CDM 2015 has been in force for over a decade. Most construction directors sat through a briefing when the regulations came in, applied what they needed at the time, and got on with running their businesses. The detail, for many, has quietly faded since.
That is not unusual. It is what happens when you are managing projects, people and commercial pressure simultaneously. The problem is that CDM duties do not fade alongside the knowledge. They sit there, live, attached to every notifiable project the business touches — regardless of how clearly the director running that business could articulate them today.
Most directors of growing construction businesses will, if asked directly, acknowledge some uncertainty about exactly where they stand. Not because they are indifferent to it. Because they are running businesses, and the framework has not needed to be tested closely enough, often enough, to stay sharp.
What CDM 2015 actually requires of you as a director
CDM 2015 replaced CDM 2007 and brought some significant shifts that still catch people out. The most important: it removed the old CDM Co-ordinator role and replaced it with the Principal Designer.
The five CDM 2015 duty holders
- Client — the organisation or individual having the construction work carried out. Carries more duties than most clients realise, and cannot simply delegate them away.
- Principal Designer — appointed on projects with more than one contractor. Manages health and safety in the pre-construction phase. Must be competent — not just available.
- Principal Contractor — manages H&S during the construction phase. Plans, manages, monitors and coordinates.
- Designer — anyone who prepares or modifies designs for construction work, including temporary works designs.
- Contractor — any individual or business that carries out, manages or controls construction work on site.
Where directors most often get unstuck is in understanding what the Client duty means in practice. Many assume that once a Principal Contractor is appointed, CDM responsibilities have largely been handed over. They haven’t. The Client retains duties throughout.
The things that actually catch businesses out
Working with construction businesses across London, Surrey and the South East, there are a handful of areas where CDM knowledge tends to have the biggest gaps.
Where CDM knowledge gaps tend to sit
- Not knowing when a project becomes notifiable to the HSE
- Informal Principal Designer appointments, or appointing someone without the competence the role genuinely requires
- Construction Phase Plans that exist on paper but bear no relation to how work is actually managed on site
- Pre-Construction Information not being properly gathered, or not being passed down the supply chain
- Duty holder responsibilities not being properly understood by the people actually holding those roles
- Domestic client situations being mishandled
- Subcontractor appointment without proper competence checking
“The Construction Phase Plan existed. It was on the server. Nobody on site had read it in six weeks, and it hadn’t been updated since the project programme changed. That’s not just a CDM compliance problem. It’s a management problem that CDM compliance is supposed to prevent.”
When did you last actually look at this?
CDM 2015 has been in force since April 2015. If you sat through a briefing when the regulations came in and haven’t revisited them in any structured way since, that’s over a decade of accumulated project experience sitting on top of knowledge that may have quietly drifted.
A note on the Building Safety Act 2022. If any of your work involves higher-risk buildings — broadly, residential buildings over 18m or seven storeys — the Building Safety Act has introduced additional obligations that sit alongside and connect with CDM duties.
What a proper refresher actually looks like
A CDM refresher for directors and senior teams isn’t about sitting in a room being talked at by someone reading from slides. That’s not useful to anyone.
A proper session works through the duty holder framework in the context of how your business actually operates. It covers real scenarios — the situations your teams face on live projects — and works out where your CDM management is solid and where there are genuine gaps.
CDM15 Refresher for Directors & Senior Teams
A focused one-day live session for construction directors, contracts managers and senior operational managers who want to get their CDM knowledge back to where it needs to be. Practical, honest, and built around how real construction businesses actually operate.
- The duty holder framework — who holds what
- What Client duties actually require in practice
- Principal Designer — competence and appointment
- Principal Contractor responsibilities on site
- Notifiable projects — triggers and process
- Construction Phase Plans that actually work
- Pre-Construction Information — gathering and passing down
- Competence checking through your supply chain
- Where CDM and the Building Safety Act connect
- Common gaps found in practice — and how to close them
If any of this resonates — the uncertainty about where the business actually stands, or a sense that CDM knowledge across the team could do with being properly tested — it is worth a conversation.