Rank: Forum user 
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We conduct in-house project work that is deemed to fall under the remit of CDM2015.
Departments may act as the client, the designer (+ principal), the contractor (+ principal) or all 3/5 of these - depending on the nature of the project.
Traditionally we appoint a project management team & those in the team cooperate (under duress sometimes) to ensure the success of the project - the team are experienced.
My query is:
Can we accept that the "team" are jointly competent to perform all aspects of the duty holders - or must we name individuals within the team that take on the duty-holder roles.
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Rank: Forum user
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Client under CDM Regs 2015: "If more than one contractor will be working on your project then, as the client, you must appoint a principal designer and a principal contractor in writing."
The main thing about CDM is also "duty holders", so therefore I would say yes you can do all 3 roles, but must be named under each duty holder role.
The client must also ensure that all appointed duty holders have the skills, knowledge training and experience, so I would also make sure that they are aware first of all as they should be asking these questions firstly.
Hope that helps?
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Rank: Super forum user 
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Just to add a caveat to the above post - if the client does not appoint a PC, PD or both, then the client by default accepts those roles. There is no point in the client appointing themselves as well unless required to do as per F10 notification.
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Rank: Super forum user 
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The Client need not make written appointment in the circumstance you describe. The roles default back to the Client. Regulation 5(3) and 5(4).
More important to have a clear Project /process planning tool which ensures all key milestones (inc. statutory ones) are mapped and achieved.
Clarity of respective roles can be a real problem where the Project is carried out entirely in-house, but compliance can be collectively achieved.
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Rank: Super forum user 
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Evans38004 wrote:
Can we accept that the "team" are jointly competent to perform all aspects of the duty holders - or must we name individuals within the team that take on the duty-holder roles.
The duty holders don't need to be named individual people ('natural person'). They can be corporate bodies or organisations, so you can name the company as each of the dutyholders.
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Rank: Super forum user
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I was at a seminar last week and the HSE were there as part of a CDM15 update on its first 6 mths. The OP's point came up and the HSE reminded everyone exactly what achrn said, ie the duty holders can be named as a corporate body rather than as an individual person. The duty holders can be from the same company so long as they are sufficiently independent from each other to apply the Regs, (ie they could be 'named' as separate departments).
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Rank: Forum user
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Thanks all for your responses - mud is clearing slightly ;-)
Dan - having a team approach does give us, as a company all the skills, knowledge & experience to perform the tasks safely (have done for >20 years).
My biggest concern - relates to Ron's comment regarding clarity of who should be doing what - especially if we do not name "leaders" as is the current management proposal.
All departments involved report to one single divisional head - so Chas' concern regarding sufficient independence is another of my concerns (or same root-concern) - if the proverbial were to hit the fan, then the divisional head would have total responsibility as all parties would claim that others did not perform the management task that resulted in the failure
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Rank: Super forum user
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Evans38004 wrote:
All departments involved report to one single divisional head - so Chas' concern regarding sufficient independence is another of my concerns (or same root-concern) - if the proverbial were to hit the fan, then the divisional head would have total responsibility as all parties would claim that others did not perform the management task that resulted in the failure
There's no requirement in the regs for independence. No duty on PC PD or Client requires one party to verify or approve the actions of another party. (Though the PD does have duties that duplicate the duties of other designers, and arguably of approving their deliverable, in my opinion).
If it all goes wrong the company is responsible. It doesn't matter whether you allocated one part of one role to one person and another to another person - the company would be responsible. It really doesn't matter what department A says about department B or whether C blames D - the prosecution will be of the company.
You might want to have some independence or some internal checking or approval processes, but I don't think the law does requires it. As such, this is now mostly a question about your company's internal procedures, and possibly high-level attitude to risk.
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Rank: Super forum user
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Chas wrote: The duty holders can be from the same company so long as they are sufficiently independent from each other to apply the Regs.
Did HSE really say that? That's a misleading statement IMO.
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