HSE Professional Guide · Safety & Health Coordination · Issue 2
Same on Paper, Different in Practice — HSE Coordination in the Design Phase: Hungary and the World
Every European construction project operates under the same EU Directive. Yet in some countries the HSE coordinator in the design phase is a strategic team member shaping safety into the drawings. In others, they sign a document and move on. What happens between those two realities — and what can we learn from each other?
1 · The Common Foundation: EU Directive 92/57/EEC and National Implementations
The shared legal foundation of European construction safety is EU Directive 92/57/EEC on the minimum safety and health requirements for temporary or mobile construction sites. The Directive is binding on all EU member states, but implementation — and enforcement — remains a national prerogative. This explains how dramatically different outcomes can emerge from an identical legal starting point.
Sweden updated its framework with effect from 1 January 2025: AFS 1999:3 was replaced by AFS 2023:3 (Design and Building Work Environment Coordination). One of the most significant changes: the competence requirement now extends to the client's own representative and to manufacturers of prefabricated building elements — not just the appointed BAS-P/U coordinator.
| Aspect | Hungary | United Kingdom (CDM 2015) | Sweden / Norway (SE / NO) |
|---|---|---|---|
| Legal basis | Decree 4/2002 SZCSM-EüM (am.: GFM 64/2023) | CDM 2015 (SI 2015/51) | SE: AFS 2023:3 (in force: 1 Jan 2025) NO: AML + FOR-1995-945 |
| EU Directive | 92/57/EEC | 92/57/EEC | 92/57/EEC |
| Design coordinator title | Safety & Health Coordinator | Principal Designer | SE: BAS-P (Byggarbetsmiljösamordnare) NO: SHA-coordinator |
| Must be a designer? | Not required | Yes — mandatory | Not legally required; industry standard: yes |
| Client duties explicit? | Limited, not explicit | Yes — CDM Reg. 4; criminal liability possible | Strong — client appoints BAS-P and must verify competence |
| Penalty scale | Labour authority fines | GBP 10,000 – 1M+; imprisonment possible | SE: Authority fines NO: Arbeidstilsynet – fines + stop orders |
| BIM integration | Not regulated | Recommended; mandatory on some projects | SE: mandatory on public projects NO: digital docs standard |
| H&S Plan | Safety & Health Plan (BE terv) — mandatory, content not fully prescribed | Construction Phase Plan — mandatory, detailed guidance | SE: Arbetsmiljöplan NO: SHA-plan — mandatory, content prescribed |
| Small project obligations | Above notification thresholds only | All projects | SE: all projects, any size NO: all employer-coordination situations |
Sources: Decree 4/2002 | CDM 2015 (SI 2015/51) | AFS 2023:3 | AML + FOR-1995-945 | EU Directive 92/57/EEC
2 · The Hungarian Framework — What the Law Requires, and Where It Falls Short
What the Regulation Prescribes
Decree 4/2002 SZCSM-EuM defines two distinct coordinator roles:
- Design-phase coordinator: the designer is legally required to engage a coordinator during the preparation of construction design documentation [Section 3(1)]
- Construction-phase coordinator: responsible for the safe delivery of the project and for keeping the Safety and Health Plan (BE terv) up to date
Where the Framework Falls Short
The regulation defines who must engage a coordinator and when, but does not prescribe the substantive content requirements in sufficient detail. There are no minimum content standards for the BE terv, no mandatory format for documenting design-phase meetings, and no explicit requirement for the coordinator to attend design team reviews.
In practice, this flexibility often produces formal compliance rather than genuine integration: the BE terv is produced, but the safety questions are never asked at the design table.
3 · CDM 2015 (UK) — A Different Philosophy, Different Outcomes
The evolution of the UK's Construction (Design and Management) Regulations is instructive. From their introduction in 1994 through to the 2015 reform, the regime has gone through three successive revisions — each one a direct response to a specific failure mode identified in practice.
The 2015 reform rationale: the Lofstedt Report found that the coordination function in the pre-construction phase was often not genuinely embedded in the project — it functioned as a bureaucratic add-on rather than a design discipline. The response: the CDM coordinator role was replaced by the principal designer, who must be a designer with actual control over the pre-construction phase.
ℹ️ The key distinction
Under CDM 2015, the principal designer does not merely coordinate — they actively manage the integration of HSE considerations into the design itself, with design authority and integration responsibility. This is not an administrative role; it is an engineering responsibility.
The second fundamental difference: CDM 2015 places explicit duties on the client. If the client failed during the design phase — for example, by not appointing a principal designer, not providing pre-construction information, or not assembling a competent team — the client is subject to prosecution and fine, in addition to any contractor liability.
