It seems extraordinary that nine years after the CDM Regulations were introduced, there still appears to have been no objective study of their cost and effectiveness.
Instead, Brian Law has to rely on statistics from a 14-year-old European Union study of construction accidents that has been widely misquoted and misunderstood (Letters, 4 June, page 34).

When the authors blamed 35% of site accidents on "unsafe design", they extended the meaning of the word "design" to cover not only the design of the permanent works but also of construction "workspaces" – the propping of excavations, shoring, scaffolding and so on. Realistically, the latter must have been responsible for most of the "unsafe design" accidents they considered, so the proportion of accidents attributable to permanent works design cannot have been more than 10-15%.

It is worth remembering this figure when you hear someone try to justify the Health and Safety Executive's obsession with blaming architects and design engineers for site accidents, or when they repeat the mantra "designers can do more" as if this was the biggest issue in construction safety.

Postscript

A Beal, Leeds, via email