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When a business commissions industrial or commercial roof work, it can become the commercial client under the Construction (Design and Management) Regulations 2015, commonly called CDM 2015. The client role is not limited to signing a quotation or appointing a roofing contractor. The commercial client influences how the project is planned, resourced and managed, and has specific duties that begin during the earliest planning stage.
This matters for roof replacement, refurbishment and many repair projects because roof work can involve work at height, fragile surfaces, access systems, scaffolding, plant, rooflights, penetrations and occupied buildings. A project that looks straightforward commercially can involve several contractors or design decisions once access, temporary works, electrical isolation, drainage, rooflights or rooftop equipment are included.
The safest approach is to establish the CDM structure before procurement is finalised. The HSE commercial client guidance confirms that commercial clients must make suitable arrangements for managing their projects, provide relevant information, allow sufficient time and resources and make the required appointments.
This guide explains the commercial client’s CDM responsibilities in the context of industrial and commercial roof work. It is not legal advice and does not determine the correct dutyholder structure for every contract or project. Complex projects, unusual contractual arrangements, higher-risk buildings, specialist structural work or disputed responsibilities may require project-specific professional advice.
It also does not replace the work of the principal designer, principal contractor, contractor, designer or other competent specialists. The client is responsible for making and reviewing suitable arrangements, but that does not mean the client should personally design access systems, write contractor method statements or make technical judgements outside their competence.
Pause before work starts if nobody can clearly identify the commercial client, the contractor structure or who is controlling the pre-construction and construction phases. The same applies if more than one contractor is likely to be involved, but principal designer or principal contractor appointments have not been considered.
For roof projects, also pause if the project team does not have reliable information about roof access, fragile areas, rooflights, previous asbestos information, plant and services, structural concerns or known defects that could affect the work. HSE guidance says roofs should be treated as fragile until a competent person confirms otherwise. A useful client brief should therefore explain what is known, what is uncertain and what must be verified rather than assuming the roof is safe to access.
A commercial client is an individual or organisation having construction work carried out in connection with a business. That can include a company occupying its own premises, a landlord, a developer, a public body, an organisation managing property or another business commissioning roof work.
The person who contacts the roofing contractor is not necessarily the legal client as an individual. The client is normally the organisation or person for whom the project is being carried out. On larger estates, a facilities manager or project manager may administer the work on behalf of that organisation, but the organisation’s client responsibilities still need to be addressed through the project arrangements.
HSE makes an important distinction here: commercial clients do not need to be construction experts. They do, however, need to make suitable arrangements and appoint people with the skills, knowledge, experience and organisational capability required for their roles. That is why a strong client-side process focuses on defining the project, selecting the right team, providing information and checking that the management arrangements remain effective.
The client should decide how the project will be managed before the construction phase begins. For a roof project, that means more than setting a budget and target date. The arrangements should allow the people doing the work to manage health and safety risks in a proportionate way.
Practical questions include who is coordinating design information, who controls the construction phase, how access will be arranged, how occupied areas will be protected, what shutdowns may be required, how emergency arrangements will work and how information will move between the client, designers and contractors.
Programme pressure can create poor decisions if surveys, access planning, design coordination or procurement are compressed to meet an unrealistic start date. The client should allow enough time for the project team to inspect the roof, understand risks, prepare design information, plan the construction phase and organise welfare and access.
This does not mean every roof repair needs a long design programme. CDM arrangements should be proportionate. It does mean the project should not be forced into an unsafe or poorly defined sequence simply because the client has committed to a start date before the work has been properly scoped.
The commercial client must make sure the people appointed have the appropriate capability for the work they will carry out. On an industrial roof project, that can include experience with the roof system, work at height, occupied premises, fragile materials, access constraints and any specialist elements included in the scope.
Capability checking should be relevant to the project rather than reduced to collecting generic certificates. A contractor suitable for a straightforward low-risk repair may not automatically be the right organisation to control a complex live-site refurbishment involving several specialist trades.
A single-contractor project does not require principal designer and principal contractor appointments simply because CDM applies. The contractor still has duties, and a construction phase plan must be prepared before the construction phase begins.
The client should be careful when deciding that a project really has only one contractor. A roof contractor may need separate scaffolding, electrical, mechanical, lifting or specialist access work. If other contractors will be involved in the project, including through subcontracting arrangements, the client should consider the multi-contractor requirements rather than relying on the headline roofing contract alone.
