The designer's risk assessment
A working guide to regulation 9 of CDM 2015: who counts as a designer, what the duties are, what a useful register records, and how to keep it short enough that the risks that matter are actually read.
What is a designer's risk assessment?
A designer's risk assessment is the record a designer keeps of the significant health and safety risks in their design, what they did to eliminate or reduce them, and what information they passed on about the risks that remain. It is how a designer shows they have met regulation 9 of the Construction (Design and Management) Regulations 2015, and it should focus on significant and unusual risks rather than every obvious construction hazard.
CDM 2015 does not actually require a document called a "designer's risk assessment" or "design risk register". It requires designers to think about risk while designing and to pass on information. A register is simply the most practical way to do that and to evidence it. The duties apply to domestic projects too; on a small job the information may be short and can often sit as notes on drawings.
Who counts as a designer?
Regulation 2(1) defines a designer as any person who, in the course or furtherance of a business, prepares or modifies a design, or arranges for or instructs people under their control to do so. "Design" includes drawings, design details, specifications, bills of quantities and calculations.
That captures architects and technologists, but also structural and services engineers, interior designers, quantity surveyors who specify, and contractors or specialists who carry out design. HSE's guidance notes that clients can be designers too if they get actively involved in design decisions.
What regulation 9 requires designers to do
Regulation 9 sets out four duties. The register is mainly evidence for the second and third.
- 9(1)
Client awareness
Do not start work unless satisfied the client knows its CDM duties. Routine early meetings will do, matched to the client's experience.
Before starting - 9(2)
Eliminate
Use the general principles of prevention and pre-construction information to eliminate foreseeable risks, so far as reasonably practicable.
While designing - 9(3)
Reduce, control, inform
Reduce or control what remains, tell the principal designer, and make sure the health and safety file has what it needs.
Residual risks - 9(4)
Design information
Provide enough information with the design to help clients, other designers and contractors meet their duties.
With the design
The order matters: eliminate first, reduce or control second, inform about whatever is left. People at risk are those building, maintaining or cleaning the structure, or using it as a workplace.
The general principles of prevention are those in Schedule 1 to the Management of Health and Safety at Work Regulations 1999: avoid risks, evaluate those that cannot be avoided, combat risks at source, and so on. HSE's L153 guidance says client awareness can be dealt with in routine early meetings.
What should a designer's risk assessment include?
For each significant risk, a useful register records where it is, who is affected, what the design did about it, what remains, and who needs to know.
- Reference and location
- So it can be found on drawings or in the model.
- Hazard and who is at risk
- Construction workers, maintenance and cleaning staff, or people using the building as a workplace.
- Design decision taken
- What was eliminated or reduced, and how.
- Residual risk
- What remains after design changes, described specifically.
- Information for others
- What the contractor, other designers or the facilities manager need to know, and where it is recorded: drawing note, specification clause or model data.
- Owner and status
- Who is responsible and whether the item is open, closed or passed on.
- Health and safety file
- Whether the item needs to go into the file at handover.
- Revision and date
- When the entry was last reviewed.
L153 para 87 notes that key information can be put on drawings or within models, including through BIM. The register does not have to duplicate it; it should point to where the information lives.
How to keep it proportionate
This is where most registers fail. HSE's guidance is clear that detail should match the risks that remain, and that listing insignificant risks is not an effective way to alert anyone.
- Insignificant risks can usually be ignored unless the design makes routine construction risks worse or significantly different (L153, para 84).
- Identifying insignificant risks is not an effective way to alert other dutyholders; designers should demonstrate they have addressed the significant ones (para 102).
- Information should focus on unusual or complex risks that contractors are more likely to miss or misunderstand (para 104(c)).
An entry for access to a specific high-level rooflight is useful; "working at height, use suitable access" is not. A long list of generic entries buries the risks that matter.
A register that lists every hazard tells the contractor nothing they did not already know.
Risks that typically do belong
- Heavy or awkward components that need a specific installation sequence.
- Temporary stability issues created by the structural design.
- Unusual ground conditions, contamination or existing services found in surveys.
- Proximity to railways, live highways, overhead lines or occupied buildings.
- Access for maintaining or cleaning high-level glazing, rooflights or plant.
- Fragile roof materials.
- Hazardous materials in existing buildings, such as asbestos identified in surveys.
- Confined spaces created by the design.
An example designer's risk register
Four entries from a mixed new-build and refurbishment project. Each is specific to this design and tells someone something they need to act on.
| Ref | Location · hazard | Design action | Residual risk and information | Owner | Status |
|---|---|---|---|---|---|
| DR-01 | Atrium rooflight, level 5. Cleaning and maintaining glazing 14m above atrium floor (maintenance staff) | Self-cleaning glass; parapet-level edge protection and anchor points; inner pane accessed from walkway | Periodic inspection still needed; access strategy on A-500 and clause L10/120. Include in H&S file | Architect | PASSED TO PD |
| DR-02 | Basement retaining wall. Temporary instability during excavation next to party wall (workers, neighbours) | Sequence revised to hit-and-miss underpinning | Contractor to follow sequence on S-201; temporary works design required | Structural engineer | OPEN |
| DR-03 | Plant room, roof. Lifting 1.8 tonne AHU onto roof (workers, public) | Plant relocated to rear to avoid lifting over street | Crane lift still required; lift zone on A-110; road closure likely | Services engineer | PASSED TO PD |
| DR-04 | Existing ground floor. Asbestos insulating board in refurbishment survey (strip-out operatives) | Layout changed to avoid disturbing ceiling void in G04 to G06 | Licensed removal still needed in G07; survey ref in pre-construction information | Client / PD | OPEN |
Note what is missing: nothing for slips, trips, dust or working at height. Each row points to the drawing or clause where the detail lives rather than repeating it.
The designer's register deals with risks that can be removed or reduced through design decisions, and information about residual risks. The contractor's risk assessments and method statements deal with how the work will be carried out safely on site. They should connect, but they are not the same document.
Where Avoice fits
Most design risk registers are spreadsheets that grow generic over time and drift away from the drawings they describe.
The CDM Designer's Risk Register in Avoice's Compliance module records significant risks against drawings and specification clauses, with owners, status and a flag for health and safety file items. It is structured to keep entries specific rather than generic, and it can be shared with the principal designer. Principal Designer tooling is coming to the same module.
Software can structure and flag. The designer still decides what is significant and what can be eliminated, and the principal designer still coordinates.
Keep a design risk register that stays specific
Record significant risks against drawings and specification clauses, track owners and status, flag health and safety file items and share with the principal designer.
This guide is for general education and is not professional advice. Check CDM 2015 and HSE's L153 guidance for the duties that apply to your role on a specific project.