Just what will a Principal Designer do under CDM 2015?
Probably the most contentious issue being discussed as a result of the ‘new CDM’ regulations set for next year is the question of what exact role the “Principal Designer” (PD) will be expected to play.
Define that, and you go some way to answering the next question – how will he or she cope with the new responsibility?
Quite a lot of safety practitioners believe that size does matter: that larger design practices will be able to take it in their stride, while smaller firms may struggle. Some say they don’t cope now, under the current (2007) regulations, not designing away potential risks. The last regulatory change took away the requirement to produce Design Risk Assessments (DRA) – but some safety experts still press the designers to provide practical evidence of what they are doing to design out risk, without the form-filling artifice. Their aim in doing this is to refocus designers away from writing meaningless motherhood statements that require little or no thought.
It is suggested in recent posts that these ‘real assessments’ are most necessary for non-standard sites – such as ones where there is confined space or the need to void asbestos disturbance.
Generally, the architect gets appointed first and has to assume the PD role, whether or not that person or company is safety-minded. Cases are adduced by safety experts where “safe access” is not considered and maintenance then requires “a 3ft tall contortionist with a degree in limbo dancing to maintain the equipment!!”
This sort of nonsense is often put down to the architects’ failure to consult the CDM. How will they fare when that person is under their roof? And will they keep up with changing events when structural engineers or contractors find the need to change the details of the plan and alter the proposed working methods?
It is, as others have pointed out, unlikely that clients will care or be aware. This is perhaps a pity because under Regulation 9 of the new law, the PD must “plan, manage, monitor and coordinate the pre-construction phase of a project”. Clients, project managers and others could take over the role in theory, rather than a designer or architect.
The devil will, as ever, be in the detail and we await 2015 with baited breath. McCormack Benson Health & Safety (like other safety consultants) may be losing its CDM Coordinator role, but it is likely that its bespoke consultancy services will be even more in demand on site than before, due to the potential pitfalls of the new legislatory scene.