The principal designer's information duty that nobody resources

Most UK cost plans carry a line that reads something like "CDM / PD". Sometimes it is a lump, sometimes a handful of days, and often it is worth less than a fortnight of one designer's time. What sits behind that line is a named duty-holder with statutory information obligations and a signature a regulator can find. What the line usually buys is attendance.

Ask the person named on the form what their fee actually covers and you tend to get a candid, faintly embarrassed answer: a template, a workshop or two, comments on somebody else's risk register. The appointment is cheap because the information work behind it was never priced as a work package. Projects appoint the duty-holder and then decline to fund the records the duty is made of.

In Great Britain, the Construction (Design and Management) Regulations 2015 give the client a duty to provide pre-construction information and to see that a health and safety file is prepared. They give the principal designer a duty to plan, manage and monitor the pre-construction phase, to help assemble and issue that information, to coordinate residual design risk, and to prepare the file. In England, from October 2023, the Building Regulations add a second principal designer — a different appointment — whose job includes planning, managing and monitoring design work so that it can be shown to comply, and contributing the records the Building Safety Act expects to stay current. Those texts assume the records exist. They do not buy the hours.

Two principal designers, one collapsed name

CDM's principal designer and the Building Regulations principal designer can be the same organisation. They are not the same role. One is about health and safety in the design and construction of the works. The other is about whether the design, as a design, complies with the Building Regulations and can be evidenced. Higher-risk buildings in England then add the golden thread: prescribed information that must be digital, accurate, secure and kept up to date, rather than assembled as a Gateway upload.

The collapse is administrative rather than deliberate. One name goes on the form. One fee line gets negotiated, often as a few extra pages in the lead designer's appointment, or as a CDM consultant on workshop days. Competence is asserted once. The information outputs — pre-construction information that designers can actually use, a live health and safety file, residual-risk records that change when the design changes, and, where it applies, a golden thread that still answers questions after the design team has left — get treated as a by-product of doing the design.

If you cannot point to two scopes, two information outputs, and two places those hours sit in the cost plan, you have a name. You do not have two appointments.

What the information duty actually is

Strip the role titles and the duty is a sequence of records.

Pre-construction information. The client must provide information that is in their possession or reasonably obtainable: the site, existing uses, existing hazards, buried and overhead services, asbestos and other surveys, existing health and safety files, adjacent activities, and enough about the design for other duty-holders to plan. The principal designer helps assemble it, checks it for gaps, and issues it to designers and contractors as they are appointed — not once, as a kick-off PDF, and not only to the firms who happened to be in the room at the start.

Designers' residual risk. Each designer must eliminate or reduce foreseeable risks so far as reasonably practicable, and must pass on information about the risks that remain. The principal designer coordinates that information so one package's assumption becomes another package's input. A design-risk assessment that says "working at height" and "services in ceiling void" is a slogan. The usable record names the residual hazard, where it sits, who needs it, and what they must do differently.

The health and safety file. The principal designer prepares it during the pre-construction phase and keeps it current while they remain appointed. If the appointment ends before construction does, the file passes to the principal contractor to review and update. The client then keeps it available for anyone who later works on the building. A binder compiled at practical completion is a completion deliverable, not a file anybody used.

Liaison into the construction phase. The principal designer must share the information the principal contractor needs to plan, manage and monitor the construction phase. That means issuing current design and residual-risk information, not holding a handover meeting.

Where the Building Safety Act applies. For higher-risk buildings in England, duty-holders must contribute to the golden thread through design and construction. A change is not only a drawing revision but a change to the record someone will later rely on to occupy, maintain or alter the building. The Building Regulations principal designer is accountable for the design being planned, managed and monitored so compliance can be shown. That cannot be discharged by handing out a CDE login.

None of those duties is "attend the HAZID", and none of them is "the model contains the data". They are dated, attributable information containers with a named recipient and a state that can be wrong.

What the fee usually buys

Look at the cost plan rather than the appointment letter. The pattern is ordinary enough to be predictable.

The lead designer is paid to produce the issued set. A CDM or principal-designer line is priced as overview: workshops, a pre-construction information template, comments on other people's risk registers, a presence at design reviews. Document control is budgeted for drawings and models. The principal contractor's preliminaries include a health and safety manager and, late on, a health and safety file. Where a golden thread gets a mention, it is often the same common data environment already bought for ISO 19650 issue.

