Construction phase plan

Every project, no exceptions

There is no size threshold. A two day bathroom refit needs a construction phase plan just as a twenty storey building does. What changes is the depth. For a small domestic job the plan can be two or three pages; for a complex project it will run to a substantial document with appendices.

The trigger for notification to the HSE is separate and often confused with the plan. A project is notifiable under regulation 6 if it lasts longer than thirty working days with more than twenty workers simultaneously at any point, or exceeds five hundred person days. Notification does not create the plan duty; the plan duty exists anyway.

Who writes the plan depends on the roles on the job, which are set out in the CDM 2015 duty holders explained.

What it must contain

Appendix 3 of the HSE guidance L153 sets out the expected content. The plan is a management document, not a bundle of risk assessments, although the significant ones are referenced from it.

• A description of the project, key dates and the details of the client, principal designer, principal contractor and other duty holders.
• The management arrangements: roles and responsibilities, site induction, welfare, information and training, consultation with workers, and how the plan is monitored and reviewed.
• The arrangements for controlling significant site risks, both those affecting workers and those affecting the public.
• Site rules, including PPE, permits, vehicle movements, hot works and access control.
• Emergency arrangements: fire plan, first aid, accident reporting, site address and rescue from height or excavation.
• Any information from the pre construction information, including the existing structure, asbestos surveys and buried or overhead services.

If anyone will work above ground level, the plan has to reference your working at height rescue plan.

The significant risks that need real detail

The plan should give proportionate attention to the risks that kill people in construction. HSE statistics put falls from height at around half of all construction fatalities year after year, followed by being struck by moving objects and vehicles, collapse and electricity.

For each of those present on your project, the plan needs to say what the method is, who checks it and how often. Vague statements such as scaffolds will be inspected are worthless. Name the inspection frequency, the competent person and where the record is kept.

On refurbishment work the survey comes before the spades, as covered in the asbestos duty to manage during refurbishment.

Domestic clients

Where the client is a domestic client, regulation 7 transfers the client duties to the contractor, or to the principal contractor where there is more than one contractor, unless there is a written agreement placing them with the principal designer. Homeowners rarely know any of this, so the contractor should explain it in plain language at quotation stage.

The practical effect is that on a domestic job the builder is responsible for the client duties as well as their own, including making sure the plan exists and welfare is provided before work starts.

Welfare before work starts

Schedule 2 welfare requirements must be in place from day one, not organised in week two. That means toilets, washing facilities with hot and cold water, drinking water, changing and storage for clothing, and a place to rest and eat that is warm and weatherproof.

Welfare failures are one of the most frequently cited breaches on small sites during HSE inspection initiatives, partly because they are so visible. Record what is provided in the plan, including any shared or client provided facilities and the arrangements for cleaning them.

Keeping it live

A construction phase plan written once and filed is a breach in waiting. Regulation 12(4) requires the principal contractor to update, review and revise it so that it continues to be sufficient. Tie reviews to programme milestones: before each new trade starts, when the sequence changes, after any incident, and at least monthly on longer projects.

Record who reviewed it and what changed, and brief the change at the next site meeting or toolbox talk. When the project finishes, the health and safety file information goes to the principal designer or client, and the plan itself should be retained with the project records.

Common questions

Is a construction phase plan needed for a one day job?

Yes. Every construction project needs one. For a very short, low risk job it can be short and simple, but it must exist before work starts.

Can a template construction phase plan be used?

A template structure is fine. The content must be specific to the project, the site and the actual sequence of work.

Who checks the plan is adequate?

The client must be satisfied that the arrangements are suitable before the construction phase begins, and the principal designer advises on pre construction information.

Related guides

• the CDM 2015 duty holders explained
• working at height rescue plan
• asbestos duty to manage during refurbishment