Key facts
- CDM 2015 has no minimum size or duration. A one-day repair is a construction project under the Regulations, just a small one.
- Construction work is defined widely: it includes repair, redecoration and maintenance, and the installation, maintenance and removal of electrical, gas, mechanical, telecommunications and similar services fixed to a structure.
- Regulation 15 sets the contractor's duties: plan, manage and monitor the work; appoint only people with the necessary skills, knowledge, training and experience; provide supervision, information and a site induction; prevent unauthorised access; meet the welfare requirements of Schedule 2.
- The only contractor on a project must draw up a construction phase plan, or arrange for one, before setting up the site (regulation 15). It can be short, but it has to exist.
- For a homeowner, the client's duties pass to the contractor on a single-contractor job, or to the principal contractor where there is more than one contractor (regulation 7).
- A project is notifiable to HSE when it is scheduled to last more than 30 working days with more than 20 workers at the same time, or to exceed 500 person-days (regulation 6).
Does CDM apply to your job?
Almost certainly. Regulation 2 defines construction work as building, civil engineering or engineering construction work, and lists what that includes: construction, alteration, fitting out, commissioning, renovation, repair, upkeep, redecoration and other maintenance of a structure; demolition and dismantling; site clearance and excavation; and the installation, commissioning, maintenance, repair or removal of mechanical, electrical, gas, compressed air, hydraulic, telecommunications, computer or similar services normally fixed within or to a structure.
That covers nearly every trade that works on buildings, and it applies on commercial sites and in private homes alike.
- An electrician changing a consumer unit or rewiring a flat
- A plumber or heating engineer replacing a boiler or pipework
- A roofer repairing a pitched roof or replacing a flat roof
- A decorator repainting an office or a house
- An HVAC engineer installing or maintaining air conditioning
- A builder fitting a kitchen, knocking through a wall or building an extension
Who is who under CDM 2015
The Regulations give duties to roles, not to firms of a particular size. On a small job one business often holds more than one role.
| Role | Who it is | Main duties |
|---|---|---|
| Client | The organisation or person, in the course of a business, for whom the project is carried out | Make suitable arrangements for managing the project, provide pre-construction information, appoint a principal designer and principal contractor where there is more than one contractor, notify HSE where required |
| Domestic client | A person having work done on their own home, not in connection with a business | None in practice: their duties pass to the contractor, the principal contractor or, by written agreement, the principal designer |
| Principal designer | The designer in control of the pre-construction phase, on projects with more than one contractor | Plan, manage and coordinate health and safety before construction; help the principal contractor with the construction phase plan; prepare the health and safety file |
| Principal contractor | The contractor in control of the construction phase, on projects with more than one contractor | Plan, manage, monitor and coordinate the construction phase; draw up the construction phase plan; provide site induction, security and welfare |
| Designer | Anyone who prepares or modifies a design, including a contractor who designs part of the work | Eliminate, reduce or control foreseeable risks through the design, and pass on information about the risks that remain |
| Contractor | Anyone who carries out, manages or controls construction work, including sole traders | The regulation 15 duties set out below |
Your duties as a contractor
Regulation 15 applies to every contractor on every project, from a sole trader on a one-day job to a firm on a major site.
- Do not start work unless you are satisfied the client is aware of their duties under CDM
- Plan, manage and monitor your work, and the work of anyone under your control, so it is carried out without risks to health and safety so far as reasonably practicable
- Where there is more than one contractor, follow the principal contractor's directions and the parts of the construction phase plan that apply to your work
- Only employ or appoint people who have, or are gaining, the skills, knowledge, training and experience for the tasks you give them
- Give each worker appropriate supervision, instructions and information, including a site induction where the principal contractor has not provided one, emergency procedures, and the risks identified by your risk assessment
- Do not begin work until reasonable steps have been taken to prevent unauthorised access to the site
- Make sure the welfare requirements of Schedule 2 are met so far as they affect you and your workers: toilets, washing facilities, drinking water, changing and rest facilities
When you are the only contractor: the construction phase plan
If you are the only contractor working on a project, you must draw up a construction phase plan, or make arrangements for one to be drawn up, as soon as practicable before setting up the site. The plan sets out the health and safety arrangements and site rules for the project, and specific measures for any work in the higher-risk categories listed in Schedule 3.
