Hi Julie
One of the reasons for the changes between CDM 2007 and CDM 2015 was HSE's view that the role of CDM Co-ordinator (and before that Planning Supervisor under CDM 1994) was too often being delivered by H&S professionals with little understanding of the nuts and bolt of designing and constructing projects.
By nuts and bolts I don't mean walking round sites and looking for defects in scaffolds, poor traffic management, but rather a real appreciation of what is needed to turn a site from a blank page into some structure.
So, in CDM 2015, it says that the PD has to a Designer and meet the definition of that word in the Regulations.
The Association of Project Safety reacted by changing its admission criteria though some who got to be CMaPS previously will still be such due to so called grandfather rights.
But for other H&S professionals the APS rules now mean that they won't get past IMaPS status unless they can demonstrate QUALIFICATIONS and EXPERIENCE in actually doing the design and/or build of construction projects.
New legislation always takes a while to bed down and HSE have done little in the way of enforcement against the front line duty holders - i.e. Clients, Designers and Planning Supervisors/CDMCs/now PDs for over 25 years.
Most of the prosecutions that HAS been taken in terms of PSs/CDMCs/PDs has been directed against small health and safety consultancy practices.
Such practices have tended to skew away from offering full PD services on anything but the simplest projects towards offering a CDM Advisor or similar title role - so advising the Client and/or PD (and/or Designer).
In terms of risk v reward this probably works for many for the simple reason that the risk of being found to have failed to discharge the duty of PD either in full or as CDM Advisor is slim and the rewards can still be good.
However, I think that this will change if such consultancies now attempt to add a PD under the BSA string to their bows as there will be pressure to make sure that all efforts are made to prevent repeats of Grenfell and other fire disasters.
Without clear understanding and experience of fire engineering, I think that moving into this particular arena is going to be fraught with peril.
It is not going to be about being capable of looking at the number and location of fire extinguishers and doing templated fire risk assessments (with caveats saying that some tenants didn't open their front doors). The regulators will be looking very closely at what is happening, albeit only on a minority of projects (not enough resources within HSE with its new BSA hat to do the job properly).