12th May, 2020

Does CDM Apply To Refurbishment?

One of the questions we often get asked regarding CDM 2015 is, does CDM apply to refurbishment projects? The answer is yes. It may surprise you to know that the refurbishment project doesn’t even have to involve any structural changes for CDM to apply.

Does CDM Apply To Refurbishment? header image

One of the questions we often get asked regarding CDM 2015 is, does CDM apply to refurbishment projects? And the simple answer is, yes. The CDM regulations apply to all construction projects, including refurbishment projects. If you are planning work on a refurbishment project, everyone on the team needs to know about CDM and carry out their duties, it's a legal requirement.

But what if the refurbishment project is really small, just lasting a week for example? Does CDM apply then? Yes, it does. And what if only one person is working on the project, will CDM still apply then? Yes. What if the refurbishment project is being done on someone's house? Does CDM still apply? Yes, it does.

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 latest version of the regulations came out in 2015, and so are often abbreviated to CDM 2015. 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.

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

  1. 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 Interpretation

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 to your project.

And from a CDM point of view, refurbishment projects are not treated any differently to any other type of project. There are just as many health and safety risks involved with refurbishment work as there are in other types of work. Perhaps even more, since you could be dealing with many unknowns regarding the existing structure, materials and services.

room for refurbishment
CDM applies to all refurbishment projects

Just like any construction project, the team will need to work together to carry out the work safely and without risk to health. Everyone involved in the project must be familiar with the hazards involved in refurbishment work so that they can navigate the risks and comply with CDM.

Every designer working on the refurbishment project will have designer duties under CDM. And every contractor working on the refurbishment project will have contractor duties.

And clients have CDM duties too. The client will need to select one contractor as the principal contractor (if there is more than one contractor). The principal contractor will have overall control of the site, health and safety, and be responsible for producing the construction phase plan. If there is only one contractor, they will have those responsibilities.

Find out more about the principal contractor role and duties in our free CDM duty holder guide for principal contractors.

Where the client has appointed a principal contractor, they will also need to appoint a principal designer. The principal designer will assist the client with the client duties, help with the development of the pre-construction information at the start of the project, and produce the health and safety file for project completion.

Find out more about the principal designer role and duties in our free CDM duty holder guide for principal designers.

cdm dutyholders
All CDM duties apply

There are only a couple of ways that how CDM applies to your project may differ.

If the client is a domestic client, as in, the client is someone having work done on their own home and not connected with any business, then some of the client duties pass to other members of the project team. And some of the appointments, like the principal contractor and principal designer, can happen automatically.

Need help understanding how CDM applies to domestic projects? Read CDM 2015 Domestic Clients And Work On Residential Projects to find out more.

On short projects, with few people involved, the project may not be notifiable. If the project is below the notification threshold, then you will not need to notify the HSE. But that doesn't change any of the other CDM requirements. CDM still applies, and all the other duties must be discharged.

Want to calculate if your project is CDM notifiable? Use the free CDM notification calculator to check today.

Remember, the CDM regulations apply to all construction work, in all settings. And this includes refurbishment projects. CDM prosecutions aren't rare, so before you start refurbishment work, make sure you are aware of your duties under CDM and comply with them.


If you need help complying with CDM duties, get our free CDM duty holder guides for more support. And check if your project is CDM ready with the CDM compliance checklist.

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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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