Design risk register: what is it and how should it be used under CDM?

What is a design risk register?

A design risk register is a structured record used by a design team to track health and safety issues that arise from design decisions.

It may record the risk, the design feature or activity creating it, what has been done to eliminate or reduce it, any further action required, who owns that action and what information needs to be passed to other designers, contractors or the client.

Is a design risk register required by CDM 2015?

No. CDM 2015 does not prescribe a design risk register, design risk assessment form or a particular risk-scoring template.

Regulation 9 instead places duties directly on designers. When preparing or modifying a design, a designer must take account of the general principles of prevention and relevant pre-construction information to eliminate foreseeable risks so far as reasonably practicable. Where risks cannot be eliminated, the designer must reduce or control them so far as reasonably practicable and provide relevant information. Read Regulation 9 on legislation.gov.uk: duties of designers: take into account the general principles of prevention and any pre-construction information to eliminate foreseeable risks so far as is reasonably practicable, reduce or control those that cannot be eliminated, and provide information with the design (opens in a new tab)

The Principal Designer has separate coordination duties under Regulation 11. A risk register can be one useful way of supporting those duties, but it should only be used where it adds value to the design process. Read Regulation 11 on legislation.gov.uk: duties of a principal designer: plan, manage and monitor the pre-construction phase and coordinate matters relating to health and safety, and ensure designers comply with their duties in regulation 9 (opens in a new tab)

Design risk register vs design risk assessment

The terms are often used interchangeably, but they are not necessarily the same thing.

A design risk assessment usually describes the process of considering hazards and risks associated with a design decision. A design risk register is normally the ongoing record used to capture significant issues, actions and residual information across the project.

Neither label changes the legal duty. CDM is concerned with what designers actually do to eliminate, reduce and communicate risk, not whether a particular form has been completed. HSE L153 guidance: Managing health and safety in construction: practical interpretation of the CDM 2015 designer and principal designer duties, PDF (opens in a new tab)

What risks should go on a design risk register?

A useful register should concentrate on significant design risks that require action, coordination or communication. HSE L153 guidance: Managing health and safety in construction: practical interpretation of the CDM 2015 designer and principal designer duties, PDF (opens in a new tab)

Examples may include:

• Unusual structural stability risks during construction or demolition.
• Complex temporary works or sequencing constraints created by the permanent design.
• Heavy or difficult-to-install components where safer design alternatives need to be considered.
• Maintenance access at height or in restricted areas.
• Confined-space risks created or affected by the design.
• Interfaces between architectural, structural, civil and building-services designs.
• Existing services, structures, contamination or ground conditions that materially affect the design.
• Residual risks that are not obvious to a competent contractor from the design itself.
• Risks associated with future cleaning, maintenance, alteration or demolition.

What should not go on the register?

The register should not become a catalogue of obvious construction hazards or generic statements that a competent contractor would already be expected to understand. HSE L153 guidance: Managing health and safety in construction: practical interpretation of the CDM 2015 designer and principal designer duties, PDF (opens in a new tab)

Entries such as ‘working at height’, ‘manual handling’ or ‘use PPE’ are rarely useful on their own. The value lies in recording what is unusual or significant about the design, what decision has been made and what another duty holder needs to know.

What should a design risk register contain?

A proportionate register may include:

• A unique reference number.
• The relevant design element, location or drawing reference.
• A clear description of the significant risk or design issue.
• Who could be affected and at what project stage.
• The design decision or control already adopted.
• Further action needed to eliminate or reduce the risk.
• The person or discipline responsible for the action.
• Target date or design-stage milestone.
• Current status.
• Residual information that needs to be communicated.
• Reference to supporting drawings, models, specifications or meeting records.

Design risk register example structure

Who should own the design risk register?

There is no statutory rule that says one particular person must own a design risk register.

Individual designers remain responsible for the health and safety implications of their own designs. On a project with more than one contractor, the Principal Designer has the wider duty to plan, manage, monitor and coordinate health and safety during the pre-construction phase. Read Regulation 11 on legislation.gov.uk: duties of a principal designer: plan, manage and monitor the pre-construction phase and coordinate matters relating to health and safety, and ensure designers comply with their duties in regulation 9 (opens in a new tab)

In practice, the Principal Designer may coordinate a common register, require designers to maintain discipline-specific records, or use another structured process. Whatever approach is chosen, it should make responsibilities and actions clear without implying that the Principal Designer has taken over the designers’ own duties.

What is the Principal Designer’s role?

The Principal Designer should use the design-risk process to support coordination across the design team, particularly where one designer’s decision affects another discipline or creates an interface with construction.

That may include challenging unresolved risks, ensuring significant issues are considered at design reviews, tracking actions, coordinating relevant information and escalating issues where the design team cannot resolve them. Where design risks affect how the work will be built, they also need to reach the Principal Contractor. Read Regulation 11 on legislation.gov.uk: duties of a principal designer: plan, manage and monitor the pre-construction phase and coordinate matters relating to health and safety, and ensure designers comply with their duties in regulation 9 (opens in a new tab)

HSE research into implementation of the Principal Designer role has referred to risk registers as one of the mechanisms used in practice to identify unresolved issues, but the effectiveness of the role depends on active cooperation and resolution rather than the existence of the register itself. HSE Research Report RR1198: Implementation of the Principal Designer Role within CDM 2015: research evidence on how the role works in practice, including risk registers used to track unresolved design issues, PDF (opens in a new tab)

Should every designer add entries to the same register?

