The fact is that designers and principal designers are not required to have Construction Skills Certification Scheme (CSCS) cards – so could ignorant contractors kindly please stop asking to see them.
“It is rife across the industry,” said architect Paul Bussey, chair of CIC’s health and safety committee, “creating unnecessary time wasting and cost to designers having to justify their own expertise, for others without competence, to profit.”
He blamed “misinformed contractors and clients who are advised by so called CDM or health & safety experts, who in turn do ‘designer competence assessments’ for a fee, or expect CSCS cards for their site access”.
He said: “For site access, membership of recognised professional designer organisations including adequate evidence of health and safety knowledge is all that should ever be required.”
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In its “clarification” on the matter of professional construction consultants demonstrating competence, the CIC said: “There has been some confusion regarding designers and principal designers presenting evidence of competence. There is no regulation that requires them to obtain a CSCS card to demonstrate this. CSCS cards are awarded based on competence in construction-related tasks and do not provide evidence of competence to act as a designer or principal designer.
“It is also explicitly stated by the Construction Leadership Council (CLC) that designers and principal designers do not need a CSCS card to access a construction site. Confusion arises, in part, due to some main contractors deviating from the CLC recommendations and insisting that anyone entering their sites must hold a CSCS card.”
The situation appears to have got worse since Part 2A of the Building Regulations (Amendment) (England) Regulations 2023 introduced requirements for any person who is proposing to appoint another person to carry out building or design work to take all reasonable steps to satisfy themselves that the person being appointed fulfils the general competence requirements of Regulations 11F (1) and (2) and duty to plan manage and monitor work in Regulation 11J. This created an industry for designer competence assessments.
However, the CIC – the umbrella body for most of the construction industry’s professional institutions – explained: “These regulations apply to anyone engaged on any controlled building work as defined in Regulation 3 of the Building Regulations 2010; they must be competent to undertake any work for which they are appointed. The regulations do not require the possession of a Construction Skills Certification Scheme Card for this purpose. Evidence that anyone appointed to carry out building or design work is competent would be expected to include evidence of relevant qualifications, professional registration with an appropriate body such as the Architects Registration Board (ARB), Engineering Council, or relevant professional body, evidence of completion of a suitable health and safety test such as the CIC or RIBA health and safety test or evidence of experience relevant to the current appointment. Competence is project specific.”
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