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Why clearer CDM guidance matters, particularly around the Principal Designer role

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

New HSE guidance is expected to clarify CDM regulations.

The Health and Safety Executive (HSE) has indicated that further guidance is expected to help clarify aspects of the Construction (Design and Management) Regulations 2015, particularly around the Principal Designer role.

For many working across construction and development, this will not come as a surprise. There has been increasing discussion across the industry around the CDM Principal Designer role and how it now interfaces with the Building Regulations Principal Designer role introduced through the Building Safety Act.

Construction News has reported that further HSE guidance is expected to clarify aspects of the regulations and the responsibilities associated with these appointments.

This is an important conversation for clients, designers, project managers, and contractors alike. Clear appointments, clear communication, and a consistent approach to design risk management remain fundamental to effective project delivery.

In recent years, the industry has been adapting not only to CDM 2015 but also to the additional dutyholder requirements introduced by the Building Safety Act and the Building Regulations. As a result, there has been increasing discussion around where responsibilities sit, how duties overlap, and how the different Principal Designer roles should operate in practice.

In reality, many projects now involve two distinct Principal Designer functions:

  • the CDM Principal Designer under CDM 2015
  • the Building Regulations Principal Designer under the Building Regulations regime

Although the titles are similar, the duties, legal context, and areas of responsibility are different.

This distinction is important because confusion at the pre-construction stage can lead to gaps in coordination, inconsistent risk management, and uncertainty around accountability. On complex projects, particularly those involving multiple designers, occupied buildings, refurbishment works, or higher-risk buildings, clarity becomes essential.

From a practical perspective, the most effective projects are usually the ones where:

  • Roles are clearly defined from the outset
  • clients understand the scope of each dutyholder appointment
  • design risk management is treated as an active process rather than a compliance exercise
  • communication between designers, contractors, and client-side teams is maintained throughout the project lifecycle.

The original intention behind CDM was always to improve coordination, encourage early consideration of risk, and embed health and safety into design and planning decisions. That principle remains as relevant today as it was when the regulations were introduced.

What has changed is the wider regulatory environment around construction and building safety. The introduction of additional dutyholder frameworks has inevitably created new interfaces between compliance regimes, and the industry is still adjusting to how those interfaces operate in practice.

Additional clarification from HSE is therefore likely to be welcomed across the sector, particularly by clients, designers, project managers, and principal contractors trying to navigate increasingly complex project responsibilities.

Ultimately, clearer guidance benefits everyone involved in project delivery. It supports better communication, more consistent appointments, and stronger coordination across the design and construction process.

Most importantly, it helps ensure that the focus remains where it should be, on managing risk effectively and delivering safer project outcomes.

Clients, designers, or contractors seeking proportionate, legally sound support under CDM 2015, Derisk (UK) Ltd would welcome the opportunity to discuss how our construction compliance and consultancy services can help manage design risk more effectively and add genuine value to projects.

Stephen Hunter CDM Principal Designer & Health and Safety Specialist | Derisk (UK) Ltd | 📧stephen.hunter@deriskuk.com | https://www.deriskuk.com/get-in-touch/

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