Does CDM Apply To Refurbishment?

One of the questions we often get asked regarding CDM 2015 is, does CDM apply to refurbishment projects?

The simple answer is, yes. The CDM regulations apply to all construction projects, including refurbishment projects. If you are planning work on a refurbishment project, everyone on the team needs to know about CDM and carry out their duties.

CDM is a legal requirement.

CDM applies to all refurbishment projects

But what if the refurbishment project is really small, just lasting a week for example? Does CDM apply then? Yes, it does. CDM applies to all construction work and projects, no matter the size or duration.

And what if only one person is working on the refurbishment project, will CDM still apply then? Yes. CDM applies to all construction projects including single contractor projects.

What if the refurbishment project is being done on someone's house? Does CDM still apply? Yes, it does. CDM applies to residential work and projects with domestic clients.

It may surprise you to know that the refurbishment project doesn't even have to involve any structural changes for CDM to apply. All the time, in every circumstance, CDM will apply to any refurbishment project, big or small, domestic or commercial.

Refurbishment work is construction work

CDM stands for the Construction (Design and Management) Regulations, and as the name suggests, they apply to all construction work.

And refurbishment work is construction work.

The latest version of the regulations came out in 2015, and so are often abbreviated to CDM 2015. The regulations also (helpfully) define what is classed as construction work.

Let's take a look at the first part of the definition of construction work under CDM 2015.

“construction work” means the carrying out of any building, civil engineering or engineering construction work and includes—

1. the construction, alteration, conversion, fitting out, commissioning, renovation, repair, upkeep, redecoration or other maintenance (including cleaning which involves the use of water or an abrasive at high pressure, or the use of corrosive or toxic substances), de-commissioning, demolition or dismantling of a structure;

Any type of upkeep, repair, redecoration or maintenance to a structure is included in the definition of construction work under CDM.

And a structure includes any building, and any other structure from a harbour to a tramway line, and includes river works, earthworks and pipes.

So, whatever you are refurbishing, CDM applies to your project.

CDM duties for refurbishment

From a CDM point of view, refurbishment projects are not treated any differently than any other type of project.

The same CDM duties apply to refurbishment as would on a new build or demolition project.

There are just as many health and safety risks involved with refurbishment work as there are in other types of work. Perhaps even more, since you could be dealing with many unknowns regarding the existing structure, materials and services.

Just like any construction project, the team will need to work together to carry out the work safely and without risk to health.

Everyone involved in the project must be familiar with the hazards involved in refurbishment work so that they can navigate the risks and comply with CDM.

Every designer working on the refurbishment project will have designer duties under CDM. And every contractor working on the refurbishment project will have contractor duties. And clients have CDM duties too.

The client will need to select one contractor as the principal contractor (if there is more than one contractor). The principal contractor will have overall control of the site, health and safety, and be responsible for producing the construction phase plan. If there is only one contractor, they will have those responsibilities.

Find out more about the principal contractor role and duties in our free CDM duty holder guide for principal contractors.

Where the client has appointed a principal contractor, they will also need to appoint a principal designer. The principal designer will assist the client with the CDM client duties, help with the development of the pre-construction information at the start of the project, and produce the health and safety file for project completion.

Find out more about the principal designer role and duties in our free CDM duty holder guide for principal designers.

There are only a couple of ways that how CDM applies to your refurbishment project may differ:

• Domestic projects
• Non-notifiable projects

Domestic refurbishment projects

If the client is a domestic client, which is someone having work done on their own home and not connected with any business, then some of the CDM client duties pass to other members of the project team.

And some of the appointments, like the principal contractor and principal designer, can happen automatically.

This doesn't just apply to refurbishment work - you can get domestic clients in any type of construction work, but it's perhaps more common on refurbishment projects when people have work done on their homes.

Need help understanding how CDM applies to domestic projects? Read CDM 2015 Domestic Clients And Work On Residential Projects to find out more.

Non-notifiable refurbishment projects

On short projects, with few people involved, the project may be classed as non-notifiable.

If your project is below the CDM notification threshold, then you will not need to notify the HSE.

Again this doesn't just apply to refurbishment work. Other types of construction work can also be non-notifiable if they fall under the notification thresholds, but smaller projects often involve refurbishment work rather than new builds which usually take longer.

Even if your project is non-notifiable, it doesn't change any of the other CDM requirements. CDM still applies, and all the other duties must be discharged.

Want to calculate if your project is CDM notifiable? Use the free CDM notification calculator to check today.

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The CDM regulations apply to all construction work, in all settings. This includes refurbishment projects.

CDM prosecutions do happen, and they can be substantial, so before you start refurbishment work, make sure you are aware of your duties under CDM and comply with them.

If you need help complying with CDM duties, get our free CDM duty holder guides for more support. And check if your project is CDM-ready with the free CDM compliance checklist.