CDM 2015 Core · Mandatory · Pre-Construction
Designer Risk Register
The Designer Risk Register records foreseeable risks that cannot be eliminated through design and the measures taken to reduce or control them. Under CDM 2015 Regulation 9, designers must not commence work unless satisfied that the client is aware of their duties. This register communicates residual design risks to contractors and future users.
Last reviewed: 29 March 2026 — This guide reflects UK law as of this date. CDM 2015 Reg 9 remains current with no amendments enacted as of 29 March 2026. Next scheduled review: 29 March 2027.
| Legal basis | CDM 2015 Regulation 9(2) — eliminate risks; Reg 9(3)(a)(b)(c) — reduce/control + inform PD + H&S File; Reg 9(4) — provide sufficient design information |
| Who produces it | Every designer on every construction project — architects, structural engineers, M&E engineers, QSs, temporary works designers, and anyone else acting as a designer under CDM 2015 |
| What it records | Significant residual risks that remain after the designer has applied the ERIC hierarchy — covering the full building lifecycle |
| What ‘significant’ means | Risks NOT obvious to a competent contractor — unusual, unexpected, or likely to be difficult to manage. Routine hazards are NOT significant residual risks. |
| Where it feeds | Into the Pre-Construction Information Pack (via PD) and ultimately the Health and Safety File |
| Common failure mode | Generic tick-box registers listing every foreseeable hazard regardless of whether a competent contractor would know about it — providing no value and confusing what actually matters |
| Format | Most commonly a register, but information can also be conveyed via notes on drawings, specifications, or design documentation |
1. What Is a Designer Risk Register?
A Designer Risk Register is the document a designer uses to record the significant residual risks arising from their design — hazards that cannot be designed out, what was done to reduce or control them, and the information that needs to be communicated to others so those risks can be safely managed.
It is the practical output of the designer's CDM 2015 Regulation 9 duty. The register demonstrates that the designer has applied the ERIC hierarchy (Eliminate, Reduce, Inform, Control) to their design, identified what significant risks remain, and passed that information on to those who need it — the Principal Designer, and through them the contractors and the permanent Health and Safety File.
“9(3) If it is not possible to eliminate these risks, the designer must, so far as is reasonably practicable — (a) take steps to reduce or, if that is not possible, control the risks through the subsequent design process; (b) provide information about those risks to the principal designer; and (c) ensure appropriate information is included in the health and safety file.”— CDM 2015 Regulation 9(3)
The register vs the risk assessment — an important distinction
The Designer Risk Register is not a contractor's RAMS or a construction-phase risk assessment. It is a design-stage document that records what risks arise from design decisions, and what information the designer is passing on to enable those risks to be managed by others. The designer is not telling contractors how to do their job — they are flagging risks that a competent contractor might not know about without this information. The contractor's own RAMS then address how those specific risks will be managed on site.
2. What Is a ‘Significant Residual Risk’?
This is the single most important concept in design risk management — and the most commonly misunderstood. Many designers produce registers that list every conceivable hazard, including those that any competent contractor would manage as a matter of course. This provides no value and dilutes the genuinely important information.
