Hi bod

I very much doubt that any change to CDM is imminent.

Possibly the reason for the question might relate to the legislation that is coming in at different speeds around the UK following Grenfell (and other incidents).

So new fire safety legislation, significant elements of which draw on CDM in terms of identifying key duty holders and what they should do. 

I guess it is possible that HSE might wish to update some CDM guidance to say, inter alia, that one named duty holder isn't necessarily the same named duty holder under the fire legislation, though often will be - if that makes sense!

However, HSE might equally wish to say as little as possible, as to make noises might draw attention to the fact that HSE has been very reluctant to take enforcement action against front end CDM duty holders - Clients, Designers and over three iterations of CDM first Planning Supervisors, then CDM Co-ordinators and now the Principal Designers.

Easy to see this for yourself. HSE has databases of both prosecutions and enforcement notices on its website, which run about 9 weeks after the event (to allow for appeals and such like).

So, as example you can go into the HSE prosecutions databases - current up to 1 year back and "history" 1-10 years back and check what prosecutions have been taken both under CDM but also under specific CDM Regulations (or a range of Regulations e.g. where the number of the Regulation is less than 12 which would capture almost all prosecutions against the front end duty holders).

I would note that doing this won't pick up prsoecution enforcement action against those same duty holders if HSE takes action against them using a differnt piece of legislation such as HSWA, bHSWA Section 3 and it would be very difficult to pick out those which deal with what the defendant should have done as a CDM (or pseudo CDM) duty holder on a construction project from a large pool of data on Section 3 being used for other reasons. Partly as the free text box setting out the Summary of each case has very often been left entirely blank or with minimal comment.