Supporting CDM Dutyholders in Cladding Remediation Projects: How Derisk (UK) Ltd Ensures Clarity, Competence and Compliance.

Article by Stephen Hunter, CDM Principal Designer & Health and Safety Specialist.

Over the past several years, I’ve had the privilege of supporting a wide range of cladding remediation projects, acting in key roles including CDM Principal Designer, CDM Client Advisor, and Principal Designer/ Principal Contractor Advisor.

Cladding remediation has become one of the most regulated and safety‑critical project types in the UK. Public investigations into major fire events have highlighted persistent failures across advisory, design and management roles, including inadequate competence, unclear accountability, and poor coordination between specialists. These lessons reinforce the need for clear duty holder definition, strong CDM processes, and highly competent design‑stage risk management, particularly for high‑risk façade remediation work.

Working across both Higher-Risk Buildings (HRBs) and non-HRB residential and commercial assets, I’ve seen firsthand how essential early, competent, and proactive CDM involvement is in driving safety, quality, and true buildability.

Experience Across All Cladding Remediation Project Types

Over the course of my work in façade safety and cladding remediation, I’ve had direct involvement in virtually every major project type currently active in the UK. This includes ACM remediation, non-ACM combustible cladding replacement on high-rise buildings, mid-rise projects delivered under the Cladding Safety Scheme (CSS), and life-critical risk remediation on low-rise buildings. My experience spans both full strip-and-re-clad schemes and targeted façade risk interventions, as well as developer-led remediation programmes, social housing provider projects, and façade safety works across commercial and mixed-use buildings. This breadth of project exposure has given me a clear and practical understanding of the regulatory pathways and the unique design‑stage risks that arise across different building typologies.

At Derisk (UK) Ltd , our focus is simple:

• Improve safety in design
• Enhance buildability
• Support compliant, coordinated project delivery.

CDM Dutyholder Support Under CDM 2015

Under the Construction (Design and Management) Regulations 2015, Clients, Designers and Contractors each carry statutory responsibilities. The Client retains ultimate legal responsibility for ensuring suitable arrangements are in place and must appoint competent duty holders based on Skills, Knowledge, Experience and Organisational capability (SKEO).

Derisk supports this framework with services that reinforce-not replace-legal duties. Whether acting as CDM Advisor to the Client, Principal Designer (non‑designing PD), or CDM Advisor to the appointed PD, our approach ensures:

• Clear separation of responsibilities
• Robust communication and coordination
• Compliance‑focused oversight
• F10 notification support (where applicable).

Below is a clear breakdown of how we deliver each role.

1. CDM Advisor to the Client

As CDM Advisor, Derisk helps Clients meet their legal responsibilities without performing the duties of the PD, PC, PM or Designers.

Client Duty Support:

• Advising on CDM 2015 duties and ensuring suitable arrangements are in place
• Supporting SKEO‑based appointments of Principal Designer and Principal Contractor
• Assisting the Client in confirming that Pre‑Construction Information (PCI) is complete (without interpreting or validating technical content)
• Checking that the Construction Phase Plan (CPP) has been prepared before works begin
• Supporting F10 notification where required
• Ensuring a process exists for producing and handing over the Health & Safety File.

Cladding‑Specific Support – The Client Advisor does not gather surveys, manage specialists, or identify construction risks; these remain PM/PD duties.

Instead, Derisk:

• Advises on the types of façade, fire and structural surveys typically required (without procuring or technically assessing them)
• Checks that required surveys have been commissioned by the PM and included in PCI
• Reviews whether arrangements for managing cladding‑related risks (e.g., work at height, falling objects, temporary conditions, resident interface) are in place, without undertaking risk assessments
• Advises on whether stakeholder engagement processes (led by the PM/PC) are appropriate.

The Client remains legally responsible; Derisk ensures they understand and discharge that responsibility.

2. CDM Principal Designer (PD)

When appointed as Principal Designer (non‑designing PD), Derisk fulfils statutory duties to:

Plan, manage, monitor and coordinate the pre‑construction phase – Coordinating health and safety matters across the design team.

Ensure Designers apply the Principles of Prevention – We review, coordinate, and challenge design risk information without producing, approving, or validating design solutions.

Coordinate all design inputs – including fire engineering, façade engineering, structural design and specialist surveying, ensuring coherent H&S risk communication.

Identify gaps and manage the flow of Pre‑Construction Information (PCI) – We assemble, review and issue PCI to all dutyholders.

Prepare and maintain the Health & Safety File – We compile and maintain the Health & Safety File throughout the project lifecycle and ensure the Client receives the completed document with a clear explanation of its contents.

Derisk does not:

• Produce design solutions
• Approve, certify or validate designs
• Undertake project management functions.

These remain the responsibility of the designers and the PM.

3. CDM Advisor to the Appointed Principal Designer

Where another organisation is appointed as PD, Derisk supports:

• Advising on statutory PD duties and compliance frameworks
• Reviewing whether Designers are applying the Principles of Prevention
• Supporting PCI collation and the flow of risk information
• Assisting with the coordination of multi‑disciplinary design reviews
• Supporting the PD with the Health & Safety File structure and processes
• Providing cladding‑specific insight (sequencing, resident impact, temporary conditions, etc.) without taking on PD or PM duties.

Strengthening Cladding Safety Through Role Clarity – Derisk ensures that Clients, PDs, PMs and Designers understand their statutory responsibilities and operate within a robust, compliant CDM framework. We reinforce role clarity and ensure competent, coordinated processes to deliver safe, transparent, compliant cladding remediation projects.

Stephen Hunter CMIOSH | Associate Director, CDM, H&S Services | Derisk (UK) Ltd | 📧stephen.hunter@deriskuk.com | https://www.deriskuk.com/get-in-touch/