The CDM Regulations 2015 have generated a good deal of discussion and debate over who might legitimately be appointed CDM 2015 Principal Designer, particularly on larger construction projects.
Questions exercising minds have included:
> > Can a design organisation which is not a member of the project design team be appointed PD?
> > Must the lead designer automatically be appointed Principal Designer?
> > Can an organisation previously offering CDM Coordinator services be appointed Principal Designer?
These questions are not addressed directly in the Regulations nor in the HSE or Industry Guidance and there has so far been no published clarification provided by HSE.
Principal Designer must measure up to template.
In the absence of further HSE guidance it is suggested that project clients must check that the appointee can (and does) take the actions and demonstrates the behaviour required of the Principal Designer as set out in the CDM Regulations 2015 and the HSE / Industry Guidance.
The central requirement is that the Principal Designer must be a designer appointed by the client with control over the project pre-construction phase (PCP) in order to plan, manage and monitor the PCP and coordinate matters relating to H&S during the PCP.
The Principal Designer must have the skills, knowledge, experience and organisational capability, necessary to fulfil the role.
It is also essential that the client project management arrangements include the allocation of sufficient resources for the appointee to undertake these extensive and new Principal Designer duties.