Article Summary
The Building Safety Act has transformed expectations of design responsibility in healthcare estates, placing accountability and coordination at the centre of patient safety. In this article, Ben Palmer, Partner at QPArchitecture, explains why the Principal Designer role is no longer administrative, but a leadership position that shapes compliance, risk and outcomes from the earliest stages of design.
For decades, healthcare capital projects have relied on a familiar structure of lead consultants, specialist designers and regulatory checkpoints. Compliance was often treated as a milestone to be reached rather than a system to be continuously managed. That model is no longer sufficient. The introduction of the Building Safety Act has fundamentally reshaped expectations of accountability, competence and leadership in the design of higher-risk buildings – particularly within healthcare estates. At the centre of this shift sits a role that is still widely misunderstood, the Principal Designer.
For Ben Palmer, Partner at QPArchitecture, and a RIBA-registered Principal Designer for Higher-Risk Buildings, the most significant change brought about by the act is not administrative. It is cultural. In healthcare environments, where buildings are clinically complex, heavily regulated and continuously evolving, poor design coordination does not simply result in cost overruns or programme delays. It creates patient safety risk.
A Shift in Responsibility
One of the most common misconceptions across healthcare projects is that the Principal Designer role under the Building Safety Act is simply an extension of the CDM Principal Designer role. In practice, the two are fundamentally different. Under CDM, the Principal Designer is focused on managing health and safety risks during construction – how the building is built, how contractors work on site and how risks are controlled during delivery and operation.
The Building Safety Act moves that responsibility upstream. Here, the Principal Designer is accountable for managing building regulations compliance throughout the design process itself. As Palmer explains, âThe real difference under the Building Safety Act is that youâre managing building regulations compliance during the design process. CDM is about managing the health and safety side during construction. This is about making sure weâve hit the building regs at a minimum and that weâve got a compliance and accountability schedule that records everything thatâs happened.â That accountability is not theoretical, it requires evidence and a clear, traceable record of decisions, risks and design coordination that can be interrogated long after handover.
Why Healthcare Projects Raise the Stakes
Healthcare environments are uniquely exposed to the risks the Building Safety Act is designed to address. Acute hospitals, mental health facilities and specialist treatment centres must operate continuously, accommodate high numbers of occupants, many of whom are clinically vulnerable, while relying on intricate building systems that support care delivery around the clock. These environments are also governed by NHS-specific guidance – HTMs and HBNs – layered on top of building regulations. In this context, fragmented design responsibility is not just inefficient. It is unsafe. Palmer notes that problems rarely appear where coordination has genuinely happened, “One of the highlights of the role is coordination and confirming that the coordination is actually taking place in its entirety.”
Where that coordination is missing, the consequences tend to surface later: during construction, during commissioning, or worse, once the building is in use. At that point, issues that should have been resolved through design become compliance-driven redesign or operational compromise in live clinical settings. The purpose of the Principal Designer role, when embedded early, is to prevent that outcome.
The Rise of the âDesign Freezeâ
One of the most practical shifts Palmer describes is the use of an early, disciplined âdesign freezeâ, not as a rigid end point, but as a moment of shared understanding of where responsibility sits at a given moment in time. As Palmer explained,
Itâs hard to ever truly freeze a design. The important thing is being able to highlight why there is a change after that point and documenting it in a way that means everyone can be correctly accountable throughout the process
In complex healthcare refurbishments and extensions, change is inevitable. Existing buildings, legacy infrastructure and product availability all introduce variables outside a designerâs control. The risk arises when changes are made informally or without full appreciation of their regulatory impact. By introducing structured gateways earlier in the design process, Principal Designers can help teams clarify:
- What was agreed
- Why it was agreed
- Who was involved
- What risks were assessed
This creates a live evidence base that supports compliance and improves lessons-learned processes – replacing hindsight reviews with real-time understanding.
Misaligned Scopes and Misunderstood Liability
Many of the challenges Palmer encounters have little to do with technical design complexity. Instead, they stem from misalignment – particularly between consultant scopes of service and the legal duties imposed by the Building Safety Act.
Thereâs often a misunderstanding of what someone must do and whatâs written down contractually. Thatâs something that needs to be resolved at project kick off, not halfway through delivery.
Too often, scopes are inherited from legacy templates that predate the Act, leaving gaps between perceived responsibility and legal obligation. Client understanding is equally critical. Informal site decisions or direct agreements with contractors may feel pragmatic, but under the Act, responsibility is shared across the client, Principal Designer and Principal Contractor. As Palmer said, âThe point is that weâre all liable because weâre all writing down that weâve evidenced whatâs occurred. Itâs not one person changing something, itâs a group decision.â This shared liability model is not about risk transfer. It is about ensuring that coordination is real, decisions are transparent, and safety is protected throughout the buildingâs lifecycle.
Integration as Risk Control
This is where integration moves from being a productivity goal to a compliance requirement. A fully integrated methodology, supported by a robust BIM protocol and a well-managed Common Data Environment (CDE), significantly reduces risk for the Principal Designer. When design developments are captured within a shared digital environment, decision-making becomes transparent, changes are recorded, responsibilities are clear and an auditable trail of compliance is created as the design evolves. In complex healthcare projects, teams often change between stages. Without a structured information model, critical design intent and risk decisions are easily diluted or lost. A well-managed BIM environment allows the Principal Designer to maintain continuity of accountability across the life of the project, rather than repeatedly reopening resolved issues.
Equally important is the cadence of engagement. Regular, well-structured design team meetings, with contractor input where appropriate, allow risks to be tested and resolved while there is still flexibility in the design. This enables the Principal Designer to lead proactively, steering the project away from non-conformance before issues harden and before Building Control intervention forces redesign.
Coordination as Clinical Risk Management
At its best, the Principal Designer role functions as a form of clinical risk management applied to the built environment. In healthcare settings, failures in coordination can result in:
- Increased costs through variations
- Extended programme
- Unsafe design
- Disruption to live services post-handover
Each of these carries significant clinical and organisational consequences. Early, competent design leadership is therefore not an overhead. It is a risk mitigation strategy. When coordination, evidence and accountability are embedded from the outset, the likelihood of latent risks emerging during construction or operation is significantly reduced.
The Value of Senior Involvement
The Building Safety Act also exposes the limits of fragmented leadership. Palmer observes that in larger organisations, responsibility is often distributed across multiple layers, with limited continuity of leadership. Smaller, specialist practices can offer an alternative, âWe demonstrate leadership through clear accountability and senior involvement throughout the entire project,â Palmer observes. This matters because the Act demands not only competence, but demonstrable competence. Clients and regulators alike need to understand who was responsible, when and on what basis decisions were made.
Practical Advice for NHS Estates Teams
For NHS estates teams navigating this shift, Palmerâs advice is direct,
Early competent design leadership is the most effective way to manage risk. It protects patients and avoids costly compliance failure later
That means appointing the Principal Designer early, aligning scopes with legislation, embedding evidence creation into everyday design workflows and treating compliance as a design outcome – not an audit exercise. Above all, it means recognising that the Building Safety Act is not asking for more documentation, it is asking for better decisions. As enforcement tightens, the role of the Principal Designer will continue to evolve. But its direction is already clear. This is not an administrative role. It is a strategic one. Healthcare organisations that recognise design responsibility as leadership rather – than delegation – will be far better positioned to deliver safe, compliant and resilient estates. Those that do not will increasingly find themselves exposed.
