Read this before you instruct a roofer on a shop, unit, hall or farm building. It explains the client's place under CDM 2015, the line between one contractor and several, and what to hand over.
Roof work is construction work, so the Construction (Design and Management) Regulations 2015, usually shortened to CDM, apply to it. The regulations are about health and safety planning from the first conversation to the last handover. They are written for projects of every size, which is why the language can read as if it were meant for a tower crane and not a lean-to on the back of a workshop.
For a homeowner the rules are gentler. The HSE's wording for a domestic client is an individual with construction work done on their own home, and the regulations move that household client's responsibilities across to the contractor. A business, a landlord, a charity or a farm having a commercial roof repaired is not in that position, so the duties stay closer to the person paying.
This guide sets out the duties in general terms. It does not replace the HSE's own guidance or advice from a health and safety consultant on a large project. What it can do is show you the questions that matter before the first quote, and what a roofer on a commercial roofing job should be asking you in return.
The page keeps to the part of CDM that decides most small and medium roof jobs: how many contractors there are, and who writes the plan.
Who is the client on a commercial roof?
Under CDM the client is the party for whom the work is carried out. On a commercial roof that is the person or organisation commissioning the roofer, and it is rarely the roofer's own call. The building's owner, a tenant who holds a repairing lease, a landlord arranging works to a shared roof and a trustee body running a hall can each be the client, depending on who instructs and pays.
The HSE's domestic-client wording helps by showing the edge of the exception. A domestic client is "any individual who has construction work carried out on their home". A unit on an estate, a barn used for a business and a church hall all sit on the other side of that line, and a shop with a flat above is a case to check.
It follows that the shortcut for homeowners, where the contractor carries the client's duties, does not apply here. Regulation 7(1) moves the duties of a domestic client across to the contractor, or to the principal contractor where there is more than one. It is limited to homes, and a trading roof is not a home. If you cannot tell who signs the purchase order, find out before the quote is accepted.
Where the building is shared, settle early who is giving the instruction. If a landlord and three tenants all talk to the roofer, nobody is clearly the client and the plan gets written round a muddle. Name one person, write it into the instruction and tell every occupier.
One contractor or several: where the duties turn
The most useful single fact in CDM for a small roof job is this: the extra duties turn on whether more than one contractor works on the project. They do not turn on how big the job looks.
| Question | One contractor | More than one |
|---|---|---|
| Who writes the plan | The contractor | The principal contractor |
| Domestic client duties | Pass to the contractor | Pass to the principal contractor |
| Who coordinates trades | Nobody needed | The principal contractor |
Regulation 15(5) says that if there is only one contractor working on the project, the contractor must draw up a construction phase plan. A roofer who brings their own scaffolding and does the whole job is that single contractor. A roofer who sublets the scaffold, or a site where an electrician is working alongside the roofer at the same time, begins to look like a project with more than one.
Ask your roofer to say in writing which of the two it is, because the answer decides who holds the paper and who answers for it on the day. Please do not guess the answer by the size of the building. A big warehouse reroofed by one firm is a one-contractor project, whatever the floor area underneath. A small shop with a roofer, a separate scaffold company on a different instruction and a builder opening the wall below is a several-contractor project.
What a construction phase plan covers on a roof
The plan is a short working document, not a binder. For roof work it explains how the job will be done safely, who is on site and what each person must do. A good one is a few pages long, and the people it names have read it before they climb a ladder.
On a commercial roof the plan normally covers these points:
- the access route to the roof and how it is kept clear of the public and staff
- edge protection, and what stops a person or a tool going over the side
- fragile surfaces, rooflights and any sheets that cannot carry weight
- what the asbestos survey found, and what is being done about it
- storage and lifting of materials, and deliveries onto a working yard
- welfare, first aid and who to call in an emergency
- how the plan changes if the weather or the findings on the roof do
The plan is only useful if it is kept up to date as the job reveals things. A tray of old rooflights that turns out to be brittle, a gutter that is rotten along its length or a sheet that cracks under a boot all need to be written in, and everyone on site told.
On a job with us as the only contractor, we write the plan and talk it through before work starts. You see it, and the days of work follow it. Our guide to roof work while a business stays open shows how it fits round trading hours.
What you hand over before the work starts
The client's part is mostly information. A roofer cannot plan round a hazard that nobody has mentioned, and the person who knows the building best is usually the one asking for the quote.
Useful things to pass over at the start:
- Any asbestos survey or register for the building, and the date of the last refurbishment.
- The positions of fragile areas, rooflights and anything you already know is weak.
- Overhead or buried services near the working area, such as power lines, gas pipes or data cables.
- The hours the site is open, who is on it and any areas that must stay clear.
- Any earlier roof repairs, with a short record of the repair and the firm that carried it out.
If you do not hold an asbestos record, say so. The next step then is the survey, and our guide to the asbestos survey before roof work explains it. Pricing before that is guesswork, and so is the plan.
Information also flows the other way. The roofer tells you which areas are out of bounds, when noisy stages happen, and where deliveries will sit. A building with shared yards and loading bays needs these things agreed in advance, because the first week is when a plan is tested.
Keep a copy of the plan with the building records. The next contractor, the next insurer or the next buyer may ask for it.
Working at height, and the highway outside
Roof work puts people at height, and CDM sits alongside the Work at Height Regulations 2005. Under regulation 6(3), an employer must put suitable and sufficient measures in place against any fall liable to cause personal injury, where it is reasonably practicable to do so.
On our jobs that means physical protection first, such as edge protection, scaffold or a mobile platform, and softer measures only after that. Our guides on roof edge protection and fragile surfaces go through those choices in turn, and the plan names the ones chosen for your roof, with the reasons.
The highway matters on a street frontage. If scaffold or a skip stands on or over the public highway, Kent County Council issues the licence or permit under the Highways Act 1980, with the scaffolding or skip company applying for it. Kent County Council asks for 5 working days' notice, charges £52 per week for scaffolding for 2026 to 2027, and the licence holder must hold public liability cover of at least £5 million. A skip permit costs £45 per week for the same year.
Kent County Council's highways team answers questions before an application goes in, on 03000 41 81 81. Build the notice period into your start date, or the plan will promise a day the scaffold cannot keep. A frontage onto a narrow street may also mean the scaffold is built in stages, which the plan should say.
How the price and the start date follow
CDM does not change what a roof costs by itself, but the planning behind it does. A job with proper access, edge protection and a written plan takes time to set up, and that time sits inside the price. Cutting the planning to save money tends to cost more later in delays, accidents or a roof repaired twice, and a stopped job leaves a half-open roof over your stock.
For a commercial building the price is set after a survey. The things that decide it include how high the eaves sit, the covering, how the roof is reached, what stands in the way on the ground and how long the site can be disturbed. The survey comes first, and a single total price follows in writing. It is the one number you compare, not a pile of figures that need adding up.
A sensible order for the client is:
- decide who the client is and who will take the instruction
- find out whether the building has an asbestos record
- ask the roofer how many contractors the job will involve, and who writes the plan
- read the plan and ask for anything you do not understand to be explained
For a roof over an occupied building, the commercial roof survey is where all of this is recorded first. It is the point at which a vague worry turns into a list of things to deal with, with names and dates beside each one. Keep the survey with the plan, the asbestos record and the licence papers in one folder.
