The Institute answers
Who is the duty holder for a demolition project?
The short answer
Under CDM 2015 there is no single duty holder. Duties fall on the client, the principal designer, the principal contractor, designers, contractors and workers at the same time. The client carries the non-delegable duty to make suitable arrangements, and demolition attracts an additional specific duty: the work must be planned in writing before it begins.
What this rests on
- Construction (Design and Management) Regulations 2015
- Sets out the duties of clients, principal designers, principal contractors, designers, contractors and workers on construction projects, which include demolition.
- CDM 2015 regulation 20
- Requires that demolition or dismantling of a structure be planned, and that the arrangements be recorded in writing before the work begins.
- Health and Safety at Work etc. Act 1974
- The general duties on employers and the self-employed that sit beneath the CDM framework.
- The Institute's competence framework
- What a demolition engineer must know and be able to do at each grade, which is what a duty holder is assessing when they appoint one.
The common misconception
"Duty holder" is often used as though it names one party — usually whoever is on site. It does not. CDM 2015 distributes duties across several roles simultaneously, and the practical consequence is that more than one party can be in breach over the same failure. Establishing who does what is therefore not an administrative exercise at the start of a project; it is the mechanism by which the work is made safe.
Who holds what
| Role | What they hold |
|---|---|
| Client | Making suitable arrangements for managing the project, and ensuring they are maintained. Appointing the principal designer and principal contractor in writing where there is more than one contractor. Providing pre-construction information. This duty is not delegable by appointment. |
| Principal designer | Planning, managing and monitoring the pre-construction phase, and coordinating health and safety in it. On demolition this is where the sequence, the load paths and the temporary works assumptions are settled. |
| Principal contractor | Planning, managing and monitoring the construction phase, and coordinating it. Preparing the construction phase plan, and securing the site. |
| Designers | Eliminating, reducing or controlling foreseeable risks through design decisions, and providing information about remaining risks. |
| Contractors | Planning, managing and monitoring their own work, and not starting until the site is adequately secured. |
| Workers | Taking care of themselves and others, reporting anything they see that is likely to endanger anyone, and cooperating. |
The duty specific to demolition
Demolition and dismantling attract a duty most construction work does not: the work must be planned, and the arrangements recorded in writing, before it begins. That written plan is not a formality. It is the artefact that shows the collapse mechanism was chosen rather than assumed, and it is the first thing anyone will ask for if something goes wrong.
In the Institute’s experience, this is where projects most often part company with reality: the plan describes a structure as recorded, and the structure as built turns out to be something else. A plan that cannot survive the discovery of an unrecorded alteration is not a plan.
Where competence enters
Every one of these duties carries an obligation to appoint people with the skills, knowledge, training and experience the work requires — and, for organisations, the organisational capability. That is the point at which a duty holder needs something external to rest on, because self-assertion is not evidence.
Assessed professional membership is what fills that gap in demolition. It is independent of the appointee’s employer, it is graded so it can be matched to the risk, and it is verifiable in seconds. Search the register →
A practical sequence for a client
- Establish the roles in writing before anything else, including whether there will be more than one contractor.
- Assemble the pre-construction information honestly — including what you do not know about the structure. Gaps declared early are cheap; gaps discovered mid-sequence are not.
- Specify the competence you require, by grade rather than job title, and check it against the register.
- Require the written demolition plan and read it. If you cannot follow the intended sequence from it, neither can anyone else.
- Keep the arrangements alive. The client duty is to ensure arrangements are maintained, not merely made.
What this does not mean
- This page is not legal advice. It describes the duty structure in general terms; how it applies to a specific project depends on facts this page cannot know.
- Appointing a competent engineer does not transfer a duty holder's own obligations. Duties under CDM 2015 cannot be delegated by appointment.
- The Institute cannot recommend or guide on demolition methods for a particular project, and does not accept liability for individual member viewpoints.
- Additional regimes may apply — asbestos, explosives, party walls, listed buildings, environmental permitting — each with its own duty holders.