CDM Regulations Explained: What They Mean for Commercial Projects

When you’re running or bidding for a commercial cleaning or maintenance project - whether within an office complex, retail centre, industrial warehouse, or other built environment - understanding the Construction (Design and Management) Regulations 2015 (“CDM 2015”) is essential. Although many assume that CDM only applies to “construction” in the traditional sense (new builds, major refurbishments), in fact these regulations extend to maintenance, cleaning, refurbishment, repairs and other building-works and therefore they have a direct impact on commercial cleaning and maintenance contractors, their clients and subcontractors.

In this article we’ll walk through what CDM Regulations are, why they matter for cleaning and maintenance projects, how the key “duty-holders” operate, what practical steps are required from planning through to handover and ongoing maintenance, and some common pitfalls you should watch for. We’ll keep it focussed on cleaning and maintenance rather than large scale construction so you can see exactly how this affects your workflows.

What Are the CDM Regulations and Why They Matter

he CDM regulations are the major UK statutory framework that sets out how health, safety and welfare should be managed in building and construction work. According to the regulatory authority Health and Safety Executive (HSE), CDM provides an overarching aim: to ensure that

“you sensibly plan the work so the risks involved are managed from start to finish; have the right people for the right job at the right time; cooperate and coordinate your work with others; have the right information about the risks and how they are being managed; communicate this information effectively; consult and engage with workers about how the risks are being managed.”

Although CDM was historically thought of in terms of heavy construction activities, the regulations explicitly state that they apply to all building and construction work - including maintenance, repairs, cleaning, demolition, refurbishment, extensions and so on.

For commercial cleaning and maintenance businesses this means that if you are carrying out cleaning or maintenance that involves risk (for example: working at height, confined spaces, major dismantling, moving heavy fixtures, cleaning in occupied premises, deep-cleaning including hazardous substances), you and your client must consider CDM compliance. The benefits of this compliance are tangible: improved safety outcomes, fewer incidents, better coordination between parties, and less exposure to legal risk.

How CDM Regulations Apply Specifically to Cleaning and Maintenance Projects

Although the cleaning/maintenance sector is often seen as less risky than major construction, there are critical ways CDM impacts it:

1. Scope of “construction work” – The regulations cover work that involves building, alteration, repair, upkeep, or cleaning of a structure (including removal, maintenance, cleaning of façade, windows etc).

2. Duty on the client – The “client” who engages the work has responsibilities. Even if the contract is just for a cleaning or maintenance task, the client must ensure that arrangements are in place for managing health, safety and welfare.

3. Planning and risk management – Even for cleaning/maintenance, you need to plan properly: identify hazards (e.g., working at height, wet surfaces, traffic in occupied building, isolation of services), ensure competent persons perform tasks, coordinate subcontractors, and provide relevant information/instruction.

4. Coordination and cooperation – If multiple contractors or cleaning teams are involved, there needs to be coordination: handovers, sequencing, safe access, shared welfare facilities, minimisation of disruption to the occupied premises.

5. Health and safety file/maintenance phase – At the end of a project (cleaning/maintenance may form part of a larger work), the information you produce may feed into maintenance and cleaning operations and be used by future cleaners or maintenance teams to understand residual risks. This is especially relevant in refurbishment and deep cleaning settings.

So, while a standard day-to-day reactive cleaning contract may not trigger the full CDM regime, any project-type cleaning / maintenance (for example, façade cleaning, major cleaning during refurbishment, full deep-clean of building systems, replacing an escalator or heavy fixture) does require consideration of CDM duties.

Key Duty-Holders under CDM Regulations and Their Obligations for Maintenance and Cleaning Projects

The CDM 2015 framework sets out several defined “duty-holders”, each with specific roles. Here’s how they work in the context of cleaning/maintenance:

In a straightforward cleaning contract (say a daily cleaning service with one contractor and no major hazards), you might not have a PD or PC formally appointed, but the duties of those roles still exist (and may be fulfilled implicitly by the client or contractor). The key is to understand your role, what you must do, and ensure you are competent and fulfilling your obligations.

