Who can be a Principal Designer under CDM 2015?

What does CDM mean by a Principal Designer?

CDM defines the Principal Designer as the designer appointed under Regulation 5 to control the pre-construction phase on a project involving more than one contractor. Read Regulation 2 on legislation.gov.uk: definitions of designer, principal designer and the pre-construction phase (opens in a new tab)

That means the role is tied to two things: being a designer under CDM and having sufficient control over the pre-construction phase to plan, manage, monitor and coordinate it. Read Regulation 11 on legislation.gov.uk: duties of a principal designer during the pre-construction phase (opens in a new tab)

Does the Principal Designer have to be an architect?

No. CDM does not say the Principal Designer must be an architect.

Depending on the project, the role may be carried out by an architect, engineer, design practice, multidisciplinary consultancy, contractor with genuine design responsibilities, or another designer that has the necessary control and capability. HSE guidance for principal designers: principal designers: roles and responsibilities under CDM 2015 (opens in a new tab)

Can a company be the Principal Designer?

Yes. The appointment can be made to an organisation rather than a named individual.

Where an organisation is appointed, the client should consider its organisational capability as well as the skills, knowledge and experience of the people who will actually perform the role. Read Regulation 8 on legislation.gov.uk: skills, knowledge, experience and organisational capability requirements (opens in a new tab)

Can an individual be the Principal Designer?

Yes. An individual can be appointed if they are a designer, have control over the pre-construction phase and have the necessary skills, knowledge and experience for the project.

On larger or more complex projects, however, an individual may need support from a wider organisation or team to discharge the coordination and management functions effectively.

What skills, knowledge and experience are required?

Regulation 8 requires anyone appointing a designer or contractor to take reasonable steps to satisfy themselves that the appointee has the skills, knowledge and experience needed to fulfil the role in a way that secures health and safety. Read Regulation 8 on legislation.gov.uk: skills, knowledge, experience and organisational capability requirements (opens in a new tab)

For a Principal Designer, that may include evidence of:

• Understanding of CDM 2015 and the duties of designers and other project duty holders.
• Experience coordinating design risk across multiple disciplines.
• Ability to identify and manage significant health and safety risks during the pre-construction phase.
• Experience leading design coordination and information exchange.
• Knowledge relevant to the type, scale and complexity of the project.
• Ability to communicate effectively with the client, designers and Principal Contractor.
• Experience managing changes and ensuring design decisions remain coordinated as the project develops.

The Principal Designer duties guide explains how that requirement applies once the appointment is made.

What is organisational capability?

Where an organisation is appointed, capability is not just about one competent individual. The organisation should have appropriate policies, systems, resources and people to support the role. HSE L153 guidance: Managing health and safety in construction: appointment, capability and principal designer duties, PDF (opens in a new tab)

For example, a client may consider whether the organisation has enough suitably experienced staff, clear responsibilities, effective design-review processes, suitable information-management arrangements and the capacity to remain involved for the necessary parts of the project.

Does the Principal Designer need control over all designers?

The Principal Designer does not need to employ every designer, but they must be in a position to plan, manage, monitor and coordinate the pre-construction phase. Read Regulation 11 on legislation.gov.uk: duties of a principal designer during the pre-construction phase (opens in a new tab)

If an appointee has little influence over other designers, limited access to design information or no authority to coordinate the design process, the client should question whether that person or organisation genuinely has the control needed for the role.

Can the lead designer automatically be the Principal Designer?

Not automatically. A lead designer may be a strong candidate, but the client still needs to consider whether they meet the CDM requirements for the Principal Designer role.

Job title alone is not enough. The key questions are whether the appointee is a designer, has sufficient control over the pre-construction phase and has the capability to discharge the statutory duties.

Can the client’s own organisation be the Principal Designer?

Potentially, yes, if the client organisation is also acting as a designer and can satisfy the requirements for the Principal Designer role.

The client should still be clear about who is carrying out the function, whether there is genuine design control and whether the organisation has the capability to perform the role effectively. Holding more than one CDM role does not reduce the duties attached to either.

Can the Principal Contractor also be the Principal Designer?

Potentially, yes. CDM does not prevent the same organisation from holding both roles, provided that organisation is also a designer and can properly discharge both sets of duties. HSE L153 guidance: Managing health and safety in construction: appointment, capability and principal designer duties, PDF (opens in a new tab)

The client should avoid assuming that a contractor can be Principal Designer simply because it is leading the construction phase. The Principal Designer role requires genuine design involvement and control of the pre-construction phase.

