I Didn't Know I Had Any CDM Duties
- Paul Scanlon
- Jul 30
- 1 min read
"I didn't know I had any CDM duties."
We hear it on almost every first call with a new client.
If you commission construction work, CDM 2015 makes you a duty holder. There is no opt-out.
That includes routine maintenance, a refurbishment, an office fit-out, or a single contractor replacing a roof.
Regulation 4 places legal duties on the commercial client the moment work is commissioned — not when the build gets "big enough."
You must make suitable arrangements for managing the project, appoint competent duty holders, and provide the information they need to work safely.
Not knowing you hold these duties is not a defence. The HSE treats the client as the duty holder regardless of awareness.
The clients who get caught out are rarely running major schemes. They are the ones who assumed CDM only applied to someone else.
If you commission any construction work and have never been told you are a duty holder, that is the gap worth closing first.
Get your free Client Guide to CDM 2015 here: cdm2015.co.uk/resource-download
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