Regulation 4: What Suitable Arrangements Actually Means
- Paul Scanlon
- Jul 30
- 1 min read
Regulation 4 of CDM 2015 is four paragraphs long. Most clients have never read it.
Those four paragraphs create the entire framework of client duty under the regulations. And they are more demanding — and more specific — than most clients realise.
The regulation requires commercial clients to make and maintain "suitable arrangements" for managing the project. "Suitable" is defined by the HSE as proportionate to the size, complexity, and risk profile of the project.
Suitable arrangements include:
Appointing competent duty holders at the right time
Allocating sufficient time at each project stage for duties to be properly discharged
Providing adequate resources for health and safety management
Maintaining oversight throughout the project lifecycle — not just at the start
The word "maintain" is important. Regulation 4 is not a one-time checklist. The obligation continues throughout the project. A client who appoints a Principal Designer, issues pre-construction information, and then disengages has not maintained suitable arrangements.
HSE inspectors look for evidence that clients understood and actively discharged their Reg 4 duties. A signed appointment letter alone is not sufficient evidence. Active, documented engagement throughout the project is.
If you want to understand what "suitable arrangements" looks like in practice for your specific project, get in touch.
Get your free Client Guide to CDM 2015 here: cdm2015.co.uk/resource-download
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