The short answer
The Construction (Design and Management) Regulations 2015 apply to roof work on commercial and domestic buildings alike. Whoever commissions the work is the client and carries duties, such as making sure the contractor has what it needs to work safely and passing on what is known about the building. On a house, much of this is normally picked up by the contractor. Ask your roofer to explain in writing who holds which role.
A plain guide to the client's part under CDM 2015 when a roof is repaired, overlaid or replaced, on a semi, a parade shop or a factory unit.
Who counts as the client
Under the Construction (Design and Management) Regulations 2015, the client is the person or organisation for whom a project is carried out. For a roof job that is whoever signs the quote and pays the bill. On a factory unit that may be the tenant or the landlord, depending on the lease. On a shopping parade it may be a managing agent acting for the owners. On a house it is the homeowner.
Being the client does not mean you have to supervise the work. It means the law gives you a short list of responsibilities, because the decisions you make early on, such as the budget, the date and the access, shape how safely the work can be done. If the roof is shared, or the building has several occupiers, agree in writing who is acting as client before anyone starts.
This page is general information, not legal advice. For your own building, check the HSE guidance on the regulations or take advice from a professional adviser. We cover the practical side below, because it is what we see on the ground when we survey a roof.
Commercial and domestic clients are treated differently
The regulations draw a line between commercial and domestic clients. A commercial client is expected to take an active part: to make suitable arrangements for the project, to allow enough time and money for the work to be done safely, and to give the contractor the information it needs about the building. That includes known hazards, such as a fragile roof, or asbestos in the existing covering.
A domestic client, meaning someone having work done on their own home, has the same duties in principle, but under the rules they are normally passed to the contractor, or to the principal designer where there is one. In practice a homeowner mainly needs to choose a roofer who understands their role and to share what they know about the house.
The line is not always obvious. A landlord with a block of flats, or a business owner who also lives above the premises, may not fall neatly into one box. If you are unsure which applies, ask before the quote is accepted, because it changes who prepares the paperwork.
What the roofer needs from you, and what you should expect back
Before we price a commercial roof, we ask what you already hold. That means previous surveys, any asbestos register or report, drawings of the roof, notes on services passing through it, and details of rooflights and plant. HSE says to assume asbestos is present in anything built or refurbished before 2000, and its asbestos cement guidance warns that such roofs are always fragile. A roofer who is not told that can step onto a roof that will not carry them.
In return, expect a clear method for the job: how people and materials get onto the roof, how edges and openings are protected, how fragile areas are marked, and how neighbours and the public are kept safe. Our guides on roof edge protection and fragile roof safety go through those controls in more detail.
Ask also how the contractor will brief its own people, and how it will tell you about anything unexpected, such as a rotten deck found after the old covering is lifted.
Paperwork, larger projects and your next step
The amount of paperwork grows with the project. A small repair needs the basics: who is on site, what they will do, and how they will do it safely. Every project needs a written construction phase plan in proportion to the job, drawn up by the principal contractor where there is more than one contractor, and some larger projects must be notified to the HSE. The regulations set the thresholds, so check the current figures on the HSE site rather than relying on anyone's summary, ours included.
Keep the paperwork afterwards, filed somewhere the next manager will find it. Information about the roof that is produced during the job, such as the make-up of the new build-up, the position of fixings and any asbestos found, helps whoever works on the roof next.
What helps us most is the building's address, a note of the roof's age and any reports you already hold. We use them in the survey, then give you one written total with a plain description of the working method. See also our guide to commercial roof condition surveys, and our commercial roofing page.
More on this in Commercial Roofing in Crawley & Gatwick
Two CDM questions from roof clients
Does a small roof repair on a shop fall under CDM?
The regulations apply to construction work of any size, which includes repairs, so a client still has duties on a small job. What changes is scale: the planning and paperwork should match the risk. A simple repair needs a short, sensible method and safe access. Ask the roofer to put in writing how the work will be done and who is responsible.
Can I pass all the CDM duties to my roofer?
Not entirely. A commercial client keeps duties that the contractor cannot take over, such as providing information about the building and allowing enough time and resources. The contractor takes on its own duties for how the work is carried out. For anything beyond a simple job, read HSE guidance or take advice from a professional adviser.