Where a project involves, or is likely to involve, more than one contractor, the client must appoint a principal designer and principal contractor. The principal designer controls the pre-construction phase from a health and safety coordination perspective, while the principal contractor controls the construction phase.
The client should make these appointments clearly and early enough for the dutyholders to influence the project. Appointing a principal designer after the important design and procurement decisions have already been made weakens the purpose of the role. Likewise, the principal contractor needs enough information and time to plan the construction phase properly.
The commercial client must provide pre-construction information to designers and contractors who are bidding for or already appointed to the project. For roof work, this is one of the most useful ways to improve both safety and quotation quality because it reduces the number of important issues left to assumption.
Relevant roof-project information may include existing drawings, roof build-up information, previous survey reports, asbestos information, known fragile areas, rooflight details, access arrangements, plant and services, leak history, previous repairs, drainage information, occupancy constraints, vehicle or pedestrian routes, emergency arrangements and known structural concerns.
The information should be proportionate to the project. A small local repair will not need the same information package as a full warehouse roof refurbishment, but the client should still identify the risks and site information that could materially change how the work is priced or carried out.
A commercial roof condition survey can help close important information gaps where the roof’s current condition or build-up is uncertain. For larger procurement exercises, the existing industrial roofing tender pack checklist can then help organise that information into a more comparable scope for bidders.
Roof access is often treated as a contractor issue that will be solved after appointment. That can be a mistake. Access can influence design, programme, temporary works, site segregation, cost and the number of contractors involved.
The client should provide known access information and make clear where assumptions remain. That may include fixed access systems, fragile surfaces, rooflights, edge protection, internal access restrictions, loading areas, crane or lifting constraints and the relationship between roof work and people using the building below.
If safe access cannot be established from the available information, the project should pause until the required assessment is completed. The commercial roof access strategy guide provides a separate framework for planning access before surveys, cleaning, inspections or repair work begins.
The client must ensure that a construction phase plan is prepared before the construction phase begins. On a single-contractor project, the contractor prepares it. On a project involving more than one contractor, the principal contractor prepares it.
The client does not normally write the contractor’s construction phase plan. The client should, however, make sure the required plan exists before work starts and that the project arrangements allow the responsible contractor to prepare something proportionate to the work.
For industrial roofing, the plan may need to address work at height, fragile surfaces, access, weather, lifting operations, site segregation, occupied areas, temporary protection, plant, deliveries and coordination with other trades. The exact content should reflect the real project rather than a generic template copied from unrelated work.
HSE states that contractors are required to provide welfare facilities and commercial clients must make sure suitable arrangements are in place. This applies to construction work generally and should be considered early enough that facilities can be available from the start of the work.
On a roof project at an occupied commercial site, the client and contractor may need to agree whether existing facilities can be used, whether temporary welfare is required and how workers will access those facilities without creating conflicts with staff, customers, pupils, patients or other building users.
This is a good example of the difference between the client’s role and the contractor’s role. The contractor provides and manages the welfare arrangements under its control. The commercial client checks that appropriate arrangements have been made rather than assuming the issue belongs entirely to the contractor.
Not every CDM project is notifiable. HSE’s current threshold is based on project duration and labour. A project is notifiable if the construction work is expected to last more than 30 working days and have more than 20 workers working at the same time at any point, or if it is expected to exceed 500 person-days.
The client has the duty to notify HSE for a notifiable project, although HSE states that the client may ask someone else to submit the notification on its behalf. The important distinction is that notification is an additional requirement for qualifying projects. CDM client duties still apply to commercial construction projects that fall below the notification threshold.
The HSE CDM frequently asked questions should be checked where project duration, worker numbers or notification responsibility are uncertain.
A practical way to control the project is to use a simple readiness gate before authorising mobilisation. The purpose is not to duplicate the contractor’s risk assessments or method statements. It is to check whether the client-side conditions needed for the project to be managed properly are in place.
Pause mobilisation if any item that affects legal appointments, safe access or significant project risk is unresolved. The purpose of the readiness check is to stop uncertainty moving from the planning stage onto the roof.
Assuming the roofing contractor takes over every CDM duty. Contractors have substantial duties, but the commercial client still has its own responsibilities for project arrangements, appointments, information, time, resources and oversight.