Practical Steps: From Bid to Handover in Cleaning & Maintenance Under CDM Regulations

Here is a walkthrough of the lifecycle of a cleaning/maintenance project under CDM, highlighting what you should do at each stage:

1. Pre-contract/Bid Stage

Before you sign the contract, consider:

• Has the client provided pre-construction information (site hazards, existing conditions, building operations, access, occupied status)? This is particularly important if cleaning/maintenance is happening while the building is live and occupied.

• Are you being asked to work at height, use specialist equipment (hoists, scaffolding), or in confined spaces? If yes, this potentially elevates the risk and brings more rigorous CDM oversight.

• Are your competence, resources, training, and experience clearly documented? Under CDM, every duty-holder must be competent.

• In your method statement or bid narrative, show how you will manage risks, coordinate with other trades (if any), ensure occupant safety, minimise disruption, provide welfare and safe access.

2. Planning and Design Phase (if applicable)

Even for cleaning/maintenance projects, there may be design or planning elements. For example: façade cleaning may require scaffold design; internal maintenance may need system isolation. At this phase:

• The PD (or designer) should be reviewing the work to identify risks to cleaning/maintenance teams, future maintenance, and residual hazards.

• The contractor (your cleaning/maintenance business) should feed into the design/planning process: provide input on cleaning methodology, equipment needs, access, safe routes, temporary works.

• The client should ensure all the key parties are engaged early so risks are managed before execution begins.

3. Construction/Work Phase

This is when the cleaning/maintenance tasks are physically undertaken. Key actions:

• The PC (if appointed) should produce a Construction Phase Plan describing how the works will be carried out safely.

• Coordinate access with building occupants, ensure welfare facilities are provided if required, apply safe systems of work, and ensure communication between all trades present.

• The contractor (you) should ensure your staff are competent/trained, method statements and risk assessments are in place, appropriate PPE and equipment are used, and that you monitor the work and report issues.

• The client should monitor the project and ensure cooperation and coordination is happening.

4. Handover & Maintenance Phase

Once the cleaning/maintenance work is complete (especially if it’s part of a refurbishment or larger project), there are ongoing implications:

• The client should receive and retain a Health and Safety File (where required) which records residual risks and maintenance/cleaning information - this aids future cleaning/maintenance contractors.

• Contractors should tie up loose ends, ensure documentation of what was done and communicate any hazards discovered that might affect future work.

• Maintenance/cleaning teams going forward should understand this file and integrate its findings into their safe systems of work.

What Cleaning and Maintenance Firms Must Watch Out For Under CDM Regulations

When focusing specifically on cleaning and maintenance, here are some common pitfalls and things to watch:

• Assuming “just cleaning” means CDM doesn’t apply – If cleaning involves significant risk (working at height, live services, dismantling, heavy equipment, occupied building disruption) then CDM duties clearly apply. The view that it is “simple cleaning” does not exempt you.

• Poor coordination with other trades – Cleaning often happens alongside other refurbishment or maintenance work. Failing to coordinate can lead to overlapping hazards (e.g., other contractors leaving debris, access changes, changes in services) and breaches of CDM duties.

• Inadequate pre-construction information – If you are not supplied with adequate information by the client or principal designer/contractor about existing conditions, hazards, occupied status, and building systems, you may be exposed to unforeseen risks.

• Competence and training gaps – Your workforce (and subcontractors) must be competent for the task, which means appropriate training, experience, equipment, and supervision.

• Incomplete documentation – Especially in larger maintenance/cleaning projects, you should be documenting your risk assessments, method statements, monitoring records, and any changes. This is vital for CDM compliance and future liability.

• Neglecting residual risks – After cleaning/maintenance works are done (especially if part of refurbishment), residual risks remain. These must be recorded in the health and safety file so that future cleaning/maintenance teams are aware.

• Occupied premises complexities – Cleaning and maintenance often take place while the building is live (occupied by staff, customers or the public). This raises additional hazards: pedestrian traffic, live services, restricted access, working outside standard hours. You must factor these in your planning and coordination.

