"Our CDM Coordinator is handling it."
If someone on your project team holds that title, there is something important you need to know.
The CDM Coordinator role was abolished when CDM 2015 came into force on 6 April 2015. It no longer exists as a legal role under the current regulations.
Under the old CDM 2007 regime, the CDMC sat between the client and the project team and took on a coordination function that partially absorbed client-side risk. That structure was deliberately removed when the regulations were revised.
Under CDM 2015, the equivalent pre-construction coordination function sits with the Principal Designer — a duty holder appointed in writing by the client under Regulation 5, with specific legal obligations under Regulations 11 and 12.
A "CDM Coordinator" who has not been formally appointed as Principal Designer under Reg 5 holds no legal function under CDM 2015. They may be providing useful advisory services. But they are not a duty holder. And their involvement does not reduce the client's direct obligations.
This creates two practical risks. First, the client may believe their obligations have been discharged when they have not. Second, the pre-construction coordination role required by Reg 11 may not be being performed by anyone.
If someone on your project is still using the title CDM Coordinator, ask when the Principal Designer was appointed in writing under Regulation 5.
The answer will tell you a great deal.
Get your free Client Guide to CDM 2015 here: cdm2015.co.uk/resource-download
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