CDM Regulations: roles and duties in the entertainment industry

This page provides information about roles and duties under the Construction (Design and Management) Regulations (CDM) in the entertainment industry, including planning, managing and coordinating construction work as part of an event or production.

What you should know

CDM defines 3 main roles with different duties within construction projects:

CDM client
CDM designer
CDM contractor

For projects involving more than one contractor, 2 additional roles are required to plan, manage, monitor and coordinate the work:

principal designer
principal contractor

These roles and their duties can be integrated into the overall safety management process for an event or production. Organisations and/or individuals may hold more than one role, for example by being both a designer and a contractor.

CDM is not about creating unnecessary and unhelpful processes and paperwork. It is about choosing the right team and helping them to work together to ensure health and safety. CDM role holders may therefore meet their duties with the help of those who work under their control, forming a part of their project team.

You can find worked examples of applying CDM regulations across the entertainment industry in the National Archives.

Getting the right project team in place

Anyone appointing organisations or individuals to work on a project must take reasonable steps to satisfy themselves that those appointed have the necessary skills, knowledge and experience to carry out their roles. An appointed organisation should also have the organisational capability to carry out the work in a way which secures health and safety.

Organisational capability means the policies and systems an organisation has in place to set acceptable health and safety standards which comply with the law, and the resources and people to ensure the standards, are delivered.

Reasonable steps will depend on the scale, complexity and type of work to be undertaken. Ask them to:

demonstrate knowledge and understanding of their work and the health and safety risks involved
provide evidence that the workforce has the necessary skills, knowledge, training and experience to carry out the work
confirm they have sufficient resource levels to do the work
provide evidence of previous successful work showing they can adopt and develop safe systems of working

CDM roles and duties

The following summaries will help you understand your role and duties under CDM.

Who a CDM client is

A CDM client is anyone for whom a construction project is carried out. This could be an event (show) organiser who commissions the building of a stage or a production company who decides what construction work is required for a TV programme.

There may be more than one client (organisation/individual) involved in construction work for a production or event. In these situations they will all have client duties unless one or more of them elect in writing to be the client(s) for the purposes of CDM.

In some circumstances, it may not be clear who the client or clients are. Any uncertainty should be resolved as early as possible by considering who:

initiates the event or production involving construction work
instructs the design and construction work
decides what is to be constructed, when and by whom
appoints construction contractors
heads up the construction procurement

It is also possible for separate construction projects to be carried out by different clients at the same venue, for example exhibitions and trade fares with 'space-only' plots. These are rented to exhibitors who independently procure their own structures.

Whatever the circumstances, it is essential that there is clarity over who is in control during the construction work in any part of the site at any given time.

Where it is not possible for one principal contractor to be in overall control, principal contractors for each project involved must:

co-operate with one another
co-ordinate their work
take account of any shared interfaces between the activities of each project (such as site perimeters and shared traffic routes)

Domestic clients hiring a venue

Domestic clients’ duties are transferred to other dutyholders. So, depending on the arrangements, CDM client duties will be transferred to the venue/planner and/or construction contractor. Compliance with their own duties as a CDM contractor will be taken as compliance with the relevant CDM client duties. If members of the public carry out the work themselves, CDM does not apply.

Volunteers contracting a company

As organisers, volunteers should co-operate with and co-ordinate their contractors’ work by providing the information and resources they need to do their work safely. All parties should co-ordinate their work to ensure health and safety. In practice, this should involve little more than what is normally required in managing health and safety risks.

Investors

If an investor just provides money, a loan/grant for an event or production and is not someone for whom a construction project is carried out, they are unlikely to be a CDM client.

Foreign clients

Foreign clients under CDM are treated the same as UK clients for work they carry out in the UK.

You can find examples of assigning CDM roles and duties across the entertainment industry in the National Archives.

What a CDM client must do when managing construction aspects of an event or production

Many clients are not experts in construction work. As a CDM client, although you are not expected to actively manage or supervise the work yourself, you have a big influence over the way the work is carried out and how much money, time and resource is available. The decisions you make have an impact on the health, safety and welfare of workers and others affected by the work.

