One of the questions we often get asked regarding CDM 2015 is, does CDM apply to refurbishment projects?
The short answer is yes.
The long answer is also yes.
It may surprise you to know that the refurbishment project doesn’t even have to involve any structural changes for CDM to apply.
All the time, in every circumstance, CDM will apply to any refurbishment project, big or small, domestic or commercial.
CDM stands for the Construction (Design and Management) Regulations, and as the name suggests, they apply to all construction work.
The Regulations also (helpfully) define what is classed as construction work.
Let’s take a look at the first part of the definition of construction work under CDM 2015.
(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;
Any type of upkeep, repair, redecoration or maintenance to a structure is included.
A structure covers any building, and any other structure from a harbour to a tramway line, and includes river works, earthworks and pipes.
So, whatever you are refurbishing, CDM applies.
If the project is below the notification threshold, then you will not need to notify the HSE, but CDM still applies, and all the other duties must be discharged.
This includes appointing the Principal Designer and Principal Contractor roles on projects with more than one contractor.
This also includes ensuring the Pre-Construction Information, Construction Phase Plan and other CDM documentation is developed.