4 · The Scandinavian Model — BAS-P, BAS-U and Client Accountability
Sweden — AFS 2023:3 (in force: 1 January 2025)
In the Swedish system, every construction and civil engineering project requires two appointed coordinators: BAS-P (Byggarbetsmiljosamordnare for Planering — design phase) and BAS-U (execution phase). The client appoints both and is responsible for verifying that they hold the required qualifications, competence, and experience appropriate to the scale and nature of the project.
Key innovation of AFS 2023:3 (2025): the competence requirement has been extended to the client's own representative and to manufacturers of prefabricated building elements. Safety accountability no longer rests solely with the appointed coordinator — documented competence must be demonstrated on the client side as well.
The BAS-P's mandate: to participate in the design process, coordinate all work environment issues during the planning and design phase, produce the Arbetsmiljoplan (work environment plan), and identify risks that may arise during the construction phase. The explicit goal is to eliminate or minimise hazards at the drawing board stage — before they are built into the project.
Norway — AML + FOR-1995-945
The Norwegian framework is built on the Arbeidsmiljoloven (Working Environment Act, AML, 2006), supplemented by Regulation FOR-1995-945 for construction project coordination. The SHA-coordinator (Sikkerhet, Helse og Arbeidsmiljo) is responsible for integrating safety, health, and working environment considerations from the design phase onwards.
Norway's enforcement body, Arbeidstilsynet, operates with active site inspection capability and immediate stop-work authority. Sanctions are not limited to fines — construction permits can be suspended. This enforcement intensity creates a materially different compliance culture from Hungary's labour authority model.
💡 What defines the Scandinavian approach?
- The coordinator is an integrated member of the design team — not an external appointment
- Risks are built into the permit drawings: scaffolding zones, emergency evacuation routes, and maintenance access paths appear on the design documents
- Client responsibility extends not just to the appointment, but to verifying and documenting the competence of those appointed
- The obligations apply to all projects, regardless of size or notification threshold
- Digital documentation and BIM integration are standard expectations; mandatory on public-sector projects
5 · Good vs. Poor Practice in the Design Phase — Side by Side
| ✕ Poor Practice | ✓ Good Practice |
|---|---|
| Coordinator engaged only after planning permission is granted | Coordinator involved from the pre-design stage onwards |
| The Safety & Health Plan (BE) is a formal administrative document only | The H&S Plan is a living document, continuously updated |
| Coordinator has no access to design drawings or documentation | Risk annotation on drawings – hazardous phases identified at source |
| Client is unaware of their own HSE responsibilities | Client duties explicitly regulated and enforceable (CDM Reg. 4) |
| HSE requirements conflict with the designer's vision – and safety loses | Coordinator acts as design integrator within the project team |
| Asbestos and PCB identified only during demolition works | Hazardous materials identified on pre-demolition drawings |
| Subcontractors only identified at the start of the construction phase | Interface risks mapped and managed at the design stage |
HSE Coordination – Design Phase · HSE Professional Guide · 2026
6 · What Hungary Can Learn — and What No System Has Fully Solved
What Is Worth Adopting
- The principal designer / BAS-P model: the design-phase coordinator should hold design competence and have genuine access to — and influence over — the drawings
- Explicit client duties with competence verification requirements — modelled on the Swedish AFS 2023:3 extension to the client's own representative
- Minimum content standards for the Safety and Health Plan: prescribed content requirements and mandatory risk annotation on design drawings
- Proportionate enforcement with stop-work authority — modelled on Norway's Arbeidstilsynet, with fines calibrated to organisational scale and risk severity
- BIM integration incentives and mandatory requirements on public-sector projects — consistent with the Scandinavian standard
- Extension of competence requirements to the client side, not just the nominated coordinator
What No System Has Fully Solved
The CDM 2015 reform was itself triggered by the failure of the previous version to reduce bureaucracy while genuinely improving safety outcomes. The Scandinavian model is among the strongest in practice, but even there the integration of smaller subcontractors (fewer than 10 employees) into design-phase safety planning remains a persistent challenge. The shared problem: how do we make safety a genuine design decision — not a compliance exercise — on every project, not just the large ones?
Closing Thought
The legal framework exists. The EU Directive, Decree 4/2002, and the 2023 amendment establish the foundation. The question is whether the content of those regulations actually materialises at the design table — or only in a signed document.
The British, Swedish, and Norwegian examples converge on the same conclusion: where the coordinator is a genuine integrator — where the client, designer, and coordinator think about safety together before the first drawing is issued — the outcomes are measurably better: fewer incidents, fewer stoppages, and lower consequential costs.
"The rules are similar on paper. The difference lies in how the role is understood, where in the process it begins, and who is held accountable when it fails."