CDM Regulation 11 Explained: The Principal Designer's Pre-Construction Duties
If you are looking up Regulation 11 of CDM 2015, you have landed on the regulation that governs the principal designer during the pre-construction phase. It is one of the most misunderstood parts of CDM, because it created a role that did not exist before 2015 and gave it a specific set of duties. This guide sets out what Regulation 11 actually requires, in plain English, and what it means for the way a project is planned before anyone lifts a tool.
What Regulation 11 covers
Regulation 11 of the Construction (Design and Management) Regulations 2015 is titled the duties of a principal designer in relation to health and safety at the pre-construction phase. In short, it defines what the principal designer has to do in the design and planning stage of a project, before construction work starts on site. It is the counterpart to Regulation 13, which sets out the principal contractor's duties during the construction phase.
The pre-construction phase is where the biggest health and safety wins are available, because that is when risks can be designed out rather than managed on site. Regulation 11 puts a named duty holder in charge of making that happen.
The core duties under Regulation 11
Regulation 11 places several linked duties on the principal designer. Read together, they describe a role that plans, coordinates and hands over.
- Plan, manage and monitor the pre-construction phase. The principal designer has to plan, manage and monitor the pre-construction phase and coordinate health and safety during it, so the project is carried out without risks to health and safety so far as is reasonably practicable.
- Apply the general principles of prevention. In doing that, the principal designer must take account of the general principles of prevention: identifying hazards, then eliminating or controlling foreseeable risks in the design.
- Make sure designers do their bit. The principal designer has to ensure that everyone designing on the project cooperates and complies with their own duties under Regulation 9.
- Help the client with pre-construction information. The principal designer assists the client in providing the pre-construction information, and then provides that information promptly and in a convenient form to every designer and contractor who needs it.
- Liaise with the principal contractor. The principal designer must liaise with the principal contractor for the length of the appointment and share any information relevant to planning, managing and monitoring the construction phase and preparing the construction phase plan.
Why Regulation 11 exists
Before 2015, coordination of health and safety in the design stage sat with the CDM coordinator, a standalone adviser. CDM 2015 abolished that role and moved the responsibility into the design team itself, through the principal designer. Regulation 11 is where that shift lives. The thinking is simple: the people making the design decisions are the people best placed to remove risk from those decisions, so the duty should sit with them rather than with an outside adviser.
Who the principal designer is
The principal designer is a designer, an organisation or individual, appointed by the client on any project involving more than one contractor. It is not the same as the principal contractor, and it is not the old CDM coordinator role renamed. The principal designer has design control during the pre-construction phase, which is exactly why Regulation 11 hangs the pre-construction health and safety duties on that role.
On a project with only one contractor the client does not appoint a principal designer, and the relevant duties fall to the contractor and designer instead. Regulation 11 bites when the principal designer role is required.
What Regulation 11 means on a real project
In practical terms, Regulation 11 is why a well run project has its health and safety thinking done on paper before the ground is broken.
- Risk is designed out first. The principal designer works through the design looking for foreseeable risks and removes or reduces them before they ever reach the site.
- Information flows to the right people. Pre-construction information is gathered and passed to designers and contractors so nobody is planning work blind.
- The handover is clean. By liaising with the principal contractor and feeding into the construction phase plan, the principal designer makes sure the construction team inherits a project that has already been thought through.
Frequently asked questions
What is Regulation 11 of CDM 2015?
Regulation 11 sets out the duties of the principal designer in relation to health and safety during the pre-construction phase of a construction project. It requires the principal designer to plan, manage, monitor and coordinate health and safety before construction work starts, applying the general principles of prevention to remove risk from the design.
Who does Regulation 11 apply to?
Regulation 11 applies to the principal designer, the designer appointed by the client to control the pre-construction phase on any project with more than one contractor. Where there is only one contractor no principal designer is appointed and the relevant duties fall to the designer and contractor instead.
How does Regulation 11 relate to Regulation 13?
Regulation 11 governs the principal designer in the pre-construction phase, while Regulation 13 governs the principal contractor in the construction phase. Together they split the project in two: the principal designer plans and coordinates health and safety before work starts, then hands over to the principal contractor who manages it during the build.
The shortcut
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This article is general guidance for UK construction and is not legal advice. For requirements specific to your work, check the full text of CDM 2015 and current HSE guidance, including L153, and your own duty holder obligations.