If by 'complete a risk assessment' you mean produce a particular document with the title "risk assessment" at the top, then no. They are not required by statute to do that for any (normal) project of any size. (The 'normal' only applies because there might be some legislation in some specific area - control of explosives in mines for example - where a specific risk assessment document is required.)

If you mean are they required to consider the risks inherent in their design, then yes, they are required to do that for all projects.

See the table in paragraph 23 of the ACOP - they have to reduce risks during design for all construction projects. Similarly para 119, 120 and 121 - these apply for all projects. You can't reduce risks if you haven't considered what they might be. Regarding timing, see paragraph 110 - "vital to address ... from the very start".

Understand where you're coming from on this Latchy - but may I suggest that it should be reverse engineered in that the Designers are actually required to identify dodgy design points and remodel it to make it less dodgy - then you can do a RA.

For example - consider the creation of Confined Spaces that are inherent features of very large monolithic concrete buildings. It's dead easy to create the pouring structure; but afterwards someone has to enter to remove it. Designers tend not to have clue 1 about the issues of doing this, nor even recognise that their design has created a clear hazard [the CS] that people now have to enter to remove the shuttering structure 'cos as far they're concerned it won't be used after the shuttering has been removed. The same applies to the creation of rain flood attenuation tanks which are almost always under the structure [though I know a couple that aren't] so inspection, cleaning and maintenance becomes far more complex and dangerous than it need be.

It's not the creation of the space, it's the failure to recognise that people will have to access and work in it after that counts.

Someone else can talk about the Work at Height related poor design that gats architectural awards and costs a fortune in access equipment.

Enough of that, I'm off to lower my blood pressure now.

Frank Hallett

That's completely unreasonable, in my view. You cannot document every risk. It is impossible to document every risk. Even if you mean every reasonably foreseeable risk, you'd still spend at least four times as much time documenting the decisions you've made as making the decisions in the first place.

If you did document every risk, no-one would read it - it would be a massive document.

Also, you seem to be asking that designers first produce a design where they ignored their statutory duties and common decency, in order that when they then produce a design that does consider their statutory duties and common decency they can document the differences between the two. You might want to pay a designer six times as much as necessary (once to do the design wrong, once to do the design right and four times to document every decision and difference between the two), but if so you're the first client I've ever met with that view.

(Of course, if you really do want to pay six times as much as everyone else for design work, I'll be very pleased to send you some of our marketing literature...)

The HSE has a reasonable approach to risk assessmnet during design, written up at http://www.hse.gov.uk/co...on/cdm/faq/designers.htm under the questions 'I’m a bit confused about whether I should be using design risk assessments...' and 'I thought the Management of Health and Safety at Work Regulations 1999 (MHSWR) required risk assessments...' The key quotes (in my view) being "The consideration of hazard and risk is integrated within the design process, so there is no need to carry out a separate ’design risk assessment’." and "as the design is worked through to completion, any hazards will be eliminated and residual risks (to those who may be affected by them) reduced, so far as is reasonably practicable. This is, in effect, the application of risk assessment to the design. ... In terms of design, the significant findings of the assessment will be the finished design, together with all relevant drawings and any accompanying notes."

In manufacturing (say) no-one would consider it reasonable to require someone operating a factory to produce a risk assessment for all factory operations that might be carried out if the factory was operating on the assumption that there was no H&S statute and no social or moral obligations not to kill or maim your workers. What is the point in a documented risk assessment of a method of working you wouldn't dream of adopting because it's not safe?

I remain perpetually flummoxed why some of the people that think they are qualified to control designers believe that designers should produce documents describing the wrong way of doing something, solely to demonstrate that they've thought about what the right way to do it is.