Not necessarily. The right approach depends on the project.

A smaller project may use one shared register. A large multidisciplinary project may use discipline-level records that feed into a coordinated project register or model-based issue-management system.

The important point is that significant issues are visible to the people who need to act on them and are not lost between organisations, disciplines or design stages.

When should the register be started?

Design-risk management should begin as early as meaningful design decisions are being made.

Starting the register at concept or early design stage can help the team identify opportunities to eliminate hazards before solutions become fixed. Creating one immediately before construction simply to demonstrate that a register exists misses most of its value.

How should the register be used at design reviews?

The register can provide a useful agenda for design-risk discussion, but the meeting should focus on decisions and action rather than reading through every row.

A good review should ask:

• Can this risk be eliminated through a different design decision?
• If it cannot be eliminated, can the risk be reduced further?
• Does another designer need to coordinate their design in response?
• Does the contractor or Principal Contractor need information now to influence planning?
• Is the entry still genuinely significant, or can it be closed?
• Does any residual information need to feed into pre-construction information or the health and safety file?

Should design risks be scored red, amber and green?

A project can use risk scoring or red/amber/green status if it helps prioritise work, but CDM 2015 does not prescribe a scoring matrix.

Scoring can become misleading if teams focus on changing a number rather than improving the design. A high-quality register should make the design decision, action and residual information clear whether or not a numeric or colour score is used.

When should an entry be closed?

An entry should normally be closed when the relevant design action has been completed and the team is satisfied that no further coordinated action is required.

Closing an entry does not mean pretending the risk has disappeared. If a significant residual risk remains, the register should make clear what has been done and where the information has been transferred.

How should residual risks be communicated?

Designers must provide sufficient information to help clients, other designers and contractors comply with their duties. Read Regulation 9 on legislation.gov.uk: duties of designers: take into account the general principles of prevention and any pre-construction information to eliminate foreseeable risks so far as is reasonably practicable, reduce or control those that cannot be eliminated, and provide information with the design (opens in a new tab)

Useful residual-risk information should be specific and proportionate. It may be communicated on drawings, models, specifications, pre-construction information, design-review records or directly to the Principal Designer and Principal Contractor. Read Regulation 4 on legislation.gov.uk: client duties in relation to managing projects, including providing pre-construction information to every designer and contractor appointed or being considered for appointment (opens in a new tab)

The risk register can help track that transfer, but contractors should not be expected to search through a large spreadsheet to discover critical information that should have been communicated clearly elsewhere.

Does the design risk register form part of the health and safety file?

Not automatically.

The health and safety file should contain information likely to be needed to protect people carrying out future construction work on the structure. A complete working design-risk register may contain closed actions, temporary issues or process information that future users do not need. Read Regulation 12 on legislation.gov.uk: health and safety file duties: the file must contain information relating to the project likely to be needed during any subsequent project to ensure the health and safety of any person (opens in a new tab)

Relevant residual information from the design-risk process should be transferred into the health and safety file where appropriate, rather than automatically inserting the entire register.

Common design risk register mistakes

Treating the register as proof of compliance

A completed spreadsheet does not demonstrate that risks were eliminated or reduced through design.

Recording every generic hazard

Long registers full of obvious risks hide the significant issues that actually require design attention. HSE L153 guidance: Managing health and safety in construction: practical interpretation of the CDM 2015 designer and principal designer duties, PDF (opens in a new tab)

Using risk scores instead of design decisions

Changing a red box to amber is not a control measure.

Making the Principal Designer responsible for every entry

Individual designers retain responsibility for their own design duties.

Starting the register too late

The greatest opportunities to eliminate risk are often available before the design becomes fixed.

Leaving actions without owners

An issue with no named owner or design discipline can remain unresolved despite appearing on the register.

Closing entries without transferring residual information

Important residual risks still need to reach the people who will construct, maintain or alter the asset.

Sending the whole register to contractors without explanation

Critical information should be communicated clearly through the most appropriate project information, such as drawings, specifications, pre-construction information or the construction phase plan, not buried in a spreadsheet.

Design risk register checklist

• Use the register only where it adds value to design-risk coordination.
• Focus on significant and unusual design risks rather than generic hazards.
• Record the design response, not only the hazard.
• Give every open action a clear owner.
• Review risks early enough for design change to remain possible.
• Use design reviews to challenge whether risks can be eliminated or reduced further.
• Coordinate issues that cross design disciplines.
• Share relevant information with the Principal Contractor at the right time.
• Close actions only when the required design response has actually been completed.
• Transfer significant residual information into drawings, specifications, PCI or the health and safety file as appropriate.
• Do not treat a risk score or closed register entry as evidence that the legal duty has been discharged.