A useful design-risk record should explain the significant foreseeable risk, the people and project stage affected, the design decision made to eliminate or reduce it, any remaining risk that others need to manage, the information or drawing that communicates it, and any unresolved action with an owner and due date.
A spreadsheet can support that process, but the register is not the legal outcome. A long list of generic hazards, copied controls and numerical scores can conceal whether the design was actually changed or whether contractors received the information they need.
The assessment happens through competent design decisions, coordination and review. The record should make those decisions understandable and traceable. It should not become a substitute for eliminating risk through the design itself.
What does CDM 2015 require designers to do?
A designer is not limited to an architect or engineer. Under CDM, the term can include any organisation or individual whose business involves preparing or modifying drawings, specifications, calculations, bills of quantity or other designs—or arranging or instructing others to do so. A client, contractor or specialist trade can therefore acquire designer duties through the decisions it makes.
Regulation 9 requires a designer, when preparing or modifying a design, to take account of the general principles of prevention and relevant pre-construction information. The designer must eliminate foreseeable risks so far as reasonably practicable to people:
- carrying out or liable to be affected by the construction work;
- maintaining or cleaning the structure; and
- using a structure designed as a workplace.
Where a risk cannot be eliminated, the designer must, so far as reasonably practicable, reduce it or control it through the subsequent design process, provide information about it to the Principal Designer and ensure appropriate information reaches the Health and Safety File. The designer must also provide enough information with the design to help the client, other designers and contractors comply with their duties.
This is a hierarchy. The first question is what can be designed out. Adding a note that tells a contractor to manage a risk is not equivalent to considering a safer design option.
Is a design risk assessment or register legally required?
The CDM Regulations do not prescribe a document with the title design risk assessment or design risk register. They prescribe duties and information outcomes. This is an inference from the wording of regulations 9 and 11: neither regulation specifies a particular template, scoring matrix or register.
A proportionate register can still be valuable. It can bring together significant design decisions, interfaces, unresolved matters and residual-risk information for a multi-disciplinary team. It may also help a client or Principal Designer check that the design-risk process is active.
The format should fit the project. Relevant evidence might sit in design-review minutes, annotated drawings, specifications, models, clash or issue trackers, option appraisals, design-change records and the developing Health and Safety File. A single register is not automatically better than clear information attached to the design.
| Useful evidence | Weak evidence |
|---|---|
| Explains the significant risk and the design decision taken. | Lists a generic hazard such as “working at height” with no design context. |
| Links the residual risk to a location, detail, drawing or specification. | Uses “contractor to manage” as the only response. |
| Records options considered and why the selected solution is reasonably practicable. | Applies a score without showing how the design changed. |
| Identifies an unresolved interface, owner, action and decision date. | Keeps closed and irrelevant items until the important actions are buried. |
| Uses plain language that the recipient can act upon. | Relies on acronyms or a separate register nobody receives. |
What should a proportionate design-risk record contain?
The level of detail should reflect the significance and complexity of the risk, the design stage and the people who need the information. Useful fields include:
- Design element and location: the relevant system, zone, detail, drawing, model or specification.
- Lifecycle stage and people affected: construction, commissioning, occupation as a workplace, cleaning, maintenance, alteration or demolition.
- Foreseeable risk: the design-specific problem and credible consequence—not simply the name of a hazard.
- Information considered: surveys, existing-file information, client constraints, manufacturer data, access strategy, sequencing and contractor input.
- Design response: how the risk was eliminated, reduced or controlled through the design.
- Options and decision: where material, the safer options considered, the constraint affecting selection and why the chosen response is reasonably practicable.
- Residual risk and required action: only the information that another designer, contractor, user or maintainer needs to act upon.
- Information route: the drawing note, specification clause, model annotation, meeting action, pre-construction information or Health and Safety File entry that carries the message.
- Owner, status and review point: who must resolve an issue, when it is needed and what design change or project event will trigger another review.
Risk scoring is optional. If a scoring system is used, it should support prioritisation rather than create false precision. The most useful question is usually whether a further reasonably practicable design measure is available and whether the remaining information is clear to the person who must use it.
Which design risks should be communicated?
Information should be proportionate and comprehensible. The project team needs design-specific information about risks that are significant, unusual, difficult to recognise from the design or not likely to be controlled adequately without the designer's input. Routine construction risks should not be repeated merely to show that a checklist was completed.
Examples that may merit clear design information include:
- an existing structure whose stability depends on a particular sequence or temporary support;
- heavy or awkward components requiring defined lifting, bearing or installation assumptions;
- restricted maintenance access or equipment that cannot be isolated from an occupied area;
- buried or concealed services that affect the proposed design or future work;
- fragile materials, unusual load paths or residual prestress that may not be apparent;
- a design relying on a specialist contractor's later design, with interfaces and performance assumptions still to be resolved; and
- hazardous materials or construction methods that could reasonably be replaced or reduced through specification.
The best information is close to the design: a clear note on the relevant drawing or model, supported by a specification or schedule where necessary. A residual-risk symbol without an explanation, or a register that the contractor never receives, does not provide useful coordination.
What should the CDM Principal Designer coordinate?
On a project involving more than one contractor, the Principal Designer must plan, manage, monitor and coordinate health and safety in the pre-construction phase. Regulation 11 also requires the Principal Designer to ensure that designers comply with regulation 9 and that the people working in the pre-construction phase cooperate with the client, the Principal Designer and each other.
This does not mean producing every designer's assessment on their behalf or owning every technical risk. Each designer remains responsible for its design and for providing adequate information. The Principal Designer should establish a workable coordination process and test whether significant risks, interfaces and missing decisions are being managed.
A proportionate review may check:
- whether every design package and contractor-designed portion has a clear owner;
- whether current pre-construction information has reached the relevant designers;
- whether foreseeable construction, cleaning, maintenance and workplace-use risks have been considered;
- whether design options and risk-reduction decisions are visible at the appropriate stage;
- whether residual-risk information is consistent across drawings, specifications and models;
- whether unresolved interfaces are assigned and closed before they affect construction; and
- whether relevant information reaches the Principal Contractor and the Health and Safety File.
The client should appoint a Principal Designer early enough to influence the design. See when the appointment is required and the separate explanation of the CDM and Building Regulations Principal Designer roles.
When should design risk be reviewed?
Design-risk work is not a one-off submission. Review it when new information or a design decision could alter who is exposed, how the work will be built or how the finished structure will be used and maintained.
Typical triggers include a new survey, change of use, value-engineering proposal, revised sequence, contractor-designed element, temporary-works interface, product substitution, altered access strategy, design development, construction query or site condition that challenges an assumption.
A late change needs the same level of design consideration as the original decision. The project should record what changed, who checked the health and safety implications, which drawings and specifications were revised, and who was told before the affected work proceeded.
What should a client or architect ask for?
- Who is acting as a designer for each package, including specialist and contractor design?
- What current pre-construction information has each designer received?
- How will the team record important option and design-risk decisions without creating generic paperwork?
- How will interfaces between disciplines and temporary or permanent works be coordinated?
- Where will residual-risk information appear so contractors and future maintainers can find it?
- Who owns unresolved actions and by what date must each decision be made?
- Which design changes trigger a renewed risk and coordination review?
- How will the Principal Designer monitor regulation 9 compliance and pass relevant information to the Principal Contractor?
The answer should describe a process connected to the design programme, not simply promise a register at the end of the project.