Client Duties – Clause-by-clause comparison of the CDM 2015 Regulations and CDM 2007

Client Duties – Comparing the changes in the CDM 2015 Regulations and CDM 2007Download a note prepared by Mike Webster that identifies, clause-by-clause, the changes in the Client duties in the CDM 2015 regulations compared to those in CDM 2007, so making it easier to comply.

The Construction (Design and Management) Regulations 2015 (CDM 2015) govern the management of health, safety and welfare when undertaking construction projects in Great Britain.  CDM 2015 replaced CDM 2007 on 6 April 2015.

The eight key changes to the CDM 2015 Regulations from CDM 2007 are:

  • The CDM 2015 Regulations have a simplified structure
  • Clients' responsibilities have been strengthened and broadened
  • The exemption for Domestic Clients has been removed
  • The role of CDM Coordinator has been removed
  • The new role of Principal Designer has been introduced to plan, manage, monitor and coordinate the pre-construction (design) phase
  • Notification of the project to the Health and Safety Executive (HSE) has been removed as a trigger point for additional duties
  • The threshold for appointing a Principal Designer and Principal Contractor is if more than one Contractor is required on a project
  • The requirement for 'competence' has been removed and replaced with 'skills, knowledge, experience and training' and 'organisational capability’

To read a brief summary of those eight key changes and what they mean in practice, click here.

To read a summary of published discussions and answers to a range of frequently asked questions click here.

A series of articles providing information on key issues regarding the CDM 2015 Principal Designer duties are collected together for ease of use in this post.

Detailed changes have been made to the clauses of the CDM Regulations themselves. To capture these changes, I have prepared a document containing a clause-by-clause comparison of the Client duties in CDM 2015 and CDM 2007.  This allows all of the changes to be identified, including the relatively subtle changes to the wording of the Regulations, so that you can make the necessary changes to your practice.

This is the second document in this series.  Comparisons are also available for Designer duties and Principal Contractor / Contractor duties.

This document may be subject to change as more information becomes available.  If you let me have your email address I will notify you when updated versions and other relevant CDM 2015 material are available.

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    Further information

    A brief summary of eight key changes to the CDM 2015 Regulations from CDM 2007 and what those changes mean in practice is provided in this post.

    A summary of published answers to frequently asked questions relating to the CDM 2015 Regulations is provided in this post.

    Detailed clause-by-clause comparisons of the changes between the CDM 2015 Regulations and CDM 2007 are available on the MPW R&R web site for Clients, Designers and Principal Contractors / Contractors.

    I gave a 25-minute presentation at the Institution of Structural Engineers Small Practitioners Conference on 26 June 2018 on understanding the CDM 2015 Designer Duties as they relate to civil and structural engineers.  The video of my presentation and the accompanying slides are available in this post.

    An overview of the issues involved in CDM 2015 Designer Duties – Designing for maintenance are discussed in this post and the guidance available to civil and structural engineers on contemporary industry practice is highlighted.

    An overview of the issues involved in CDM 2015 Designer Duties – considering temporary works in permanent works design are discussed in this post and signposting is provided to the guidance available to civil and structural engineers on contemporary industry practice.

    The HSE web site contains a range of information on CDM 2015 including the guidance on the regulations, a short guide for clients and a guide on construction phase plans.

    The CITB web site contains industry guidance for each of the duty holders.

    About the author:

    Dr Mike Webster is a chartered civil and structural engineer with over 30 years' experience.  He specialises in construction and structural safety, CDM and risk, and founded MPW R&R to provide Consulting, Forensic and Expert Witness services in those areas.

    Mike has worked on the design, inspection, appraisal and site supervision of building, bridge and car park structures.  He has developed guidance for assessing the safety of existing structures.  Mike led an independent review of CDM 1994 and the independent evaluation of CDM 2007.  He also led the review of the use of CDM 2007 in the construction of London 2012.

    Mike has been instructed as an expert witness by both defence and prosecution teams in cases involving allegations of gross negligence manslaughter, breaches of the Health and Safety at Work Act and the CDM Regulations and the appeal of enforcement notices.  These cases have involved the construction, maintenance and demolition of a range of building, bridge and industrial structures.

    Mike is the author of around 20 published reports and papers on construction health and safety and the CDM Regulations.  He is also the author of a range of articles on CDM 2015.   He is a member of Structural-Safety and the Institution of Structural Engineers Health and Safety Panel.

    For more information email Mike at or give him a call on 07969 957471.