When the PC Is on Site the Client's CDM Duties Remain
- Paul Scanlon
- Jul 30
- 1 min read
When the Principal Contractor is on site, many clients assume their CDM exposure is covered.
It is not.
The PC owns the construction phase. Regulations 12 to 14 place on them the duty to plan, manage, monitor and coordinate health and safety during construction. That is a significant set of obligations.
But the client's parallel duties do not evaporate when the PC takes over.
As the construction phase progresses, the client must still:
Maintain the management arrangements that were in place at the start of the project
Ensure welfare facilities remain adequate as the project evolves
Continue to engage with the Principal Designer on the Health and Safety File
Remain available and engaged if the PC identifies issues requiring client-level decisions
Many clients disengage from CDM management once work starts on site. They assume the PC is now "in charge of health and safety" and no further input is required from the client.
But the client remains responsible for the project-level management framework.
If something goes wrong due to inadequate management arrangements, HSE will look at what the client did — not just what the PC did. Client disengagement during the construction phase is not a defence.
That is not a theoretical risk. There are prosecutions on record that prove it.
Get your free Client Guide to CDM 2015 here: cdm2015.co.uk/resource-download
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