What the law says
Designer duties under CDM Regulation 9
CDM 2015 places clear obligations on every designer involved in a construction project — architects, structural engineers, mechanical and electrical consultants, interior designers, and anyone else who prepares or modifies a design.
Reg 9 requires designers to: when preparing or modifying designs, eliminate, reduce or control foreseeable risks that may arise during construction, maintenance, use and eventual demolition — and communicate residual risks to those who need to know about them.
The key point is that this is a design-stage duty. It's not something you delegate to the contractor. Decisions made on the drawing board directly affect how safely a building can be constructed, used, and maintained — and the law recognises that.
The process
How designer risk assessment works in practice
Designer risk assessment (DRA) isn't a one-off exercise — it runs alongside the design from concept to tender. Here's how the process flows:
1
Identify foreseeable risks
Consider hazards arising from the design at every stage — construction, maintenance, use, and demolition.
2
Apply the hierarchy
First, eliminate. If you can't, reduce. If risk remains, control it and pass information on.
3
Record significant risks
Log risks that couldn't be eliminated in a Designer Risk Register — your evidence of compliance.
4
Share with the team
Co-ordinate with other designers and the Principal Designer. Pass residual risks into the Pre-Construction Information.
5
Review at each RIBA stage
Update the DRA as the design develops. A final review at tender is essential before work starts on site.
The DRA should be updated at each RIBA design stage — particularly Stage 2, Stage 3, and Stage 4. Review again following any significant design change.
0Strategic
Definition
Definition
1Preparation
& Brief
& Brief
2Concept
DesignDRA starts ✓
DesignDRA starts ✓
3Spatial
CoordinationUpdate ✓
CoordinationUpdate ✓
4Technical
DesignUpdate ✓
DesignUpdate ✓
5Mfg &
ConstructionFinal review ✓
ConstructionFinal review ✓
6Handover
What to record
What designers should be capturing in their risk register
Many designers ask us what actually needs to go in a Designer Risk Register. The answer is: anything that couldn't be designed out, and that someone downstream needs to know about.
The hazard and its source — structural complexity, temporary works requirements, restricted maintenance access, materials or substances involved.
Who is at risk — construction workers, maintenance operatives, the public, building users, or a combination. Our template captures these against each entry.
Initial risk score (before design measures) — High, Medium, or Low. Documents the starting point and shows what work the design has done.
Design measures taken — what the designer changed, specified, or detailed to eliminate or reduce the risk. This is the core of Regulation 9 compliance.
Residual risk score (after design measures) — what risk remains. If it's still High or Medium, it must be passed to the Principal Designer for inclusion in the Pre-Construction Information.
Responsible originator and design stage — who raised the risk, and at which RIBA stage. Essential for multi-disciplinary projects.
Whether the risk passes to construction or remains in use — maintenance access risks are ongoing and must appear in the Health & Safety File.
Our template
Safety CDM Ltd Designer Risk Register
We've developed a purpose-built Designer Risk Register that aligns with CDM 2015 Regulation 9. It includes the main Design Risk Register, a Residual Risk Register, and a built-in Reg 9 Duties Checklist.
Design Risk Register — key columns
Safety CDM Ltd template
Ref & CategoryNumbered entries by activity or discipline
Risk DescriptionHazard detail and context
Persons at RiskConstruction, public, maintenance, in-use
Initial Risk ScoreHigh / Medium / Low before design measures
Design MeasuresActions taken to eliminate or reduce the hazard
Residual RiskRemaining risk after design measures applied
OriginatorResponsible designer and review date
Closed / OngoingDesign closed, construction, or contractor risk type
The template also includes a CDM Regulation 9 Duties Checklist — a practical compliance audit trail covering pre-design client awareness, DRA process, co-ordination with other designers, information provision, competence, and ongoing review at each RIBA stage.
How we can help
Working with your design team
We work alongside architects, engineers, and design consultants on projects of all sizes. Our support is practical and tailored — not a box-ticking exercise.
Designer training
Practical CDM training sessions for design teams — explaining Reg 9 duties and how to integrate DRA into your design process without slowing things down.
DRA review and support
We'll review your existing Designer Risk Registers, identify gaps, and advise on residual risks that need to pass forward into the Pre-Construction Information.
Template setup and roll-out
We can provide our Designer Risk Register template branded for your practice, with guidance on completing it at each RIBA stage — ready to use straight away.
Principal Designer CDM Advisory
On notifiable projects, we act as Principal Designer CDM Advisor — co-ordinating design risk across all disciplines and ensuring Reg 9 compliance across the team.
CDM training for design teams
Half-day or full-day sessions available for practices of any size. From CDM basics for junior designers through to advanced Reg 9 workshops for senior architects and engineers.