CDM 2015 applies to virtually all construction work in care homes. The client duty sits with the care provider -- not the contractor. Most care operators do not know this. Here is what it means in practice.
The Construction (Design and Management) Regulations 2015 apply to all construction work, including maintenance and refurbishment projects. There is no minimum project size that exempts a project from CDM -- all construction work carries some CDM obligations. The regulations scale with project size: small projects have simpler obligations; notifiable projects (more than 30 working days with more than 20 workers simultaneously, or more than 500 person-days of construction work) trigger additional formal requirements including notification to HSE. A bathroom refurbishment, a roof repair or a kitchen refit at a care home all fall within CDM 2015. The regulations do not apply to domestic clients commissioning work on their own home -- care home providers are commercial clients.
Under CDM 2015 Regulation 4, the client (the care provider) has specific duties that cannot be delegated to the contractor. The client must: make suitable arrangements for managing the project, including allocating sufficient time and resources; ensure those arrangements are maintained and reviewed throughout the project; provide pre-construction information to designers and contractors; ensure a construction phase plan is prepared before work begins; and ensure that a health and safety file is compiled and handed over at project completion. These are the client's obligations -- the contractor cannot discharge them on the client's behalf.
For notifiable projects, the client must appoint a Principal Designer (PD) and a Principal Contractor (PC) in writing before design work begins. The Principal Designer coordinates health and safety during the design and pre-construction phase. The Principal Contractor manages health and safety on site during the construction phase. Both must be appointed before design commences -- retrospective appointment is non-compliant. The care home operator as client is responsible for making these appointments and confirming in writing that the PD and PC have accepted their roles.
Before any contractor starts work, the client must provide pre-construction information: information about the site and the existing structure that could affect health and safety during the works. For a care home, this typically includes: the asbestos management plan and register; structural drawings; the location of services (gas, electrical, water, drainage); any contamination or environmental surveys; details of any existing hazardous materials; and information about the building's occupancy and any constraints on working hours or methods that protect residents and staff. Providing comprehensive pre-construction information is not optional -- it is a client duty.
At project completion, the client must receive a health and safety file -- a record of all significant hazards remaining in the completed structure that workers need to know about for future maintenance, repair or demolition. For a care home refurbishment this might include: as-built drawings, details of any asbestos left in place, information about structural elements that were modified, commissioning records for installed systems, and details of any residual contamination or specialist materials. Retain the file permanently and make it available to anyone carrying out future work on the building.
The most common CDM failures by care home clients are: failure to recognise the client duty (assuming CDM is the contractor's job); failure to appoint a Principal Designer before design commences; failure to provide pre-construction information (particularly asbestos information); failure to receive or retain the health and safety file at handover. Address each of these by making CDM compliance a standard part of your project initiation checklist -- before the first design meeting, before the first site visit, and before practical completion sign-off.
CareHomeDesk gives you compliance checklists, maintenance logs, and contractor management tools built around exactly this kind of knowledge.