Quick Reference Table: CDM Regulations – Implications for Cleaning & Maintenance

Real-World Example: Façade Cleaning in a Live Commercial Building

To illustrate how CDM applies in a cleaning/maintenance scenario, consider a major façade cleaning works on a live commercial office building:

• The client (building owner) engages a cleaning firm to remove and clean glazed façade panels and carry out repairs to window-seals.

• The cleaning contractor must plan the work carefully: access via scaffolding or abseiling, coordination of occupant use (office remains live during day), traffic/pedestrian segregation below, waste and debris removal, safe hoisting of panels, isolation of relevant services (perhaps windows or glazing elements).

• Because there are multiple contractors on site (maintenance trades, building management, perhaps mechanical/electrical works), the building owner or principal contractor appoints a Principal Designer and Principal Contractor for the “refurbishment/cleaning” project.

• The Principal Contractor produces a Construction Phase Plan detailing welfare facilities (for the cleaning team), access, segregated walkways for building occupants, emergency evacuation routes, cleaning team induction, interface with other trades (e.g., glazing replacement crews).

• The cleaning contractor provides their method statements, risk assessments, ensures staff are trained, appropriate PPE, safe decanting of cleaning fluids, control of fall-risks, and communicates with the building management and other trades.

• At project handover, a Health & Safety File is generated, capturing permanent access arrangements, cleaning platform details, residue hazards (e.g., sealed glazing system needing periodic cleaning), and this is held by the building management for future cleaning/maintenance.

• Future cleaning teams then refer to the file to understand residual risks and the safe systems established.

How to Use CDM Compliance as a Competitive Advantage in Cleaning & Maintenance

From a business perspective, embracing CDM compliance can actually be a competitive differentiator for a commercial cleaning/maintenance firm:

• Demonstrate competence and commitment – When you show potential clients that you are fully aware of CDM duties, competent in risk assessment, method statements, coordination and documentation, you position yourself as a professional partner rather than just a service provider.

• Bid-winning advantage – Many facilities managers and building owners are themselves aware of CDM obligations. A cleaning/maintenance contractor who demonstrates CDM-aligned processes may be preferred or required.

• Reduced incidents, lower cost – Proper planning and coordination reduce the likelihood of accidents, disruption, or additional cost arising from incomplete planning. This means happier clients and fewer reactive cost overruns.

• Better relationships with other contractors/trades – On multi-contractor sites, cleaning and maintenance firms that engage proactively in the planning/coordination process (rather than reactively) are viewed more favourably.

• Future work and maintenance lifecycle – By participating in the full lifecycle (including handover and health & safety file provision), you can create ongoing contracts for after-care cleaning/maintenance, asset care, facilities management.

In short: rather than seeing CDM as “just another regulation to tick,” consider incorporating CDM-aligned practices into your business model, marketing and service delivery.

Summary and Final Thoughts

In summary:

• The CDM Regulations 2015 apply to all building and construction work in the UK, including cleaning, maintenance, repair and refurbishment tasks.

• European and national regulatory history shows that the aim of CDM is to improve health and safety outcomes through planning, coordination, competent persons and communication.

• For commercial cleaning and maintenance projects, this means you must consider hazards, plan appropriately, identify roles (client, contractor, designer etc), produce documentation, coordinate with other trades and ensure handover information is in place for future operations.

• Cleaning/maintenance firms that proactively engage with CDM responsibilities position themselves as professional, competent, safe and reliable - which can support bids, client relationships and repeat business.

• Ignoring CDM can lead to greater risk of incidents, client dissatisfaction, regulatory exposure and reputational damage.

If you are involved in commercial cleaning or maintenance projects, I recommend carrying out a short audit of your business: check how your bid documents reference risk assessments and method statements, how you coordinate with clients and other contractors, what documentation you provide at handover, and how you train and brief your teams. Integrating CDM awareness into your business is not just good practice; in many cases, it’s the prudent thing to do.