Construction phase plan: who needs one, what goes in it, and when

Every project needs one

HSE: “Under the Construction (Design and Management) Regulations 2015 (CDM 2015) a construction phase plan is required for every construction project. This does not need to be complicated.” [HSE CIS80]

HSE says the plan should be proportionate to the size and scale of the job, and that “a simple plan before the work starts is usually enough to show that you have thought about health and safety.” [HSE CDM 2015 FAQ; HSE CIS80]

Who writes it

• The principal contractor, where there is more than one contractor. [reg 12(1)]
• The contractor, where there is only one. [reg 15(5)]
• The client must make sure it is drawn up before the construction phase begins. [reg 4(5)(a)]
• The principal designer must help, by giving the principal contractor the information they hold that is relevant to the plan. [reg 12(3)]
• For a domestic client, the client’s duties are carried out by the contractor or principal contractor, or by the principal designer under a written agreement. [reg 7(1)]

When it must be ready

• The principal contractor draws it up during the pre-construction phase, before setting up the site. [reg 12(1)]
• A sole contractor draws it up as soon as is practicable before setting up the site. [reg 15(5)]

What goes in it

The law: “The construction phase plan must set out the health and safety arrangements and site rules taking account, where necessary, of the industrial activities taking place on the construction site and, where applicable, must include specific measures concerning work which falls within one or more of the categories set out in Schedule 3.” [reg 12(2)]

Site rules are “rules which are drawn up for a particular construction site and are necessary for health or safety purposes”. [reg 2(1)]

Schedule 3: work involving particular risks [Schedule 3]

• Work which puts workers at risk of burial under earthfalls, engulfment in swampland or falling from a height, where the risk is particularly aggravated by the nature of the work or processes used or by the environment at the place of work or site.
• Work which puts workers at risk from chemical or biological substances constituting a particular danger to the health or safety of workers or involving a legal requirement for health monitoring.
• Work with ionizing radiation requiring the designation of controlled or supervised areas.
• Work near high voltage power lines.
• Work exposing workers to the risk of drowning.
• Work on wells, underground earthworks and tunnels.
• Work carried out by divers having a system of air supply.
• Work carried out by workers in caissons with a compressed air atmosphere.
• Work involving the use of explosives.
• Work involving the assembly or dismantling of heavy prefabricated components.

HSE’s checklist for a simple plan [HSE CIS80]

• Plan: key dates, and information from the client about the property, such as where the services and isolation points are, access restrictions, and whether there is any asbestos.
• Organise: the main dangers and how you will control them, such as scaffolding for work at height, supporting structures and excavations to prevent collapse, and preventing exposure to asbestos and building dust; keeping the site safe and secure for the client, their family and the public; toilet, washing and rest facilities; the person responsible for the job running safely; and how supervision will be provided.
• Working together: who else is working on the job, and how you will communicate, coordinate your work with theirs and keep them updated about changes.

Keeping it current

• The principal contractor must make sure the plan is appropriately reviewed, updated and revised throughout the project. [reg 12(4)]
• Where there is more than one contractor, each contractor must follow the parts of the plan relevant to their work. [reg 15(3)(b)]
• The principal contractor must make sure that employers and, if necessary for the protection of workers, self-employed people follow the plan where required. [reg 13(3)(c)(ii)]

Bigger jobs

HSE says a job big enough to be notified to HSE “is likely to be too complex for this simple plan format”. [HSE CIS80]

Under CDM 2015 regulation 6(1), a project is notifiable if the construction work on a construction site is scheduled (planned) to last longer than 30 working days and have more than 20 workers working simultaneously (at the same time) at any point in the project, or exceed 500 person days. [reg 6(1)]

Check whether your project is notifiable with the free F10 checker →

Questions

Do I need a construction phase plan?

Yes. HSE says that under CDM 2015 “a construction phase plan is required for every construction project. This does not need to be complicated.” (HSE CIS80)

Who writes the construction phase plan?

The principal contractor, where there is more than one contractor (CDM 2015 regulation 12(1)), or the contractor, where there is only one (regulation 15(5)). The client must make sure it is drawn up before the construction phase begins (regulation 4(5)(a)).

When must a construction phase plan be in place?

The principal contractor draws it up during the pre-construction phase and before setting up a construction site (regulation 12(1)). A sole contractor draws it up as soon as is practicable before setting up the site (regulation 15(5)).

What should a construction phase plan include?

The health and safety arrangements and site rules for the site, taking account of any industrial activities there, and specific measures for any work in the Schedule 3 categories (CDM 2015 regulation 12(2)).

Do small jobs need a construction phase plan?

Yes, but it should be proportionate to the size and scale of the job. HSE says a simple plan before the work starts is usually enough to show that you have thought about health and safety (HSE CDM 2015 FAQ; HSE CIS80).

Does the construction phase plan need updating?

Yes. The principal contractor must make sure it is appropriately reviewed, updated and revised throughout the project (CDM 2015 regulation 12(4)).