RO, I am sure some of my colleagues may disagree, but I have two points to make: i. I cannot envisage any construction project that requires no design input at all; and ii. Unless the health and safety practitioner in question has relevant design experience, I cannot envisage them wanting to take on the liability of a PD role. That said, the short answer to your question is 'yes'. Technically, anybody who is competent to do so can take on the PD role. The question will be, would he/she want to? Sorry to be such a pain but I hope this does help. Kind regards. DJ

I think the implication of CDM 2015 on the requirement for the PD role go much wider than those referred to above. For example, a very small kitchen re-fit business (which would, of course, be classed as construction work) employing say 2 direct persons and regularly using a subcontractor to do the electrical and gas installation work. Under CDM 2015 this business would incur PD duties and responsibilities (and be required to evidence PD competence when bidding for work!!). The same small business would also now be a PC under CDM 2015 and again would need to demonstrate competence in the PC role including site safety management e.g. CITB SMSTS certification. Reality is, thousands of similar construction related small businesses will not have the slightest idea of these requirements and responsibilities let alone be able to demonstrate them. What a mess!!!

Like so many new laws it is up to the general public to know the changes. Builders are usually members of trade associations who will inform their members about CDM 2015 so they should be able to adopt and adapt to the changes. If they do not on their own head be it, we safety professionals should not be getting involved in this side of the business unless it is to advice clients? May I ask do we all know the latest changes to driving laws regarding middle lane use on motorways, for example? The Police will enforce this without sympathy for anyone who says they were not aware.

in my experience there are many many jobs where no designer is ever involved e.g. where a 'like for like' direct replacement with no other change being made takes place; - e.g. replace a number of doors [old off new on] = no designer input, replace a number of sets of taps [old off new on] = no designer input and so on and on Whilst I have quoted mini jobs the same can be said for some large industrial jobs as well e.g. my last but one job; power station outages where the main boiler tubes are 'like for like' replaced under a new for old system where the new must be identical to the old from drawings/specifications that have been in place for many many years and teh designers are now passed away and 'new' designers are nowhere to be seen and as has already been said these new regs are probably not fit for purpose

Thanks for the comments, very helpful. Ron, I should have clarified that in my example the client has stated they want the PC to do the PD role too. I think we have established that when no traditional design such as drawings is needed then it could be one of a few people who occupy the PD role or even a group including the person who specifies the materials, the technical team who state how to fit them, the person that orders them etc. In this case the PC was thinking they had to employ a RIBA certified Architect to oversee this design team but didn't understand why.