CDM-compliant shop refurbishments – how to control your contractors

Many builders merchants regularly undertake shop refurbishments and other internal building works. Under the Construction (Design and Management) Regulations 2015, (CDM) these activities can carry significant health and safety responsibilities for merchants as clients of the works. In this post, we will look at the duties that CDM places on merchants as clients and how to make sure you're meeting them.

Duties placed on clients under CDM

CDM Regulations apply to all construction work, including the maintenance, repair, or alteration of any building. It is important to note that 'any building' means both your showroom and yard. CDM defines a 'client' as any business or individual for whom a construction project is being carried out. This means the majority of builders merchants who are commissioning construction or refurbishment works will have CDM duties.

The extent of your duties as a CDM client will depend on the size of your project. Simple refurbishments involving a single contractor can follow a simpler process, with additional responsibilities being triggered as projects grow in size and complexity.

Clients' duties for single contractor projects

For most simple refurbishment projects involving a single contractor, merchants will need to ensure:

• Pre-construction information is provided to the contractor. This includes any relevant information you hold about the building they are working in, for example, electrical schematics, asbestos surveys, and structural drawings.
• Contractors have been competency checked. For example, checking their HSE registration, insurance documents, accreditation, and references.
• A site-specific health and safety plan is provided. This identifies the hazards specific to the site and documents the responsibilities of each party.
• The welfare provision on site is satisfactory. For instance, the contractor has access to toilet, hand-washing, and rest facilities.

A health and safety file is not needed for a single-contractor project. It becomes a requirement once more than one contractor is involved, when the principal designer prepares it as the record of health and safety information for the building.

Duties for multiple contractor projects

For larger, more complex projects involving multiple contractors, CDM requires the appointment of a Principal Designer and Principal Contractor. As a client, you retain responsibility for ensuring that suitable parties have been appointed to each role and that they are managing the project in line with CDM requirements.

In the case of a large-scale shop refurbishment, you would typically appoint an architect or design-and-build contractor as your Principal Designer and a main contractor as your Principal Contractor.

HSE notification

For projects which will last longer than 30 working days with more than 20 simultaneous workers, or projects which will exceed 500 person-days, you have a duty to notify the HSE through their online portal.

Who can help you?

If you're planning a shop refurbishment or other building work and are unsure about your CDM duties, our team of consultants can provide guidance on how to meet these requirements. We can provide support in a variety of ways, including:

• Providing a pre-construction information pack and health and safety plan
• Reviewing your contractor's construction phase plan
• Undertaking site inspections to verify adherence to the health and safety plan
• Reviewing your contractor competency checking process