“Significant risks are not necessarily those that involve the greatest risks but those which are not likely to be obvious, are unusual, unexpected or difficult to manage on this occasion.”— HSE L153 and ICE Design Risk Management Guidance (Version 2, March 2020)
The three-part test for whether a risk is significant — and therefore belongs in the register — is:
- Is it NOT obvious to a competent contractor? (If yes — include it)
- Is it unusual, unexpected, or non-standard for this type of project? (If yes — include it)
- Is it likely to be particularly difficult to manage? (If yes — include it)
| Risk / Hazard | Why or why not | Include in register? |
|---|---|---|
| Unusual structural loading assumption | Where the designer has assumed a specific limited load on a floor or roof that is less than standard — a contractor loading materials in that area could cause structural failure | YES — not obvious, unusual, could cause harm if unknown |
| Non-standard temporary works requirement | Where a facade panel system requires a specific propping sequence during installation that is not obvious from the drawings and could cause collapse if done out of sequence | YES — unusual, likely difficult to manage, specific to this design |
| Contaminated ground in a specific location | Where ground investigation has identified a localised area of contamination that will require specific handling during excavation | YES — not obvious without the survey data, could cause harm to excavation workers |
| Structural element that looks removable but is load-bearing | A wall or column that appears non-structural but carries significant load — critical for future refurbishment and demolition work | YES — not obvious, could cause structural collapse if removed without knowledge |
| Deep excavation near existing foundations | Where the design requires excavation that could undermine existing adjacent foundations in a way that is not immediately apparent from site conditions | YES — unusual, not obvious without the design information, could cause structural damage or collapse |
| Working at height on a standard flat roof | Working on a flat roof is a standard construction activity. A competent contractor knows edge protection is required and will plan for it. | NO — obvious to any competent contractor; routine risk |
| Manual handling of standard building materials | Every construction project involves manual handling. A competent contractor knows to assess and control this. | NO — routine, obvious to any competent contractor |
| Electrical installation risk | All electrical work involves the risk of electric shock. A qualified electrician knows how to manage this. | NO — obvious to a competent electrical contractor |
3. ERIC Across the Full Building Lifecycle
CDM 2015 Regulation 9 requires designers to consider risks not just during construction, but across the entire lifecycle of the structure — including maintenance, operation and use, and eventual demolition. The register must cover all four lifecycle stages, not just construction-phase risks.
| Construction | Maintenance | Use / Operation | Demolition | |
|---|---|---|---|---|
| ELIMINATE | Design out the need for working at height — e.g. specify permanent safe access routes, use ground-level maintenance where possible | Eliminate need for roof access — specify self-cleaning glazing, ground-level plant and meters, maintenance-free materials | Eliminate trip hazards, sharp edges, slips — specify level thresholds, rounded details, slip-resistant surfaces in circulation | Eliminate complex disassembly — design for deconstruction, use bolted rather than welded connections where practical |
| REDUCE | Reduce manual handling — specify prefabricated elements, modular components, maximum block weights | Reduce working at height duration — locate air handling units at ground level, provide safe permanent access where elimination not possible | Reduce noise, dust, vibration exposure — specify ventilated plant enclosures, low-vibration HVAC, acoustic separation details | Reduce structural instability risks — provide clear load path information, mark primary structural elements, design for phased demolition |
| INFORM | Communicate unusual structural loading assumptions, non-standard temporary works requirements, buried services routing | Document maintenance access requirements, inspection intervals for structural elements, location of valves and isolators | Record hazardous materials in the structure, non-standard structural systems, fire compartmentation locations | Provide demolition-specific information: asbestos location, structural interdependencies, environmental hazards |
| CONTROL | Where construction hazards cannot be designed out — identify that specific controls will be needed, e.g. permit to work for confined spaces | Where access risks remain — identify that specialist access equipment will be required, e.g. fall arrest on this element | Flag operational controls needed — interlocks, safety equipment, specialist training for building systems | Identify specialist demolition controls needed — structural surveys before demolition of specific elements |
Maintenance and demolition risks are the most commonly missed
Most designers apply ERIC to construction risks reasonably well. Maintenance and demolition risks are where design risk management most commonly fails. Ask: how will this element be maintained safely? Can it be accessed without working at height? If a future contractor needs to replace this component, will they know it is load-bearing? Will they know about the services running through this void? The H&S File is the vehicle for passing this information to future owners and contractors — it relies on the designer's register to identify what needs to be in it.
