CIOB wants to know if CDM is working: here's what we'd tell them

On 9 April 2026, the Chartered Institute of Building launched a survey asking the construction industry how CDM 2015 is being interpreted, enforced, and trained on. The survey closes 30 April. They’re gathering views from designers, contractors, clients, and CDM advisers on whether the regulations are achieving what they were written to achieve.

We filled it in. Here’s what we’d say if we had more than a tick-box form.

The principal designer role still confuses everyone

CDM 2015 introduced the “principal designer” role, replacing the old CDM coordinator from the 2007 regulations. The idea was sound. Instead of a standalone CDM-C who acted as a safety consultant bolted onto the project team, the principal designer would be the lead designer, someone with actual design authority, who would manage health and safety risks during the design process.

In practice, the role landed badly on most projects.

On a typical commercial or infrastructure project, the architect or consulting engineer is appointed as principal designer. They accept the role, because the client’s project manager tells them it’s a contractual requirement, and they add a fee line to their appointment. What happens next varies enormously.

On well-run projects with experienced design teams, the principal designer coordinates design risk reviews, maintains a hazard register, and ensures that the construction phase plan reflects decisions made during design. The pre-construction information pack reaches the principal contractor in time to be useful. Design changes during construction get assessed for safety impact before they reach site.

On the majority of projects we work on, none of that happens. The principal designer produces a design risk register at the start of the project, files it, and doesn’t update it. Pre-construction information arrives as a PDF dump two days before the contractor mobilises. Nobody reviews design changes for safety impact in any structured way. The principal designer role exists on paper, in the F10 notification, and nowhere else.

The problem is that CDM 2015 placed the principal designer duties on a role defined by design leadership, but most designers don’t see health and safety coordination as part of their core competence. They were trained in structural analysis, or architectural design, or highway geometry. They were not trained in construction methodology, temporary works, or the specific risks that arise from the sequence in which things get built. So they default to a compliance exercise: produce the documents, tick the boxes, move on.

The client duties get ignored on smaller projects

CDM 2015 applies to all construction work, from a kitchen extension to Hinkley Point C. Every project has a client with duties under the regulations. The client must make suitable arrangements for managing the project, ensure that pre-construction information is provided, and appoint a principal designer and principal contractor if the project involves more than one contractor.

On projects above £5-10 million, these duties are usually discharged properly. The client has a project manager, a safety adviser, and the resources to run a compliant procurement process. On projects below £500,000, which is the overwhelming majority of UK construction projects by volume, the client duties are frequently invisible.

A developer commissioning a warehouse fit-out, or a landowner building an agricultural barn, or a small business extending their premises does not know they have duties under CDM. Their architect might mention it in passing. Their quantity surveyor might include a line in the cost plan for “CDM adviser.” Nobody explains what the duties actually require or what happens if they’re not discharged.

The result is that the principal contractor (usually the main building contractor) ends up carrying the client’s CDM duties by default, plus their own, plus the practical safety management of the site. They do this without additional fee, without the authority that comes from being the client, and without the pre-construction information that the client was supposed to provide.

This is not a training problem. It’s a structural problem. CDM 2015 assumed that all clients would engage with the regulations. Commercial and domestic clients on smaller projects have no incentive to engage and face minimal enforcement risk if they don’t.

Enforcement is thin and getting thinner

The HSE is the enforcing authority for CDM on most construction sites. Local authorities enforce on some smaller domestic projects, though in practice they rarely do.

HSE construction inspector numbers have declined steadily. The number of proactive site inspections has fallen. When inspectors do visit sites, their focus is understandably on the highest-risk activities: working at height, excavation collapse, crane operations, and demolition. CDM compliance (whether the right duty holders are appointed, whether the construction phase plan is adequate, whether the pre-construction information was provided) is a secondary concern during a site visit focused on preventing someone from dying today.

The consequence is that CDM non-compliance carries almost no enforcement risk on projects that aren’t already on the HSE’s radar. A client who fails to appoint a principal designer on a £200,000 project is unlikely to be inspected, unlikely to be noticed, and unlikely to face any regulatory consequence unless someone is seriously injured.

We’re not arguing for more inspections. HSE inspectors do vital work with limited resources, and we’d rather they focus on preventing fatalities than auditing paperwork. But the gap between the regulations’ ambition (universal compliance, active client engagement, integrated design-stage risk management) and the enforcement reality (sporadic inspections focused on acute hazards) is wide enough to drive an excavator through.

What actually works on site

CDM 2015 gets some things right. The construction phase plan requirement, when taken seriously, forces the principal contractor to think through the sequence of work, identify the high-risk activities, and document the control measures before work starts. A good construction phase plan is a working document that the site team refers to. A bad one is a 40-page generic template downloaded from the internet and filed in the site office.

The requirement for pre-construction information pushes clients and designers to share what they know about the site: ground conditions, existing services, asbestos surveys, contamination data. When this information reaches the contractor in time, it prevents surprises. When it arrives late or incomplete, which happens on at least half the projects we price, the contractor carries risks they didn’t price for and couldn’t foresee.

The duty holder structure (client, principal designer, principal contractor, designers, contractors) makes logical sense. Everyone who can influence safety has a defined role with specific duties. The problem is not the structure. The problem is that three of the five duty holders (clients, principal designers, and designers) frequently treat their duties as administrative obligations rather than active safety functions.

What the review should address

If the CIOB’s review leads to recommendations for the HSE and policymakers, here are four changes that would make a practical difference on the projects we run:

1. Separate the principal designer competence from the lead designer appointment. Not every lead designer has the construction methodology knowledge to manage design-stage safety risks effectively. Allow the principal designer to be a specialist role (similar to the old CDM-C) where the lead designer lacks competence, without losing the principle that design-stage risk management should be integrated into the design process. The current regulations technically allow this, but the guidance pushes strongly toward the lead designer holding the role.

2. Create a proportionate compliance framework for smaller projects. A £150,000 warehouse extension does not need the same CDM apparatus as a £50 million infrastructure project. A simplified duty structure for lower-risk projects below a defined threshold, with clearer guidance on what “suitable arrangements” actually means for a small commercial client, would improve compliance far more than the current one-size approach.

3. Align CDM with the Building Safety Act. The Building Safety Act 2022 introduced the Building Safety Regulator (currently within HSE, moving to the housing department). The Act creates new competence requirements for designers, contractors, and building control bodies that overlap with, but don’t exactly match, CDM duty holder requirements. Two parallel regulatory regimes covering similar ground with different terminology and different enforcing authorities is a recipe for confusion. The CIOB review should push for alignment.

4. Publish enforcement data by project type and value. CDM compliance rates almost certainly vary by project size, sector, and region. If the HSE published anonymised enforcement data showing where compliance is weakest, the industry could target training and guidance resources at the gap. Right now, everyone assumes compliance is a problem “on other people’s projects.”

Fill in the survey

The CIOB survey closes 30 April 2026. It takes about 15 minutes. If you’re a contractor, designer, client, or CDM professional, your input shapes whether the review produces recommendations that reflect site reality or just recycles the same guidance documents in a new format.

CDM 2015 replaced CDM 2007, which replaced CDM 1994. Every version improved on the last. This review is the mechanism for the next improvement. It works better if the people who actually build things tell the reviewers what they see.

Eddie Lyons is construction director at Rospower Projects. We deliver earthworks, groundworks, and civil engineering packages across the UK, with health and safety management integrated into every project from pre-start to handover. Get in touch if you’re planning a project.