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Designers don’t need CSCS cards to enter construction sites, CIC confirms

The Construction Industry Council (CIC) has issued a clarification on site access rules, in a bid to stop main contractors refusing access to designers.

New regulations around building safety require contractors and clients to check the competence of their subcontractors by law – but the CIC’s statement suggests some firms are asking for the wrong qualifications.

Some major contractors are wrongly demanding CSCS cards from designers who want to enter their sites, according to the body.

“Confusion arises, in part, due to some main contractors deviating from the CLC [Construction Leadership Council] recommendations and insisting that anyone entering their sites must hold a CSCS card,” the CIC said.

The body clarified that designers do not need CSCS cards, and instead should be asked to show other evidence of their competence.

The CIC said CSCS cards are awarded based solely on competence in construction-related tasks, and do not prove competence in design.

The CLC also states that designers and principal designers do not need CSCS cards to access construction sites.

Paul Bussey, who chairs the CIC’s Health and Safety Committee, said the clarification was “long-awaited”.

“For site access, membership of recognised professional designer organisations including adequate evidence of health and safety knowledge is all that should ever be required,” he added.

While a contractor or client must check their appointees are “competent to undertake any work for which they are appointed”, under Regulation 3 of the Building Regulations 2010, that does not mean that everyone must have a CSCS card.

Instead, designers should provide evidence of their relevant qualifications, or their professional registration with a body like the Architects Registration Board or the Engineering Council, the CIC said.

They must also prove they have completed relevant health and safety checks like the CIC check, or those carried out by the Royal Institute of British Architects, and have experience relevant to the job itself.

But the CIC also confirmed that design competence is project-specific.

The confusion flows from an increased focus on competency requirements introduced last year as part of the Building Regulations (Amendment) (England) Regulations 2023.

Contractors and clients are now required by law to “take all reasonable steps” to make sure they appoint competent workers.

New rules around building safety also include keeping a golden thread of information on all projects, and a gateway system to ensure building safety as the project moves forward.

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