4. What a Register Entry Should Contain
A designer risk register entry should capture enough information that someone reading it — a contractor, the PD, or a future maintenance team — can understand the risk, why it is significant, and what they need to do about it. The following fields are recommended.
| Field | What to include |
|---|---|
| Reference | Unique entry number for cross-referencing with drawings and PCIP |
| Design element / location | The specific design element, system, or area of the project to which the risk relates — with drawing reference where applicable |
| Hazard identified | Description of the specific hazard arising from this design element |
| Lifecycle stage affected | Which lifecycle stage(s) this risk applies to: Construction / Maintenance / Use / Demolition |
| Persons at risk | Who could be harmed — construction workers, maintenance operatives, building occupants, public |
| ERIC step taken — Eliminate | What was done to eliminate the risk through design. If elimination was not reasonably practicable, explain why. |
| ERIC step taken — Reduce | What was done to reduce the risk through design. If reduction was not reasonably practicable, explain why. |
| Residual risk description | Description of the significant residual risk that remains after all reasonable design measures have been taken |
| Why it is significant | Brief explanation of why this risk is not obvious to a competent contractor — unusual, unexpected, non-standard, or difficult to manage |
| Information to be communicated | What information needs to be passed to the PD (for PCIP and H&S File), the PC, or other contractors to enable safe management of this risk |
| Date / design stage | Date of entry and design stage at which this risk was identified — risks may change as the design develops |
| Designer / reviewer | Name and role of the designer who made the entry, and reviewer (often PD or senior designer) |
5. A Worked Example Register Entry
The following shows a single completed register entry for a non-standard structural arrangement — the type of risk that genuinely belongs in the register and that contractors cannot be expected to identify without the designer's information.
| Field | Value |
|---|---|
| Ref | DRR-07 |
| Design element | Transfer beam at Level 3, Grid E-F/3-4. See Structural Dwg S-301. |
| Hazard | Transfer beam spans a column-free space below. The columns below Level 3 in this bay are non-structural (facade only). Future refurbishment or demolition work that removes these columns without knowing they are non-structural is safe. However, if the beam itself is assumed to be a secondary element and removed prematurely during any future structural alteration, significant collapse risk would arise. |
| Lifecycle | Maintenance / Refurbishment / Demolition |
| Persons at risk | Future contractors carrying out structural alterations or demolition |
| Eliminate | Not reasonably practicable — the column-free bay is a design requirement of the client brief (large open-plan floor). |
| Reduce | Transfer beam clearly marked on structural drawings. Non-structural facade columns annotated to distinguish from primary structure. Design load path diagram produced. |
| Residual risk | Transfer beam position, size, and critical load-bearing role is not obvious from visual inspection. Future contractors may incorrectly assume it is a secondary element. |
| Why significant | Non-standard structural arrangement — not obvious to a competent contractor without the structural drawings. Removal or temporary propping of this beam would cause disproportionate collapse of the three floors above. |
| Information to communicate | Structural system diagram and load path drawing included in H&S File. H&S File to note: ‘Transfer beam at Level 3 Grid E-F/3-4 is critical primary structure. No structural alterations to this bay without structural engineering review.’ |
| Date / Stage | March 2026 — RIBA Stage 4 (Technical Design) |
| Designer | S. Patel, Structural Engineer, Meridian SE Ltd |
6. Common Mistakes
Listing every foreseeable hazard regardless of whether it is obvious to a competent contractor
Approximately 90% of Designer Risk Assessments received by Principal Designers are described by industry as generic and tick-box in nature. A register that includes ‘working at height risk’ on a standard roof, ‘manual handling risk’ for standard building materials, and ‘electrical risk’ for standard electrical installation adds no value — a competent contractor knows about all of these. It also buries the genuinely significant entries that contractors do need to know about. Be selective: include only what a competent contractor would not know without your specific design information.
Only considering construction risks — ignoring maintenance, operation and demolition
CDM 2015 Regulation 9 is explicit that the designer must consider risks ‘to the health or safety of any person’ — including those who will maintain, clean, use, and eventually demolish the structure. A register that only addresses construction-phase risks has failed to discharge the full Regulation 9 duty. Maintenance access, future replacement of major components, and demolition sequence are all within scope.