What those lines do not buy:

a gap analysis of pre-construction information against what each incoming designer needs, with a list of what the client still has to obtain
hours to chase existing-building records the client does not hold, and to say in writing what remains unknown
review of design-risk information for content, not for the presence of a PDF
an owner for the live health and safety file as the design changes, not as a completion milestone
a map of which container is pre-construction information, which is the file, and which — if the building is higher-risk — is prescribed golden-thread information
administration of two principal-designer appointments when the firms are different, including two competence records and two information outputs

Design hours are not automatically information hours. A coordinated model can be entirely current in the authoring tool and silent on residual risk. A document controller can run an immaculate issued set and still have no current pre-construction information anywhere on the job. The vacancy is not a missing person. It is a missing work package with liability still attached to the name on the form.

Diagnose the gap on Monday

You do not need a consultant for this. Take the live project and write the answers from the system of record and the cost plan, not from memory.

Who is appointed, twice if you must. Name the CDM principal designer. If the job is in England and Building Regulations duty-holders apply, name that principal designer too. If they are the same firm, say so, and say which schedule of services covers which output.
Where the hours sit. Find the fee line, day-rate or included lump that is supposed to pay for assembling pre-construction information, coordinating residual risk, and keeping the health and safety file current. If the only line is "CDM / PD" under design management, and it amounts to a fraction of a single designer-month, you have the collapse.
What went out as pre-construction information, to whom, and when. Reconstruct the last issue: containers, date, named recipients — not "the design team". If the only copy is a kick-off PDF, or if an engineer appointed last month cannot show they received a current set, the client and principal-designer duties are not being resourced.
Whether residual-risk information can be queried. Pick one interface — a roof edge, a plant-room access, a buried service. Can you find the residual hazard, the designer who owns it, and the last date it was updated, without opening personal inboxes? If all you can find is a generic register, you have theatre.
Whether the health and safety file has a current container. Not a folder named for completion. A container that changed the last time the design changed, with an owner and a state. If the file is a milestone in the contractor's programme, it is already late.
If the building is higher-risk, what the golden thread is as a list of containers. A platform name is not a thread. Prescribed information that cannot be pointed at, dated and attributed is not being kept.

If you can complete (1) and not (2), you have a duty-holder without a budget. If you can complete (1) and (2) but not (3) to (5), you have budgeted a presence rather than an information duty. If (6) fails on a higher-risk building, the Building Safety Act's record-keeping duty is being treated as storage.

Three projects in a row will tell you whether this is a habit. One tidy pack tells you nothing.

What to put on the budget if you mean the duty

Name the work as information exchanges rather than as a role.

PCI assembly and issue. A first gap list against what is reasonably obtainable, then a dated issue to each appointed designer and contractor as they arrive. Include the survey and existing-records allowances the client still has to fund. "PD to compile PCI" with no survey budget is how a gap list quietly becomes a recycled template.
Residual-risk coordination. Hours to review designer information for content, to reject slogans, and to re-issue when the design changes. Put a reject path in the appointment. A register that cannot fail is not a register.
Live health and safety file. A container from the pre-construction phase, an owner while the principal designer remains appointed, a named transfer to the principal contractor if they leave, and a change rule: a design change that affects residual risk updates the file in the same cycle as the drawing.
Where it applies, golden-thread containers. List the prescribed information as rows, each with an author, a state and an acceptance test. Do not hide them inside "CDE provided".
Two appointments, two outputs. If one firm holds both principal-designer roles, still write two information outputs into the schedule of services. Competence for one role does not write the records for the other.

None of that requires a new stamp. It requires the cost plan to stop treating the information duty as a courtesy that rides on the design fee.

Limits

A learning post that pretends a template is a certification is lying. None of this is legal advice. CDM 2015, the Building Safety Act, the Building Regulations duty-holder regime, and the competence regulations each have owners. HSE, the Building Safety Regulator and the relevant approved codes and guidance are the texts that decide what "enough" looks like on a given job. Nothing here sells a stamp, and nothing here tells you that you are competent.

What can be said plainly is where to look first, which is the fee line. If you are the client or the appointing party — and on this you are the only one with the leverage — ask your principal designer, both of them where two apply, to show you the last dated pre-construction information issue and the current health and safety file container, then ask your cost manager which line paid for either. Where the answer is a workshop and a template, the duty is unresourced, and the cheapest moment to fund it is before the next designer is appointed. Expect it to cost real fee: hours for a gap analysis, a survey allowance somebody has to carry, and continuing time to keep the file moving while the design does.