Section 1
Purpose
At pre-appointment stage, QS firms have both statutory and professional health and safety duties. Statute imposes civil and criminal liability for unsafe acts — principally under the Health and Safety at Work etc. Act 1974 (HSWA 1974) and the Construction (Design and Management) Regulations 2015 (CDM 2015). Professional duties arise under RICS Surveying Safely, 2nd edition (November 2018), which is a mandatory Professional Standard for all RICS-regulated firms.
The two duty streams operate in parallel: even where the QS is not a CDM duty-holder, the firm remains subject to Surveying Safely's requirements for H&S management, risk assessment, and lone-working protocols whenever members visit premises or construction sites.
Pre-appointment is when H&S risks must be scoped, CDM duty-holder roles clarified with the Client, and PII endorsements for any advisory H&S work confirmed. Getting this right at appointment prevents significant exposure downstream.
Section 2
Key Principles
- HSWA 1974 s.2 and s.3 impose general duties on employers and the self-employed to ensure safety "so far as reasonably practicable" — covering employees, visitors, and the public.
- CDM 2015 identifies duty-holders: Client, Principal Designer, Principal Contractor, designers, and contractors. The QS as cost consultant is not automatically a duty-holder, but the QS Scope of Services (May 2022) obliges the QS to advise the Client of their CDM duties.
- RICS Surveying Safely, 2nd edition (November 2018), is a mandatory Professional Standard. It requires firm-level H&S management: written policy, risk assessment, method statements, lone-working protocol, PPE provision, and accident-reporting procedures (including RIDDOR).
- RICS Standard Form of Consultant's Appointment (E&W, April 2025) and Quantity Surveyor Services (E&W, May 2022) both require the QS to advise the Client of their CDM 2015 obligations at appointment stage.
- Rules of Conduct 2021, Rule 2 (Competence) — members must not accept instructions beyond their H&S competence. This is a frequent oversight where junior QS are deployed on high-hazard sites.
- For domestic clients (Reg 7 CDM 2015), the Client's CDM duties default to the Principal Contractor, or to the contractor on a single-contractor project — the Client needs to be told this in writing.
- Surveying Safely applies to every site visit — including pre-appointment reconnaissance — not only to post-contract site inspections.
Section 3
Practical Application
Step 1
Before any site visit (including pre-appointment reconnaissance), complete the Surveying Safely pre-visit checklist — known hazards, emergency contacts, PPE, lone-working check-in plan.
Step 2
At appointment stage, advise the Client in writing of their CDM 2015 duty-holder obligations (Reg 4) — this satisfies the QS Scope of Services clause and creates a defensible audit record.
Step 3
For domestic clients (Reg 7 CDM 2015), confirm whether a Principal Designer and Principal Contractor have been appointed; if not, advise the Client of the default allocation to the Contractor or Principal Contractor.
Step 4
Include H&S scope exclusions explicitly in Terms of Engagement — the QS is not the Principal Designer or Principal Contractor unless expressly appointed and competent.
Step 5
Confirm the firm's PII policy covers H&S advisory work — check for Principal Designer / Principal Contractor exclusions if any site-management role is contemplated.
Step 6
Maintain the firm's H&S Management System per Surveying Safely — annual review, lone-working protocol, training records, and RIDDOR reporting procedures.
Step 7
For higher-risk work — demolition, asbestos surveys, working at height, confined spaces — obtain specialist sub-consultancy advice before commencing and reflect this in the scope and fee proposal.
Section 4
Common Mistakes to Avoid
- Assuming the QS role is risk-free at pre-appointment — site visits and client meetings are "work activities" under HSWA 1974 and attract the full range of statutory duties.
- Failing to advise the Client of CDM duties in writing — a breach of the QS Services scope (May 2022) and a frequent audit finding.
- Undertaking Principal Designer or Principal Contractor roles on domestic projects under Reg 7 CDM 2015 without explicit appointment and a documented competence check.
