The HSE's CDM 2015 Review Confirms What Many of Us Have Been Seeing for Years

In March 2026, the HSE published its Second Post-Implementation Review of the Construction (Design and Management) Regulations 2015 (CDM 2015).

The headline is straightforward:

CDM 2015 is here to stay.

The review concludes that the regulations remain fit for purpose and continue to provide benefits to the construction industry. However, beneath the headline findings are several observations that many clients, Principal Designers and contractors will immediately recognise.

In many ways, the report confirms issues that have been affecting projects for years.

Too Much Information Does Not Always Improve Safety

One of the strongest themes within the review is that project information is becoming increasingly large, generic and difficult to use.

As projects become more complex, information is often layered upon existing information rather than reviewed, filtered and refined. Documents grow larger, appendices become longer and critical information becomes harder to find.

The intention is usually good.

The outcome is often the opposite.

When project teams are overwhelmed with information, there is a risk that genuinely important hazards become lost amongst generic wording, duplicated content and historic information that adds little value to the task being undertaken.

This is particularly relevant within industrial decommissioning, asbestos and demolition projects.

We regularly encounter projects where contractors are issued with years of historic reports, legacy drawings, outdated surveys and large volumes of pre-construction information. While the information may technically exist somewhere within the documentation, finding and understanding the information that truly matters can become a challenge in itself.

The risk is not a lack of information.

The risk is when critical information loses visibility because there is simply too much of it.

Poor Hazardous Materials Information Remains a Significant Challenge

One issue that continues to affect decommissioning and demolition projects is the quality and usability of hazardous materials information.

Many industrial facilities have undergone multiple modifications, surveys and maintenance campaigns over several decades. As a result, asbestos and hazardous materials information can become fragmented across numerous reports, surveys and databases.

It is not uncommon to encounter:

• Multiple asbestos surveys completed by different organisations.
• Conflicting information across reports.
• Historic survey data with limited validation.
• Large appendices containing extensive information but little practical guidance.
• Hazardous materials information that is difficult to interpret and apply to the proposed works.

The challenge is not simply identifying whether asbestos or hazardous materials are present.

The challenge is ensuring that the information is structured in a way that supports planning, tendering and safe execution.

Poor-quality or poorly organised hazardous materials information creates uncertainty.

Uncertainty creates assumptions.

Assumptions create risk.

The Principal Designer Is Still Being Appointed Too Late

The HSE review also identified a widespread concern that Principal Designers continue to be appointed too late within the project lifecycle.

Too often, the Principal Designer is appointed shortly before construction or demolition works commence, limiting their ability to influence key project decisions.

This is particularly problematic within decommissioning and demolition.

The greatest opportunity to eliminate risk rarely exists once demolition methodology has been developed.

It exists during the planning stage.

It exists when the project scope is being defined, hazardous materials investigations are being commissioned, waste strategies are being developed and tender documentation is being prepared.

By the time contractors are developing RAMS, temporary works designs and demolition methodologies, many of the most significant project decisions have already been made.

Competence Remains a Challenge

Perhaps one of the most interesting findings within the review relates to competence.

The report highlights concerns that unqualified or inexperienced individuals are increasingly undertaking Principal Designer appointments and that clients often struggle to assess what competency is actually required for the role.

This is a challenge across the construction sector.

Within decommissioning and demolition projects, it can be even more significant.

We frequently see organisations appointed as Principal Designer that possess extensive construction experience but have limited understanding of industrial dismantling, hazardous materials management, temporary works, demolition engineering, process isolation, waste classification and asset closure strategies.

The Principal Designer role is far more than a compliance exercise.

The role requires the ability to identify risks, challenge assumptions, coordinate design decisions and influence project outcomes.

Most importantly, the Principal Designer must possess the skills, knowledge and experience relevant to the specific project.

A competent Principal Designer for a residential housing development may not necessarily be the most suitable Principal Designer for a complex refinery, power station or chemical manufacturing facility.

The Pre-Construction Phase Does Not End When Demolition Starts

One area often overlooked within industrial decommissioning and demolition is that the pre-construction phase frequently continues well beyond the commencement of physical works.

Unlike many traditional construction projects, information continues to evolve throughout demolition projects.

Additional intrusive investigations are undertaken.

Previously hidden conditions are discovered.

Hazardous materials are uncovered.

Temporary works designs develop.

Demolition methodologies are refined.

Waste streams are reassessed.

As a result, risk management, design coordination and information review continue throughout the project lifecycle.

This is one of the reasons why effective Principal Designer involvement remains important long after contractors arrive on site.

Why Front-End Planning Matters

The findings of the HSE review reinforce something that many experienced project teams already understand:

The best-performing projects are usually the ones that invest sufficient time and effort before tendering.

This principle is widely accepted within construction through Front-End Engineering Design (FEED) studies and detailed project development.

Yet decommissioning and demolition projects are often expected to proceed with less information despite containing greater uncertainty, more unknowns and frequently higher levels of risk.

A well-executed planning phase allows clients to:

• Better understand hazardous materials risks.
• Develop practical waste management strategies.
• Quantify scrap metal inventories and recovery opportunities.
• Improve the quality of pre-construction information.
• Reduce contractor assumptions.
• Improve tender quality.
• Achieve more accurate project pricing.
• Reduce the likelihood of programme delays and scope creep.

The objective is not to produce more paperwork.

The objective is to provide the right information, in the right format, to the right people.

The Real Message From The HSE Review

The HSE review concludes that CDM 2015 remains effective and should remain in place.

However, the report also highlights several challenges that continue to affect projects across the industry:

• Information overload.
• Poor information quality.
• Late Principal Designer appointments.
• Competency concerns.
• Weak client understanding of duties.

These are not simply compliance issues.

They are project delivery issues.

For complex decommissioning, asbestos and demolition projects, success is rarely determined by the amount of documentation produced.

Success is determined by whether project teams can clearly understand the scope, identify the real risks and make informed decisions early enough to influence the outcome.

Because the safest and most successful projects are rarely those with the most paperwork.

They are the projects where the right people receive the right information at the right time.