any building, civil engineering or engineering construction work and includes—

(a) the construction, alteration, conversion, fitting out, commissioning, renovation, repair, upkeep, redecoration or other maintenance (including cleaning which involves the use of water or an abrasive at high pressure, or the use of corrosive or toxic substances), de-commissioning, demolition or dismantling of a structure;

The Construction (Design and Management) Regulations 2015

As you can see, redecoration comes within the definition of construction work.

What does this mean? It means even if no other contractors or construction work is involved in your project, as a painter and decorator, you need to be aware of CDM.

When a principal contractor is required.

Any, and every, construction project with more than one contractor needs to have a principal contractor.

If you are working as a painter and decorator for a client, and no other contractors are involved in the project, and you won't be appointing any subcontractors, then a principal contractor is not needed.

If there are any other contractors or subcontractors involved, then you must have a principal contractor.

The principal contractor will have overall control of the project and has some extra responsibilities, such as preparing the construction phase plan, organising the works and managing health and safety on site.

If you are the only contractor, you must prepare the construction phase plan and are responsible for health and safety on site.

Working on domestic projects.

What about domestic projects, working in someone's house, are you not exempt from CDM?


Domestic clients have their client duties transferred to other members of the project team, that could be you. And on top of this, as a contractor, you still have the same CDM duties as any other project.

In fact, on a domestic project with multiple contractors, the principal contractor can be appointed automatically.

How to comply with CDM.

Ok, so now we know that CDM will apply to your projects, how do you comply with it as a painter and decorator?

First of all, you will be glad to know that CDM is proportional. You are not expected to have the same procedures in place as say, a big demolition project. If you have good health and safety systems in place, you are probably well on your way to complying with CDM.

But, there are a few extra duties you should be aware of, whether you are a principal contractor or a contractor.

The good news is, we have some free CDM guides to help you.

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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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