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Using the Same Contractor Does Not Mean Competence Is Checked

You have used the same contractor for three projects. You trust them. You know their team.

Under CDM 2015, that is not the same as having checked their competence for this project.

Regulation 8 requires duty holders to take reasonable steps to verify competence at the point of appointment — on each project, not once across all projects. A competence assessment from a previous appointment does not carry forward automatically.

Circumstances change between projects. Key individuals move on. Subcontractor relationships change. Workload increases. The management structures that existed on your last project may not be in place for this one.

The HSE is clear that competence checking must be proportionate and project-specific. Clients who rely on an approved supplier list without refreshing their assessment for each appointment are not fully discharging their Reg 8 duty.

What does proportionate checking look like in practice?

It means reviewing the contractor's specific experience in projects of this type and scale. It means asking about the project team — not just the company. It means understanding whether their current workload allows them to resource your project properly.

This does not need to be an enormous exercise. But it needs to be a genuine one.

If your contractor appointment process has not been refreshed recently, we can help you build a proportionate approach that satisfies Reg 8 without creating unnecessary administrative burden.

Get your free Client Guide to CDM 2015 here: cdm2015.co.uk/resource-download

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