On 4th December 2019, one of our Architects attended a Principal Designer Course, held by the RIBA at their headquarters in London. The course was designed, developed and delivered by Paul Bussey and Tony Putsman, an RIBA Chartered Architect and Civil Engineer who each have significant experience in the management of Health & Safety in design and construction.
A Principal Designer is one of the three main duty holders designated under the Construction (Design and Management) Regulations 2015 update, alongside the Client and Principal Contractor. The CDM Regulations apply to all construction projects and they also give responsibilities to Designers, Contractors and Workers. The Principal Designer should be a member of the design team and is responsible for planning, managing, monitoring and co-ordinating Health & Safety during the design (pre-construction) phase of a project. This ensures the early consideration of Health & Safety issues, which otherwise might lead to significant risks being discovered later in the process with cost, design and safety implications. During the design stage, the Principal Designer co-ordinates information from other Designers and makes appropriate checks to ensure that they are in receipt of the correct information from the Client and other duty holders.
The Principal Designer discharges their duties under the principal of ‘so far as reasonably practicable’. ‘So far as reasonably practicable’ relates to the proportionate integration of Health & Safety into creative design – weighing the risk against the resources need to eliminate or reduce the risk. Given that the role of Principal Designer involves duties separate to that of standard architectural services, being appointed as Principal Designer on a project should incur an additional fee to the Client; this cost should be itemised separately in fee proposals.
A CDM Strategy Brief should be prepared at the project’s outset – the Client and Principal Designer should identify key Health & Safety concerns for the project and develop a clear plan for managing significant risks. This brief should be produced separately from a Project Brief to ensure that it maintains a CDM focus. Other relevant data or information should also be recorded, including details of other Designers, Contractors and Principal Contractor (if known). This should be used as a reference resource throughout the project and updated to reflect any changes at each work stage.
The Principal Designer should also help the Client with the preparation of Pre-Construction Information, for which the Client is ultimately responsible; this should be passed to any appointed Designer or Contractor and will facilitate the Principal Contractor in their preparation of a Construction Phase Plan. Drawings and information matrices should be produced by the Principal Designer as part of this Pre-Construction Information, which clearly and simply identify significant project-specific risks using a visual risk assessment process (diagrams, annotated drawings, symbols). The Principles of Prevention should be applied to identify and manage foreseeable risks, so far as reasonably practicable. These risks should be reviewed at every work stage by the Client, Principal Designer and Principal Contractor (once appointed), with input from all other Designers to produce a collective resource which lists significant risks and how they are to be controlled, reduced or eliminated.
The production and development of Pre-Construction Information will continue for as long as design takes place; design may continue after construction has begun. The quantity of information should be proportionate to the scale and complexity of the project. General Health & Safety issues (which are not project-specific), for example ‘working at height’ should not be included within the Principal Designer’s information as the management of these standard issues falls within the Principal Contractor’s remit for any project. Architectural drawings, surveys or previous information about the site will also be included within the Pre-Construction Information.
Although it is the Principal Contractor’s responsibility to prepare the Construction Phase Plan, the Principal Designer should carry out checks to ensure that all significant risks have been addressed. Schedule 3 of Document L153 addresses specific risks in construction projects and the Construction Phase Plan should recognise this.
Once construction is completed, the Principal Designer is responsible for compiling a Health & Safety File. Health & Safety should be considered throughout a building’s lifespan, including issues of access, maintenance and operation; therefore the Health & Safety file should include all information which may be relevant to the future use of the building or its demolition, including significant risks which have not been eliminated. The Health & Safety File will become the Pre-Construction Information for any subsequent works to the site or building. The responsibility for producing the Health & Safety File may be passed to the Principal Contractor should the Principal Designer’s appointment cease before completion of the works.
Although the CDM Regulations define specific expectations of separate duty holders, successful Health & Safety management depends on mutual help, excellent communication and teamwork. A holistic approach to Health & Safety considers team performance above individual duties.
Upon completion of the course which included an online exam (passed with 95%), we now consider that we have the skills, knowledge, attitude, training and experience to carry out Principal Designer services for your project. Should you not wish to appoint us as Principal Designer, we would still occupy the role of a Designer under the CDM Regulations; this implies a duty of care to consider Health & Safety and any significant risks in our designs. A separate Principal Designer should still be appointed.
The 2015 CDM Regulations update also gives greater responsibilities to the Client, who is responsible for appointing the other duty holders, checking that they have the necessary skills, knowledge and experience to fulfil their role and to produce the relevant information. We would be happy to advise on how you might fulfil your role as Client under the CDM Regulations (including the submission of the F10 form, where required); if you are a domestic Client, your duties will be transferred to the Principal Contractor by default.