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19th February, 2016

Key changes in the CDM 2015 regulations

So by now, the new CDM Regulations (2015) have been in force in the UK for nearly a year, but there are still some key changes to the CDM Regulations that we are often asked about.

While the changes under CDM 2015 may not seem massive at first glance, there have been changes to the project team, required duty holders, appointment of duty holders, duties and notification.

Here are some of the key changes to the CDM regulations under CDM 2015 you and your team should know about to make sure your construction project complies.

The CDM project team.

CDM has always required certain duty holders to be appointed and carry out responsibilities and duties. CDM 2015 introduced a change to this project team.

CDM 2007

  • Client
  • CDM Coordinator (-)
  • Principal Contractor
  • Contractors
  • Designers

CDM 2015

  • Client
  • Principal Designer (+)
  • Principal Contractor
  • Contractors
  • Designers

The removal of the CDM Coordinator.

The CDM Coordinator role existed under CDM 2007, but was removed under CDM 2015.

A new role of Principal Designer has been introduced instead, with Clients and Principal Designers having additional duties, some of which used to be completed by the CDM Coordinator.

The introduction of the Principal Designer.

CDM 2015 defines the principal designer as the designer with control over the pre-construction phase of the project.

So, to meet this definition, the Principal Designer must be a designer, and also be appointed, and in control of the pre-construction phase of the project. The Principal Designer will have overall responsibility for CDM compliance during the pre-construction phase.

More information on the Principal Designer duties here: CDM 2015 principal designer duties explained

The appointment of the Principal Contractor and Principal Designer.

Under CDM 2007, the appointment of the Principal Contractor and former CDM Coordinator only needed to be made on Notifiable Projects.

Now the appointment of the Principal Contractor and Principal Designer roles needs to be made on any project with more than one contractor (including subcontractors), so most projects even small works will now require these roles.

The notification thresholds.

So the change here is so subtle on paper you may not even notice it, going from "CDM 2007: Notification required for projects lasting over 30 days or 500 person days", to "CDM 2015: Notification required for projects lasting over 30 days with 20 or more workers or 500 person days".

So before if you were over 30 days you knew you were notifiable. Now, this threshold only counts if you have 20 or more workers. This makes the 500 person days much more important but is also harder to work out. You can use our notification calculator if you need help.

The impact of notifications.

Under CDM 2007, if your project was notifiable this triggered additional 'notifiable project duties'. Under CDM 2015, the presence of more than one contractor triggers the need for additional appointments, and duties apply to all projects regardless of if they are notifiable or not.

The need for CDM documentation.

Under CDM 2007, key CDM documents such as the Pre-Construction Information, Construction Phase Plan and Health and Safety File were only required on notifiable projects.

The requirement for these documents now applies to all projects and you should certainly see the Pre-Construction Information and Construction Phase Plan on every construction project, and the Health and Safety File on any project with a Principal Designer.

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