THE CONSTRUCTION Industry Council (CIC) has clarified that construction design professionals do not need a Construction Skills Certification Scheme (CSCS) card to prove competence.

It follows confusion over the roles of designers and principal designers presenting evidence of competence to gain construction site access.

The Building Regulations say anyone appointing builders or designers must ‘take all reasonable steps’ to ensure they are competent.

Part 2A of the Building Regulations (Amendment) (England) Regulations 2023 says they must satisfy themselves that the person being appointed fulfills the general competence requirements of Regulations 11F (1) and (2) and duty to plan manage and monitor work in Regulation 11J.

Designers Don’t Need CSCS Cards

These regulations apply to anyone engaged on any controlled building work as defined in Regulation 3 of the Building Regulations 2010.

The regulations do not require the possession of a CSCS card for this purpose.

However, anyone appointed to carry out building or design work would be still expected to include evidence of competence.

This could be relevant qualifications, professional registration with an appropriate body such as the Architects Registration Board (ARB), Engineering Council, or relevant professional body.

Other evidence could be 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.

Competence in Tasks

The CIC clarification explains CSCS cards are awarded based on competence in construction-related tasks. They do not provide evidence of competence to act as a designer or principal designer.

The confusion is thought to partly stem from some main contractors deviating from the CLC recommendations and insisting that anyone entering their sites must hold a CSCS card.

Paul Bussey, Chair of CIC’s H&S Committee said: “This clarification by CIC is a long awaited correction to the ‘designer & principal competence requirements’ that has prevailed under the CDM Regulations since 2007 and even earlier. 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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