Client Duties under CDM 2015

TL;DR

As the client, you bear ultimate responsibility for ensuring suitable health and safety arrangements are in place throughout your construction project. Your duties include making the right appointments early, ensuring the project does not start without a Construction Phase Plan, and receiving the health and safety file at completion.

Who is a Client under CDM 2015?

A client is any organisation or individual for whom a construction project is carried out. This includes:

• Property developers and housing associations
• Local authorities and public bodies
• Businesses commissioning office fit-outs or factory upgrades
• Landlords and building owners commissioning maintenance or refurbishment
• Individuals commissioning work on commercial property

Domestic clients — homeowners commissioning work on their own home — have reduced duties and can pass most responsibilities to the principal contractor or principal designer.

Core Client Duties

Make the Right Appointments

Clients are responsible for appointing a principal designer and principal contractor on projects involving more than one contractor. These appointments must be:

• Made in writing
• Made as early as possible — the principal designer should be appointed at the design stage
• Given to competent, adequately resourced organisations

If a client does not make these appointments, their duties automatically pass to the principal designer (for design stage) and principal contractor (for construction stage).

Allow Sufficient Time and Resources

Clients must ensure that:

• Adequate time is allocated for design and planning before construction starts
• Contractors are given enough time to plan and carry out their work safely
• Budgets reflect the true cost of safe working

Rushing a programme is one of the most common causes of safety shortcuts on construction sites. The client has a direct responsibility to ensure this does not happen.

Provide Pre-Construction Information

Clients must gather and pass on all relevant information about the site and structure to the principal designer for inclusion in the pre-construction information pack. This includes:

• Existing surveys and drawings
• Known hazards (asbestos, contamination, underground services)
• Access and logistics constraints
• Any requirements for future maintenance

Ensure the Construction Phase Plan Exists

Clients must not allow the construction phase to begin unless the principal contractor has prepared a suitable Construction Phase Plan. The client does not write the CPP, but they must be satisfied that one is in place.

Maintain Welfare Arrangements

Clients must ensure suitable welfare facilities are available throughout the project. In practice, the principal contractor manages this day-to-day, but the client must ensure arrangements are in place and adequate.

Receive the Health and Safety File

At project completion, the client receives the health and safety file from the principal designer. The file contains information needed for future maintenance, alteration or demolition. Clients must keep this file and make it available to anyone who needs it.

Notifiable Projects

On notifiable projects, the client must notify the HSE using the F10 form before construction starts. The F10 must be displayed on site throughout the construction phase.

Projects are notifiable if construction will:

• Last longer than 30 working days with more than 20 workers working simultaneously, OR
• Exceed 500 person-days of work

Domestic Client Rules

Domestic clients — homeowners commissioning work on their own home — have significantly reduced CDM duties. They can pass their responsibilities to:

• The principal designer (for projects with multiple contractors)
• The principal contractor (if no principal designer is appointed)
• The contractor (on single-contractor projects)

This should be agreed and documented in writing at the start of the project.

Evidence Clients Should Keep

How Workforce Guardian Supports Clients

Workforce Guardian gives clients real-time visibility of project compliance without requiring them to manage it day-to-day:

• Project dashboard — see CPP status, induction completion rates and incident summaries
• Document repository — store F10s, appointments and the health and safety file in one place
• Evidence pack — generate a complete compliance pack for audit, handover or insurance purposes

FAQs

What happens if I do not appoint a principal designer?

If no principal designer is appointed, the client automatically takes on those duties. On complex projects this creates significant risk. The HSE may hold the client liable for failures in pre-construction health and safety coordination.

Can I transfer my CDM duties to someone else?

Commercial clients cannot fully transfer their CDM duties. You can delegate day-to-day management, but you remain ultimately responsible for ensuring suitable arrangements are in place. Domestic clients can pass most duties to the principal contractor.

Do I need to appoint a principal designer on a simple refurbishment?

If there is only one contractor and no design work involved, a principal designer is not required. However, on most commercial refurbishments there will be a designer involved, which triggers the requirement for a principal designer appointment.

Is the client responsible if a worker is injured on site?

The client may be held partially responsible if they failed to make proper appointments, did not allow enough time or budget, or did not ensure a CPP was in place before construction started. The principal contractor bears the primary operational safety responsibility.

How long must I keep the health and safety file?

The health and safety file must be kept for the life of the structure. It should be updated whenever alterations are made to the building and passed on to any new owner or occupier.