It should be proportionate. For a small single-trade job it can be a few pages, and HSE publishes a short template for exactly this (CIS80). A job-specific RAMS covers much of the same ground, including the hazards, controls and sequence of work, but the plan also has to set out the arrangements for the project as a whole: contacts, site rules, welfare, security and emergencies.
Schedule 3 lists the work that needs specific measures in the plan.
- Risk of burial under earthfalls, engulfment in swampland or falling from a height, where the risk is particularly aggravated by the work, the processes or the site
- Chemical or biological substances that are a particular danger, or need health monitoring by law
- Ionising radiation requiring controlled or supervised areas
- Work near high voltage power lines
- Risk of drowning
- Wells, underground earthworks and tunnels
- Diving, and work in caissons with a compressed air atmosphere
- Use of explosives
- Assembly or dismantling of heavy prefabricated components
Working for homeowners
A homeowner having work done on their own home is a domestic client, and regulation 7 moves their duties to the people doing the work. On a job with only one contractor, that contractor takes on the client's duties as well as their own, including making suitable arrangements for managing the project and notifying HSE if the project is large enough.
Where more than one contractor will work on the project, a principal designer and a principal contractor are needed. If the homeowner does not appoint them, the designer in control of the pre-construction phase becomes the principal designer, and the contractor in control of the construction phase becomes the principal contractor, who then carries the client's duties too.
Notifying HSE
A project is notifiable if its construction work is scheduled to last longer than 30 working days and have more than 20 workers working at the same time at any point, or to exceed 500 person-days. Notification is the client's duty, made on HSE's form F10 before the construction phase begins, and the notice must be displayed in the site office. For a domestic project it falls to the contractor or principal contractor who has taken on the client's duties.
Most small jobs are not notifiable, but that changes nothing else: every other duty in the Regulations applies to a project whether it is notified or not.
Questions
Sources
The legislation and HSE guidance this guide is based on. Legislation links go to the revised text on legislation.gov.uk.
- The Construction (Design and Management) Regulations 2015 · legislation.gov.uk
- CDM 2015, regulation 5 (appointment of the principal designer and principal contractor) · legislation.gov.uk
- CDM 2015, regulation 6 (notification) · legislation.gov.uk
- CDM 2015, regulation 7 (application to domestic clients) · legislation.gov.uk
- CDM 2015, regulation 12 (construction phase plan and health and safety file) · legislation.gov.uk
- CDM 2015, regulation 15 (duties of contractors) · legislation.gov.uk
- CDM 2015, Schedule 2 (minimum welfare facilities required for construction sites) · legislation.gov.uk
- CDM 2015, Schedule 3 (work involving particular risks) · legislation.gov.uk
- Managing health and safety in construction: CDM 2015 guidance on regulations (L153) · Health and Safety Executive
- CDM 2015: contractors · Health and Safety Executive
- CDM 2015: domestic clients · Health and Safety Executive
- Construction phase plan (CDM 2015) (CIS80) · Health and Safety Executive
- Notification of construction project (F10) · Health and Safety Executive
This guide is general information about UK health and safety practice. It is not legal advice, and it does not replace a competent person's assessment of your own work.
Write yours in minutes
Describe the job, answer the questions a site would ask, and RAMS Pal produces a job-specific RAMS to review, edit and issue. From £14.90, no subscription.
RAMS Pal is a documentation support tool. Generated content must be reviewed and adapted to the actual work, site conditions, workforce, equipment and applicable health & safety requirements.