If you are commissioning a fit-out, an extension or any construction work in the UK, the Construction (Design and Management) Regulations 2015 — CDM 2015 — apply to your project. Not just to big sites with cranes: CDM 2015 applies to all construction work, including a two-week shop refit. What changes with project size is who must be appointed and what must be written down.
Here is who does what, in plain English.
The client: more duties than most people expect
Under CDM 2015 the client is not a passive buyer. A commercial client must make suitable arrangements for managing the project, allow adequate time and resources, and ensure the right people are appointed. Two appointments matter most:
- A principal designer, where more than one contractor will be involved (on almost any real fit-out, they will be). The principal designer plans, manages and monitors health and safety in the pre-construction phase.
- A principal contractor, for the construction phase — the party who plans, manages and monitors the work on site.
If the client fails to make these appointments in writing, the client carries those duties themselves. That is the trap many commercial tenants fall into: no appointment letter means the dutyholder is you.
When does the HSE need to know? The F10 notification
A project must be notified to the Health and Safety Executive on an F10 form if the construction work is expected to either:
- last longer than 30 working days and have more than 20 workers working simultaneously at any point, or
- exceed 500 person-days of construction work.
Notification is the client’s duty (in practice usually handled by the principal designer or principal contractor on the client’s behalf). Note that notification is a separate question from whether CDM applies — the regulations apply to every project, notifiable or not.
The documents that prove the project is run properly
Three documents form the backbone of CDM compliance:
- Pre-construction information (PCI) — the client (through the principal designer) gives designers and contractors the information they need about the site and existing structure: asbestos surveys, structural information, services, known hazards.
- Construction phase plan (CPP) — required for every project, even small ones. The principal contractor (or the contractor, on single-contractor jobs) must draw it up before the site is set up, describing how the work will be managed safely.
- Health and safety file — prepared during the project and handed to the client at completion, recording the information a future owner or contractor will need to work on the building safely. On a fit-out, this is part of a proper handover package alongside O&M manuals.
Method statements and risk assessments (often bundled as RAMS) sit underneath the CPP: they are how each contractor demonstrates that their specific tasks have been thought through.
What this looks like on a real London fit-out
On a typical café or retail fit-out with several trades, a sensible arrangement is: the client appoints the design lead as principal designer and the fit-out contractor as principal contractor, both in writing, before work starts. The principal contractor produces the construction phase plan and site rules, inducts every worker, keeps inspection records, and builds the health and safety file as the job progresses — so handover paperwork is assembled during the project, not reverse-engineered after it.
Run this way, CDM 2015 is not bureaucracy. It is simply the paper trail of a well-managed site — and it is also what protects the client if something goes wrong.
Quick checklist for clients
- Appoint a principal designer and principal contractor in writing before work starts.
- Ask for the construction phase plan before the site is mobilised.
- Provide pre-construction information — especially the asbestos survey in older buildings.
- Check whether the project is notifiable (F10) and who is submitting it.
- Make sure a health and safety file is part of the handover.
If any of those items is missing on your current project, that is worth a conversation this week, not at handover.