Proportionate to the scale, complexity and risks of a project, the main CDM client duties include:

making suitable arrangements to ensure that construction work is carried out safely
ensuring proper co-operation and co-ordination between those involved in the planning, design and management of construction work
ensuring pre-construction information is provided to the right people at the right time to help with designing the structure(s) and construction planning
ensuring a suitable document (referred to in the regulations as a construction phase plan) has been drawn up before construction work begins on site
ensuring that arrangements for the provision of suitable welfare facilities are put in place for construction workers, by the principal contractor/contractor
ensuring the construction project is notified to HSE if construction work lasts longer than 30 working days and has more than 20 workers working simultaneously on it or exceeds 500 person days
co-ordinating with other independent construction projects on site

In event management, a CDM client will perform these duties with assistance from their production and site management team. You can find examples of assigning CDM roles and duties across the entertainment industry in the National Archives.

Pre-construction information

Pre-construction information provides the health and safety information needed by designers and contractors (including the principal designer and principal contactor) to enable them to carry out their duties.

The assembly and dissemination of this information is the duty of the CDM client (assisted by the principal designer).

Pre-construction information is defined as being in the client's possession (or reasonably obtainable by or on behalf of the client), which is relevant to the construction work and is of an appropriate level of detail and proportionate to the risks involved.

This would include information about the project, the planning and management of the project, plus health and safety hazards of the site or venue, including design and construction hazards, and how they will be addressed.

For example, a theatrical production design team would need information about the venue within which they were constructing the set, including permissible floor loadings, fly-bar and rigging and any factors about the 'get in' which would limit the size of scenic elements. Similarly, the project team on a festival site may need information to help them avoid underground or overground services.

This information should be gathered and added to as the design process progresses and reflect new information about risks to health or safety and how they should be managed. There is further guidance on pre-construction information in Managing health and safety in construction.

Who a CDM designer is

The term 'designer' has a broad meaning in the entertainment industry, ranging from conceptual to technical designers of structural components. However, CDM designer relates to the function performed, rather than the profession or job title. This means that some people who use the title 'designer' may not have duties under CDM.

A CDM designer is an organisation or individual who prepares or modifies designs for construction projects, or arranges for, or instructs others to do this. Designs include drawings, specifications and design calculations.

If you have input to the physical design of the structure, you will have CDM designer duties. You will also have CDM contractor duties during the assembly of the structure on your site. In practice, this should involve little more than what you have normally done to manage health and safety risks.

CDM doesn't apply to the task of manufacturing individual components.

When a producing company/event organiser uses a venue’s premises

The venue normally holds the role of a CDM designer and/or contractor, providing services into the production as required. Venue staff often take an active role in helping a producing company or event organiser with their management of the 'get in' and 'get out' phases of a show. So, proper co-operation and co-ordination between those involved is essential.

What the CDM designer’s role involves

Depending on the scale, complexity and risks of a project, designers involved in technical design work must:

have the necessary skills, knowledge, and experience relevant to the work they are doing
ensure the person or company they are doing the work for are aware of their CDM duties
take account of pre-construction information provided during design work.
provide information to assist others
eliminate foreseeable health and safety risks to anyone affected by the project (if possible)
take steps to reduce or control any risks that cannot be eliminated. Health and safety risks need to be considered alongside other factors that influence the design such as cost, fitness for purpose, aesthetics and environmental impact, for example how a theatre set can be designed to limit the amount of work at height required during construction
co-operate and co-ordinate with others

Find out more

There is more guidance on when your design role means you have duties under CDM in Managing health and safety in construction.

Who a CDM contractor is

A contractor is anyone who, in the course of their business, carries out, manages or controls construction work. This means an individual, a self-employed worker (freelancer) or a business that carries out, manages or controls construction work as part of their business during an event or production can be a contractor.

This also includes companies that use their own workforce to do construction work on their own premises. The duties on contractors apply whether the workers under their control are volunteers, employees and/or self-employed (freelance).

Venues using organisations or individuals as contractors must take reasonable steps to ensure they have the necessary skills, knowledge and experience to carry out relevant CDM roles and functions. An organiser would be expected to take reasonable steps to ensure this had been done by the venue.

