CDM 2015: Understanding the Significance of Domestic Clients: A Comprehensive Overview

In April 2015, with the onset of the third iteration of CDM Regulations, a new term emerged – “domestic client”. This introduction marked a pivotal point, extending the roles and responsibilities of CDM duty holders to encompass projects undertaken within our residential spaces, distinct from the traditional commercial or business settings.

You might naturally question the rationale behind this shift, unless you’re already familiar with it.

It’s understandable to assume that this segment of the construction landscape, involving minor tasks and domestic trades like painters, decorators painting a bedroom, or plumbers installing modern bathrooms, could raise concerns for the Health and Safety Executive (HSE). One might even anticipate a higher rate of incidents or accidents, prompting the need for legislative control, but that’s not the case here.

In the realm of the construction sector, financial considerations play a pivotal role, often dictating decisions. There lies an opportunity to tap into a fresh stream of revenue from the DIY and domestic market.

The challenge of implementing CDM within the domestic market revolves around convincing individuals, largely unaware of its existence, about the added cost of compliance. This additional financial burden isn’t always well-received.

Moreover, for contractors whose primary focus is small-scale domestic projects, investing time in crafting CDM construction phase plans, method statements, and risk assessments isn’t a high priority. Their client base generally doesn’t express keen interest in these aspects.

Consequently, integrating CDM practices, even in a limited capacity, can prove pivotal in clinching a contract or losing it. Naturally, there’s always a presence of more budget-friendly alternatives, yet incorporating CDM within a domestic setting could potentially introduce an approximate 10% increase to the overall project cost.

Domestic projects primarily involve a single trade, and their nature tends to be low-risk. This rarely falls under the category of notifiable projects, which effectively keeps it off the Health and Safety Executive’s (HSE) radar.

Principal Contractor – My Perspective

Through our direct involvement in various domestic projects, we’ve gained firsthand insights into the gap between the theoretical ideals of best practice and the practical realities on the ground and how it is actually being done.

In the realm of small-scale domestic endeavours, especially those involving the coordination of two or more independent trades, a clear pattern emerges: none of these trades are inclined to shoulder the mantle of the Principal Contractor. The legal liabilities inherent in this role are evident, and most likely, they lack the necessary insurance coverage for such a responsibility.

Frequently, the selection of these trades happens in isolation, driven by the preferences of the domestic client. Consequently, they are not costed to account for the added responsibilities of a Principal Contractor.

The rationale behind introducing the Domestic client concept in CDM 2015, as articulated by the Health and Safety Executive (HSE), rests on aligning with the EU Directive that originally underpinned CDM regulations.

Not the strongest or most convincing arguement. Especially when you consider the UK’s departure from the EU.

For the vast majority – potentially as high as 90% – of domestic clients, the justification for and benefits of CDM implementation remain hard to see, and from what I have seen out in the field, its simply not being applied.

To achieve meaningful impact, a focused approach seems warranted. CDM could potentially find its effectiveness in areas of elevated risk or projects that surpass a certain financial threshold, such as £100,000, for instance.