Under the Construction (Design and Management) Regulations 2015, designers have a clear duty to eliminate foreseeable risks during construction, use, cleaning, and maintenance of buildings. Yet, even a decade on from CDM 2015’s introduction, accidents still occur because cleaning and maintenance activities are often overlooked at the design stage. For architects, integrating safe access, inspection, and maintenance solutions from the outset is not only a legal duty — it’s fundamental to good design.
The Legal and Practical Context
Regulation 9 of CDM 2015 requires designers to “eliminate, reduce or control foreseeable risks” through design decisions. This includes risks arising during future cleaning, maintenance, repair, and demolition.
In practical terms, that means considering how building elements — façades, roofs, plant rooms, and windows — will be accessed and maintained safely once the building is occupied. A beautiful design is not compliant if the gutters can’t be reached without a scaffold or the glazing can’t be cleaned without a harness.
Safe Access Starts with Good Design
Architects should work closely with structural and MEP designers early in the design process to identify where maintenance access will be required and what form it should take. Key principles include:
– Permanent safe access wherever possible — such as stairs, ladders, walkways, or platforms designed to BS 5395 and BS 4211 standards.
– Avoiding reliance on temporary systems like mobile towers or MEWPs where fixed access is feasible.
– Designing parapets, guardrails, or edge protection to provide collective fall prevention on roofs and terraces.
– Integrating fall arrest or restraint systems where maintenance at height cannot be avoided.
Early coordination with a Principal Designer or Health & Safety Consultant can identify high-risk maintenance areas and develop practical, compliant solutions before drawings are finalised.
Façade and Roof Maintenance
Façade design often presents the highest cleaning and maintenance risks. Architects should consider how window cleaning will be carried out — whether by internal access, cradle system, or reach-and-wash methods. Integrating safe fixing points, davit arms, or discreet access hatches ensures the building remains maintainable without excessive cost or disruption.
Roof design also demands attention. The layout of plant, drainage, and skylights should allow safe access routes that avoid fragile surfaces. Where gutters or equipment require regular inspection, level and guarded walkways should be provided.
Internal Maintenance Considerations
Safety doesn’t stop at the roofline. High-level lighting, atriums, and plant rooms all require ongoing maintenance. Providing built-in access platforms, removable floor panels, or suspended walkways can prevent unsafe working practices later. Access to plant and MEP services should be logical, unobstructed, and clearly designed with maintenance teams in mind.
The Cost of Oversight
Failure to consider cleaning and maintenance safety can lead to costly retrofits, ongoing reliance on specialist contractors, or even future enforcement under CDM. Clients increasingly expect a building maintenance strategy as part of handover documentation — a reflection of growing awareness that safety must extend beyond practical completion.
Conclusion
Architects play a crucial role in shaping not just how buildings look, but how they are safely used and maintained throughout their lifecycle. By embedding CDM 2015 principles into every stage of design — from concept sketches to detailed sections — architects can create buildings that are both beautiful and safe to operate.
If you’d like support developing compliant cleaning and maintenance strategies or CDM design reviews, contact us today. We work with architects and design teams across the UK to ensure safety is built in — not bolted on.
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