RICS has prepared a submission in response to research being undertaken into the impact and implications of the revision of the Construction (Design and Management) Regulations (CDM) 1994, Construction (Health, Safety and Welfare) (CHSW) Regulations 1996, Approved Code of Practice (AcoP) and Guidance on small businesses and occasional clients. 

We feel that the proposals do not simply strengthen current wording within the regulations but re-distribute and increase the level of responsibility on the client considerably. 

As such it is vital that strong guidance and clear criteria are provided to allow clients to effectively use the regulations to ensure health and safety standards are maintained and on-site risks and hazards reduced.  In order to achieve this a realistic timeframe and programme of disseminating the proposed changes needs to be implemented.  Smaller businesses and occasional clients may need particular assistance in ensuring that they are made aware of the regulations and the obligations they hold under them.

The response raises concerns about the proposed new role of project coordinator and calls for clarity regarding whether this person or the client will ultimately be hled liable at the end of the process. We also suggests that a minimum set of responsibilities should be established for the coordinator so that this new role does not conflict with the responsibilities of others working on projects including the Project Manager, Building Surveyor and Lead Designer.