What the CDM contractor role involves

Depending on the scale, complexity and risks of a project, contractors must:

have the skills, knowledge and experience relevant to the work they are doing, and if they are an organisation, the organisational capability to carry out the work safely and without risk to health
ensure the organisation or person they are doing the work for is aware of their CDM duties
co-operate and co-ordinate with others. Where more than one contractor is involved, they must comply with the directions of the organisation or person planning, managing and monitoring the project
plan, manage and monitor the way they carry out their own construction work
take account of the general principles of prevention when planning the build and breakdown of a structure
check that all workers they employ or appoint have the skills, knowledge, training and experience to carry out the work, or are in the process of obtaining them
provide appropriate supervision, instructions and information to their workers
not start work until steps have been taken to prevent unauthorised access to areas where construction is taking place
take reasonably practicable steps to ensure suitable welfare facilities are in place for their workers
ensure general requirements for construction sites are met, such as stability of structures, good order, safe traffic routes, fire prevention and emergency procedures

If they are the only contractor, they must draw up a construction phase plan or make arrangements for such a document to be drawn up, before construction work starts and keep it up to date as work progresses.

Find out more

Planning, managing and co-ordinating construction work as part of an event or production

CDM refers to 2 main phases of a project:

the 'pre-construction phase' – during which design or preparatory tasks for construction work is carried out. This may continue into the next (construction) phase
the 'construction phase' – beginning when construction work starts, for example the build phase of a structure or show, and finishing when construction work is completed, for example the breakdown of structures at the end of a show

When these phases involve more than one contractor, a CDM client must appoint an organisation (or individual) to plan, manage, monitor and co-ordinate each of these phases of the work. These roles are called the CDM principal designer and principal contractor. If the client does not appoint anyone, they must fulfil the duties of these roles themselves.

In many event and entertainment workplaces the same organisation may fulfil both of these co-ordinating roles.

Who a principal designer is

A principal designer is the organisation (or individual) in control of the pre-construction phase.

They have the duty to plan, manage, monitor and co-ordinate the pre-construction phase of a project involving more than one contractor, for example the period before the build and breakdown phases of an event or production. In practice, this duty is likely to continue into the construction phase of an event or production when further design and/or modification work is carried out and when gathering information for projects.

In the context of event management, a CDM client may often act as their own principal designer, assisted by their production and site management team.

They should have:

the technical knowledge of construction in the entertainments industry, which is relevant to the project
the understanding and skills to manage and co-ordinate the pre-construction phase, including any design modification work carried out after construction work begins

Previous worked examples of applying CDM regulations across the entertainment industry in the National Archives show how the principal designer can be assisted by production and management teams.

What the principal designer role involves

Depending on the scale, complexity and risks of a project, a principal designer’s main duties include:

helping and advising the client about bringing together pre-construction information
during the pre-construction phase, ensuring co-ordination and co-operation among the project team
working with any other CDM designers on the project to eliminate foreseeable health and safety risks to anyone affected by the work and, where that is not possible, taking steps to reduce or control those risks
ensuring CDM designers comply with their duties
liaising with the principal contractor about design matters
preparing a health and safety file for subsequent projects

Much of this can be achieved by bringing together designers and others in the project team as early as possible in the project and then on a regular basis. This can be done as part of the normal design process for an event or production.

Who a principal contractor is

A principal contractor is the organisation (or individual) in control of the construction phase. They have the duty to plan, manage and monitor the construction phase of a project involving more than one contractor. In particular, they co-ordinate matters relating to health and safety during the build and breakdown of structures.

Similar to the principal designer role, in a production or event setting, a client may often act as their own principal contractor, assisted by their production and site management team.

Previous worked examples of applying CDM regulations across the entertainment industry in the National Archives show how the principal contractor can be assisted by production and management teams.

What the principal contractor role involves

Depending on the scale, complexity and risks of a project, a principal contractor’s main duties include:

taking reasonably practicable steps to ensure construction work is carried out without risks to health or safety
taking into account the general principles of prevention when planning the build and breakdown of a structure
ensuring everyone working on site receives appropriate health and safety information to help keep them safe (draw up site rules that are appropriate to the site and the activities and provide a suitable site induction)
taking any necessary steps to prevent unauthorised access to areas where construction work is being done
providing suitable welfare facilities for those engaged in construction work
making arrangements for worker engagement and consultation
ensuring general requirements for construction sites are met, such as stability of structures, good order, safe traffic routes, fire prevention, emergency procedures
drawing up a construction phase plan before construction work starts and keeping it up to date as work progresses