When must a Principal Designer be appointed?

A Principal Designer is required where a project involves, or it is reasonably foreseeable that it will involve, more than one contractor. Read Regulation 5 on legislation.gov.uk: client appointment duty and timing where more than one contractor is involved (opens in a new tab)

The client must appoint the Principal Designer in writing as soon as practicable and, in any event, before the construction phase begins. Read Regulation 5 on legislation.gov.uk: client appointment duty and timing where more than one contractor is involved (opens in a new tab)

Separate arrangements apply on domestic-client projects, where the client duties normally transfer to other duty holders.

What should a client check before appointment?

Before appointing a Principal Designer, the client should consider:

• Is the proposed appointee a designer under CDM?
• Will they have sufficient control over the pre-construction phase?
• Do they understand the Principal Designer duties under CDM 2015?
• Do they have suitable skills, knowledge and experience for this type of project?
• If an organisation is being appointed, does it have sufficient organisational capability?
• Can it coordinate the other designers and the flow of relevant information?
• Does it have enough resource to remain effective as the project changes?
• Is the appointment in writing and made early enough to influence the project?
• Are the boundaries of the appointment clear where there are multiple design organisations or phases?

What evidence can demonstrate capability?

There is no single certificate that automatically proves someone is suitable to be Principal Designer. The client should take a proportionate view of the evidence relevant to the project. HSE L153 guidance: Managing health and safety in construction: appointment, capability and principal designer duties, PDF (opens in a new tab)

• Relevant project experience and examples of similar work.
• Professional qualifications and memberships where relevant.
• Evidence of CDM knowledge and design-risk management experience.
• CVs or role profiles for the people who will perform the function.
• Design-coordination procedures and examples of previous outputs.
• Quality, information-management or assurance systems relevant to the work.
• References or evidence of previous Principal Designer appointments.
• Available resources and proposed project-team structure.

Is training alone enough to be a Principal Designer?

No. Training can support knowledge, but completing a course does not by itself demonstrate the skills, knowledge, experience or organisational capability required for a particular Principal Designer appointment.

Suitability should be judged in the context of the project, including its risks, complexity, design interfaces and the level of control the appointee will have.

What happens if the wrong person is appointed?

An unsuitable appointment can create gaps in design coordination, unclear ownership of risks and poor information transfer into construction.

The client also has a specific duty to take reasonable steps to satisfy themselves that those they appoint have the necessary capability. Appointment should therefore be treated as a substantive CDM decision rather than a paperwork exercise. Read Regulation 8 on legislation.gov.uk: skills, knowledge, experience and organisational capability requirements (opens in a new tab)

How is the CDM Principal Designer different from the Building Regulations Principal Designer?

The CDM Principal Designer and the Principal Designer under the Building Regulations are separate legal roles created under different legislation.

One person or organisation may sometimes be appointed to both roles, but that should not be assumed. The client should make the appointments clearly and assess suitability against the requirements of each regime. The Principal Designer duties guide explains the distinction in more detail.

Principal Designer appointment checklist

Before confirming the appointment, check that:

• The project actually requires a Principal Designer.
• The proposed appointee is a designer under CDM.
• They have genuine control over the pre-construction phase.
• Their skills, knowledge and experience are appropriate to the project.
• Their organisational capability has been assessed where an organisation is appointed.
• The people performing the role have relevant project experience.
• They can coordinate other designers and relevant information effectively.
• Their resources are proportionate to the project’s scale and complexity.
• The appointment is made in writing.
• The appointment is made early enough to influence design and pre-construction decisions.
• The scope and boundaries of the role are clear.
• The client understands that appointment does not transfer away the client’s own CDM duties.

Common mistakes when appointing a Principal Designer

Appointing by job title alone

Being the architect, lead designer or design manager does not automatically make someone suitable to be Principal Designer.

Appointing someone with no real design control

The appointee needs sufficient control over the pre-construction phase to coordinate it effectively.

Treating a training certificate as proof of competence

Training is only one part of capability and does not replace relevant experience or organisational capacity.

Making the appointment too late

A late appointment reduces the Principal Designer’s ability to influence early design and planning decisions.

Ignoring organisational capability

Where a company is appointed, the systems, resources and wider team matter as well as the named lead.

Confusing the CDM role with the Building Regulations role

The appointments should be assessed and documented separately even where the same person or organisation performs both.