Deciding the project is single-contractor too early. Separate access, scaffolding, electrical, mechanical or other specialist work can change the dutyholder structure. The project should be assessed based on the contractors actually likely to be involved.
Requesting prices before issuing important roof information. If bidders do not receive the same information about condition, access, asbestos, plant or occupancy, quotations may contain different assumptions and may not be genuinely comparable.
Treating the construction phase plan as paperwork to collect after mobilisation. The plan must be prepared before the construction phase starts. The client should make that a pre-start condition.
Confusing HSE notification with CDM applicability. A project can be below the notification threshold and still be subject to CDM duties. Notification is not the test for whether commercial client duties exist.
Failing to review arrangements when the scope changes. An apparently simple repair can expand after investigation. If the contractor structure, design work, access method or project risks change, the management arrangements should be reviewed rather than left as originally assumed.
Commercial client duties do not simply disappear when the roofing contractor leaves site. HSE states that client duties start from the beginning of the project and continue to the end and beyond in relation to later use and maintenance.
For projects involving more than one contractor, the client must ensure the principal designer prepares the health and safety file and that it is revised as necessary. The file should provide relevant information needed to help future construction work on the building be planned and carried out safely.
For a roof project, useful handover information can include the final roof build-up, access arrangements, fragile areas, rooflight information, installed safety systems, residual risks, drawings, significant materials and details relevant to later inspection, maintenance or alteration. The exact contents depend on the project and should be managed by the appropriate dutyholders.
That information also supports future asset management. Once the project is complete, planned inspections and ongoing industrial roof maintenance support can be organised with a clearer understanding of the roof that was installed or refurbished and the access conditions that apply.
Before commissioning industrial or commercial roof work, define the client-side project structure first. Confirm who the client is, whether one or multiple contractors are likely to be involved, which appointments are required and what information must be assembled before tender or mobilisation.
Provide potential contractors with a clear brief covering the roof scope, known condition, access, occupancy, site restrictions, asbestos information, services, programme and any known design requirements. Where key information is missing, identify the gap and decide who will investigate it rather than asking contractors to price an unknown condition differently.
A good quotation or survey proposal should make its assumptions visible. It should explain the proposed scope, information required, access approach, exclusions and any further investigation needed before work can be finalised. On multi-contractor work, the CDM appointments and information flow should be established early enough for the principal designer and principal contractor to perform their roles properly.
If you are preparing a commercial roof project and need the roofing scope or existing condition clarified before procurement, you can send the project details to Industrial Roofing Services so the appropriate survey or roofing service can be discussed.
CDM 2015 gives the commercial client an active role in how industrial and commercial roof projects are set up and managed. The client must make suitable arrangements, appoint capable people, allow sufficient time and resources, provide relevant pre-construction information and make sure the required construction phase planning is in place.
The most important early decision is whether the project involves one contractor or more than one, because multi-contractor work requires principal designer and principal contractor appointments. Roof-specific risks such as fragile surfaces, access, asbestos information, plant and occupied areas should be identified before they become assumptions in a quotation or problems during mobilisation.
The client does not need to become the roofing designer or site manager. The client’s job is to create the conditions in which the appointed dutyholders can manage the project properly, then review those arrangements as the project develops.
Commercial client duties are not limited to large or notifiable projects. The arrangements should be proportionate to the size, complexity and risks of the work. The specific application to maintenance activities can depend on the nature of the work, so borderline cases should be checked against current HSE guidance.
A principal designer is required where the project involves, or is likely to involve, more than one contractor. A genuinely single-contractor project does not require that appointment under the same rule, although other CDM duties still apply.
If the project involves more than one contractor, the client should apply the multi-contractor requirements. Subcontracting can therefore affect the dutyholder structure even where the client has placed one main roofing contract.
For a project involving more than one contractor, the principal contractor prepares the construction phase plan. For a single-contractor project, the contractor prepares it. The commercial client must ensure the plan is prepared before the construction phase begins.
No. Notification depends on the HSE thresholds for duration, simultaneous worker numbers or total person-days. Commercial client CDM duties can still apply when a project is below those notification thresholds.
Provide information that is relevant and proportionate to the project, such as roof build-up, existing surveys, asbestos information, access, fragile areas, services, plant, previous repairs, occupancy restrictions and known structural or drainage issues.
No. The contractor has its own duties, but the commercial client still needs to make and review suitable project arrangements, make required appointments, provide relevant information and ensure key planning requirements are in place.
