Delivering the full value of the Principal Designer’s role under CDM 2015
The UK Health and Safety Executive (HSE) introduced the Principal Designer (PD) role into the Construction (Design and Management) Regulations (CDM) in 2015. The intention was to add value by controlling and influencing the designer-led risk management process. An HSE research report issued in June 2023, RR1198 (Ref. 1), highlights that the PD’s value is not being fully delivered across the UK construction sector as the HSE had originally hoped.
This article summarises the key findings of RR1198 and suggests learnings for energy transition projects to realise the full value of the PD role, ultimately enabling the safe transition to net carbon zero.
INTRODUCTION
The PD must plan, manage, monitor and coordinate health and safety in the pre-construction (design) phase of a project, accounting for all lifecycle phases. Decisions taken at this point can significantly influence whether a project is delivered in a way that secures health and safety throughout the project’s full lifecycle.
RR1198 was commissioned by the HSE to broaden understanding of how the PD role is working in practice. Information provided by survey respondents and stakeholder organisations was used to gain greater insight about those undertaking the PD role, their activities and influence on health and safety. The research also considered the extent to which PDs are meeting their CDM 2015 responsibilities and the underlying reasons for this.
KEY FINDINGS OF THE RESEARCH
1. Breaking tradition – establishing the PD role
An important but not surprising finding in RR1198 is that the PD role does not fit easily into construction projects. The construction industry has been around for centuries and has many established customs and practices. Conversely, the PD is an artificial construct introduced in 2015 that did not exist within traditional construction sector contractual arrangements.
This has led to difficulties in establishing the position of the PD in project structures. Striking the balance between independence from the designers and contractors, whilst maintaining sufficient oversight and authority over the design process to guide a risk-based approach, has proven to be a significant challenge. Consequently, the PD may fail to discharge its duties under CDM 2015 and not contribute in a valuable way.
2. Early engagement
The report highlights the importance of appointing the PD at an early stage in a project and into a position to drive effective risk management of the design.
Early appointment helps to embed the PD into the project structure, improves their knowledge of the project and introduces the principles of risk-based design and decision making from the start. Figure 1 illustrates how through-life project risk profiles can be significantly reduced by early risk-based design decisions.
Figure 1: Lifecycle opportunities for risk reduction
3. Uniting organisational delivery and individual diligence
A key theme to emerge from the research is that, when done properly, the PD role is significant and the breadth of skills, knowledge and experience required is wide-ranging. Notably, skills, knowledge and experience alone are recognised as insufficient without authority and resources. As such, the role cannot realistically be covered by one individual. That said, the research report highlights the importance of the diligence, persuasiveness, conscientiousness and leadership from the individuals discharging the role.
4. Charting the course – defining and documenting the PD strategy
Less than half of respondents had a documented design risk management system. Additionally, there is a varying degree to which twenty activities required of the PD are performed. As a result, CDM 2015 is inconsistently applied with legal duties not all being met, exposing clients and people to unnecessary risk.
The report also identifies a general issue with recording design decisions and risk. This is amplified if the PD role changes hands, introducing problems due to inadequate handovers. Good design decision record-keeping, which is traceable to risk assessments and risk register management, is essential to demonstrate the principles of safe by design have been met. A meaningful health and safety file cannot be constructed without this information – agreeing on its format and structure early on is important.
A robust and thorough strategy or process is needed to enable and manage the PD’s activities. The PD strategy should establish the project’s systematic design risk management and safety assurance processes, together with how tangible deliverables, such as the design decision log and risk register, will be managed and reported.
One approach used in some other energy sectors is a Claims Arguments Evidence (CAE) process, which allows a client to clearly demonstrate that they and the PD have discharged their duties under CDM 2015. This approach provides evidence that the principles of prevention have been followed and, as far as reasonably practicable, the project is safe by design.
5. Navigating communication
There is no doubt that effective communication is crucial for the PD role. The report highlights that the PD role improves coordination and communication between teams and duty holders, enhancing awareness and understanding of design risk and project information.
When agreed and endorsed by the client, the PD strategy promotes communication, by providing the terms of reference and authority for the PD to all project stakeholders, and establishing lines of communication and management arrangements for the PD’s integration into the project’s design environment.
WHAT CAN ENERGY TRANSITION PROJECTS LEARN?
As a relatively young industrial movement, the customs and practices of energy transition projects are less entrenched as traditional construction. This creates the opportunity for project execution models that utilise the PD to lead effective design risk management, enabling risk-based design decisions and extracting maximum value from the role.
The PD needs to be appointed early in project lifecycles to a position that provides clear lines of communication with the client, designers and contractors, as well as oversight of the design process. The PD not only requires skills, knowledge and experience, but also needs to nurture a project culture that encourages a proactive, safe by design approach.
PD organisations not individuals suit energy transition projects, due to the breadth of engineering disciplines and lifecycle phases. Establishing long term relationships between the PD organisation and the client project is paramount for seamless risk communication.
Maintaining knowledge through a project’s life is important. A structured approach like CAE captures and disseminates risk information, enabling the demonstration that risks have been reduced to as low as is reasonably practicable throughout the lifecycle.
CONCLUSION
The HSE research provides some timely insights for energy transition projects to deliver the full value of the PD role. By understanding the importance of the PD role as a critical enabler of successful projects, clients can maximise the value potential as informed “intelligent customers”. The alternative is increased likelihood of regulatory intervention, delaying projects and increasing costs, at a time when society demands both an acceleration of the energy transition and a lower cost of energy.