Treating the register as a one-off document produced at the end of the design stage
Design risk management should be an ongoing process throughout the design, not a form produced when the RIBA Stage 4 drawings are issued. Risks that are identified at concept stage may be able to be designed out — risks identified at detailed design stage may only be manageable, not eliminable. The register should be a live document, updated as the design develops and reviewed at each design stage gate.
Providing the same generic register for every project regardless of design specifics
A Designer Risk Register that does not reference specific drawing numbers, specific grid references, or specific design elements is not project-specific. Every design is different. The register must reflect the specific risks arising from this design — not a generic list of construction hazards that could apply to any building.
Not passing the register to the Principal Designer promptly
CDM 2015 Regulation 9(3)(b) requires the designer to provide information about residual risks to the Principal Designer — and Regulation 8(6) requires that this information be provided ‘as soon as is practicable.’ Providing the register at the end of the project is too late for the PD to incorporate it into the PCIP, and too late for contractors to plan for identified risks. Update the register progressively and pass updates to the PD as the design develops.
Specifying construction methods in the register
The designer’s job is to identify and communicate significant residual risks — not to prescribe how contractors should manage them. A register entry that says ‘contractor must use X method’ or ‘contractor must provide Y barrier’ is overstepping the designer’s role and potentially creating liability if the specified method is not appropriate for site conditions. Communicate what the risk is and why it is significant; leave safe system of work decisions to the competent contractor.
8. Frequently Asked Questions
Does CDM 2015 explicitly require a Designer Risk Register?▾
CDM 2015 does not name ‘a designer risk register’ as a specific mandatory document. However, Regulation 9(3) requires designers to provide information about significant residual risks to the PD and to ensure appropriate information is included in the H&S File. A register is the most practical and widely adopted format for fulfilling this duty — it provides a structured, dated, auditable record of what was considered and what was communicated. Information can also be conveyed via notes on drawings, specifications, or design documents — but a register is the clearest approach.
Does every designer need to produce their own register?▾
Yes — every party acting as a designer under CDM 2015 has Regulation 9 duties. An architect, structural engineer, M&E engineer, temporary works designer, and a specialist contractor who designs their own installation all hold designer duties and should each produce a register for their own design scope. The Principal Designer’s role is to coordinate these individual registers and ensure the significant risks are captured in the PCIP.
Should the register be updated after the design is complete?▾
The register should be updated whenever the design changes. Where a design revision eliminates a previously identified risk, update the register to reflect this. Where a design change introduces a new significant risk, add it. The final version of the register, covering all residual risks in the completed design, is what feeds into the H&S File.
Is a high-risk entry the same as a significant residual risk?▾
Not necessarily. A risk can be high in likelihood or severity and still be obvious to a competent contractor — in which case it is not ‘significant’ in the Regulation 9 sense and does not need a register entry. Conversely, a risk may have a relatively low probability but be non-obvious and unusual — making it exactly the kind of information the register exists to communicate. The test is not magnitude but whether the risk is obvious: would a competent contractor know about it without the designer’s information?
Can risk information be conveyed on drawings instead of in a register?▾
Yes — CDM 2015 does not prescribe a specific format. Notes on drawings, specifications, or design documentation can all be used to convey residual risk information. Many designers use a combination — annotating specific risks on relevant drawings with a cross-reference to the register for fuller detail. What matters is that the information is clear, accessible, and reaches the people who need it — not that it is in a particular format.
How does the designer know what to include in the H&S File?▾
CDM 2015 Regulation 9(3)(c) requires designers to ensure appropriate information is included in the H&S File — information about residual risks that could affect the health and safety of anyone carrying out future construction, maintenance, or demolition work. The test is: would a future contractor carrying out work on this building be at risk from this element if they didn’t know about it? If yes — structural information, hazardous material locations, non-standard systems, access limitations — it belongs in the H&S File, sourced from the register.
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