CDM 2015 client duties

You are the client even if a fit-out firm "does everything"

A design and build contractor can be appointed as principal designer and principal contractor, which is common on fit-outs. That does not remove the client's own duties: you still have to make suitable arrangements, provide information and check that the plan and file exist. Where a client fails to appoint a principal designer or principal contractor on a project that needs them, the Regulations say the client must fulfil those roles.

Asbestos is the information most often missing

For refurbishment, the single most important piece of pre-construction information is usually the refurbishment and demolition asbestos survey of the areas to be disturbed. A management survey alone is not enough. HSE's HSG264 explains the difference. Commission it before the work is priced.

Notification is about size, not risk

A project is notifiable to HSE (using form F10) if construction work will last longer than 30 working days and have more than 20 workers working at the same time at any point, or will exceed 500 person-days. The client is responsible for notifying, though the principal designer or contractor often does it on the client's behalf. Most single-floor refurbishments with a sizeable team cross the 500 person-day line.

Occupied buildings need extra thought

When staff, pupils, patients or customers stay in the building, the client knows things the contractor does not: who is where and when, fire evacuation routes, deliveries, vulnerable people. Share that early and agree how the site will be separated from the occupied areas.

Building regulations dutyholders

Since October 2023, the Building Regulations in England also give clients, principal designers and principal contractors dutyholder and competence duties for building regulations compliance. They sit alongside CDM, with the same role names but a different purpose. Your contractor should be able to explain how both are covered.