Under the Construction (Design and Management) Regulations 2015, the client must appoint a principal contractor whenever more than one contractor will work on a project. The principal contractor is in charge of health and safety during the construction phase: planning it, managing it, monitoring it and making sure everyone on site works together.
When you are the principal contractor
The client appoints the principal contractor in writing where there is, or is likely to be, more than one contractor. If the client fails to appoint one, the client must carry out the principal contractor’s duties itself. Where only one contractor works on a project, that contractor must still plan, manage and monitor the work and draw up a construction phase plan.
The duties
- Plan, manage, monitor and coordinate the whole construction phase.
- Draw up a construction phase plan before the construction phase begins, then put it into practice and review and revise it regularly.
- Make sure every worker has a site-specific induction, and any further information and training they need.
- Take steps to prevent unauthorised access to the site.
- Provide suitable welfare facilities from the start and maintain them throughout the construction phase.
- Consult and engage with workers about their health, safety and welfare.
- Liaise with the principal designer throughout the project, including sharing information for the health and safety file.
Coordinating contractors
Many accidents on multi-contractor sites happen where trades meet. Appoint contractors with the skills, knowledge and experience for the work, check their RAMS before they start, and hold regular coordination meetings and daily activity briefings so each trade knows what the others are doing and where.
Monitoring: the records that show it happened
- Daily and weekly site inspections, and the actions raised from them.
- Permits to work issued and closed for high-risk activities.
- Inspections of scaffolds, excavations, lifting equipment and temporary works.
- Induction, briefing and toolbox talk attendance.
- Accident, near miss and observation reports, with RIDDOR reports where required.
- A site diary and progress records.
The health and safety file
The principal designer prepares the health and safety file, but the principal contractor must give it the information it needs during the project, such as as-built drawings, operating and maintenance information and residual hazards. If the principal designer’s appointment ends before the project does, the file passes to the principal contractor to keep up to date and hand to the client at the end.
Frequently asked questions
Does CDM 2015 apply to small jobs?
Yes. CDM 2015 applies to all construction work, whatever its size. What changes with size is how much paperwork is proportionate, and whether the project has to be notified to HSE.
What happens on a domestic project?
Where the client is a domestic client, their duties normally pass to the contractor, or to the principal contractor where there is more than one contractor, unless the domestic client agrees in writing for the principal designer to take them on.
Who makes sure there is a construction phase plan?
The principal contractor draws it up, and the client must make sure one is in place before the construction phase begins.
This guide is general information for UK businesses, not legal advice. Check the current regulations and HSE guidance at hse.gov.uk, and take professional advice for your situation.