- Treating Surveying Safely as advisory — it is a mandatory Professional Standard, and compliance is assessed at Firm Regulation review visits.
- No PPE or lone-working protocol for junior QS site visits — a frequent RICS audit failure and a significant HSWA exposure.
- Overlooking PII territorial/scope exclusions for H&S advisory work — gap in cover only becomes apparent after a claim.
Section 5
APC Competency & Quick Reference
This topic is relevant to: Health and Safety (Level 1–2 mandatory across all pathways; Level 3 for specialist roles); Conduct Rules, Ethics and Professional Practice (Level 2–3); Contract Practice and Contract Administration (Level 2–3).
Is the QS a duty-holder under CDM 2015?
Not usually. The QS as cost consultant is not automatically a CDM 2015 duty-holder. The duty-holders are Client, Principal Designer, Principal Contractor, designers, and contractors. The QS's obligation is to advise the Client of their CDM duties, as required by the QS Scope of Services (May 2022).
Source: Construction (Design and Management) Regulations 2015 (SI 2015/51), Regs 4–9 — https://www.legislation.gov.uk/uksi/2015/51/contents/made
What is the RICS Surveying Safely standard?
RICS Surveying Safely, 2nd edition (November 2018), is a mandatory global Professional Standard on health and safety for all RICS members and regulated firms. It covers H&S management systems, site-visit protocols, PPE, lone working, occupational health, and accident reporting.
Source: RICS Surveying Safely, 2nd edition (November 2018) — https://www.rics.org/content/dam/ricsglobal/documents/standards/Surveying-safely-2nd-edition-RICS-professional-standard.pdf
What pre-visit checks must a QS complete before attending site?
Per Surveying Safely: known site hazards identified, emergency procedures understood, PPE specified and available, lone-working plan in place with check-in/check-out protocol, valid H&S induction (CSCS or equivalent where required), and suitable insurance cover confirmed.
Source: RICS Surveying Safely, 2nd edition (November 2018), Section 3 (Site visits and surveys) — https://www.rics.org/content/dam/ricsglobal/documents/standards/Surveying-safely-2nd-edition-RICS-professional-standard.pdf
Section 6
Pre-Appointment Checklist
☐
Firm-level H&S Management System documented per Surveying Safely (Nov 2018)
☐
Pre-visit site hazard check completed before every site visit, including pre-appointment
☐
Lone-working protocol live, with active check-in/check-out process
☐
Client advised in writing of CDM 2015 duties at appointment stage
☐
PII policy confirmed to cover H&S advisory work; PD/PC roles separately endorsed if relevant
☐
Annual H&S training delivered; RIDDOR reporting procedures in place and tested
☐
Terms of Engagement expressly exclude CDM duty-holder roles unless appointed and competent
Section 7
CPD Learning Outcomes
- Identify statutory and RICS professional H&S duties applicable at pre-appointment stage.
- Apply the Surveying Safely pre-visit checklist to a site inspection.
- Advise clients correctly on their CDM 2015 duty-holder obligations, including for domestic clients under Reg 7.
Section 8
Further Reading
- RICS Surveying Safely: Health and Safety Principles for Property Professionals, 2nd edition (November 2018) — https://www.rics.org/content/dam/ricsglobal/documents/standards/Surveying-safely-2nd-edition-RICS-professional-standard.pdf
- Health and Safety at Work etc. Act 1974
- Construction (Design and Management) Regulations 2015 (SI 2015/51) — https://www.legislation.gov.uk/uksi/2015/51/contents/made
- RICS Quantity Surveyor Services (England and Wales), May 2022
- RICS Standard Form of Consultant's Appointment (England and Wales), April 2025 edition
- RICS Rules of Conduct (October 2021, effective 2 February 2022)
Subscriber Content
Sections 3–8 are for subscribers
Your subscription unlocks Practical Application steps, Common Mistakes to Avoid, APC Quick Reference, the Stage Checklist, CPD Learning Outcomes, Further Reading, and all production-ready templates.