Construction Phase Plan: CDM 2015 Requirements

The Construction Phase Plan is a legal requirement under the CDM Regulations 2015 for managing health and safety during construction work. It sets out the health and safety arrangements and site rules for the construction phase, detailing how risks will be controlled and how the project will be managed safely.

What is a Construction Phase Plan?

The Construction Phase Plan is a document that describes the health and safety arrangements and site rules for the construction phase of a project.

It's a practical, working document that:

• Sets out how health and safety will be managed on site
• Identifies significant risks and how they'll be controlled
• Describes site rules and arrangements
• Details emergency procedures and welfare facilities
• Provides information for everyone working on the project

Purpose of the Construction Phase Plan

The plan serves several essential purposes:

For the Principal Contractor:

• Demonstrates how they'll fulfil their CDM duties
• Provides a framework for managing site health and safety
• Records key decisions and arrangements
• Shows how risks identified in design will be managed

For contractors and workers:

• Communicates site rules and procedures
• Explains how specific risks will be controlled
• Sets out welfare and emergency arrangements
• Clarifies responsibilities and reporting lines

For the client:

• Provides assurance that arrangements are suitable
• Demonstrates compliance with CDM before work starts
• Records the management structure and approach

For HSE inspectors:

• Shows the project is properly planned and managed
• Demonstrates understanding of risks and controls
• Evidences compliance with CDM Regulations

When is a Construction Phase Plan required?

The requirement for a Construction Phase Plan depends on the nature and size of the project.

Notifiable projects

A Construction Phase Plan is legally required on all notifiable projects.

A project is notifiable if the construction work is expected to:

• Last more than 30 working days and involve more than 20 workers at any point, OR
• Exceed 500 person days of work (e.g., 10 workers for 50 days)

On notifiable projects:

• The Principal Contractor must prepare the plan
• It must be prepared before the construction phase begins
• Construction work must not start until the plan is in place
• The client must review and be satisfied the plan is appropriate

Non-notifiable projects with multiple contractors

Even when a project isn't notifiable, if there's more than one contractor, health and safety arrangements must be planned and coordinated.

While CDM 2015 doesn't explicitly use the term "Construction Phase Plan" for non-notifiable projects, Regulation 8 requires contractors to plan, manage, and monitor construction work.

In practice:

• The lead or main contractor should prepare arrangements similar to a Construction Phase Plan
• It can be proportionately simpler than on notifiable projects
• It should still address coordination, site rules, and key risk controls
• The client should ensure suitable arrangements are in place

Single contractor projects

When there's only one contractor:

• No formal Construction Phase Plan is required under CDM
• But the contractor must still plan, manage, and monitor their work (Regulation 8)
• A written plan or risk assessment/method statement approach is good practice
• The level of documentation should be proportionate to the risks

Who prepares the Construction Phase Plan?

Responsibility for preparing the Construction Phase Plan depends on the project structure.

On notifiable projects

The Principal Contractor must prepare the Construction Phase Plan (Regulation 12(1)).

The Principal Contractor is the contractor appointed by the client under Regulation 6 to coordinate the construction phase on notifiable projects.

They must:

• Prepare the plan before construction work begins
• Ensure it's appropriate for the project
• Keep it up to date as work progresses
• Make relevant parts available to contractors and workers

On non-notifiable projects

The contractor (or main contractor if there are multiple contractors) should prepare suitable arrangements for managing construction health and safety.

While there's no explicit "Construction Phase Plan" requirement, Regulation 8 requires contractors to:

• Plan the work so it can be carried out without risks to health and safety
• Have suitable welfare facilities in place
• Manage and monitor the work

This typically means preparing a written plan covering site arrangements, key risks, and controls.

What the client must do

On all projects where a Construction Phase Plan is required:

The client must not allow construction work to start unless satisfied that:

• The Construction Phase Plan is in place (Regulation 4(5)(a))
• Welfare facilities will be provided from the start of construction (Regulation 4(5)(b))

This means the client should:

• Request and review the plan before construction begins
• Check it addresses the project's key risks
• Confirm it's proportionate and suitable
• Not allow work to commence if the plan is inadequate

What must be in the Construction Phase Plan?

Regulation 12(2) requires the Construction Phase Plan to set out the health and safety arrangements and site rules, taking into account:

• The work involved
• The risks
• Any pre-construction information provided

The HSE guidance (L153) provides additional detail on what should be included.

Core content requirements

1. Project description and programme

• Description of the project and construction work
• Scope of work covered by the plan
• Key programme dates and phases
• Contact details for the project team

2. Management arrangements and responsibilities

• How the construction phase will be managed
• Who is responsible for what (organisational structure)
• Arrangements for coordinating contractors
• Communication and consultation arrangements
• Arrangements for monitoring and review

3. Health and safety aims for the project

• Health and safety objectives and targets
• Standards that will be applied
• Key priorities for the project
• How success will be measured

4. Site rules

• Access and security arrangements
• Site induction requirements
• Permit to work systems
• Restrictions and prohibitions
• Personal protective equipment (PPE) requirements
• Smoking, drugs, and alcohol policy
• Reporting procedures for incidents and near misses

5. Arrangements for controlling significant site risks

• Identification of significant risks
• Method statements and risk assessments required
• Specific control measures for key risks
• Temporary works procedures
• Coordination of high-risk activities
• Management of design changes during construction

6. Health and safety information

• Relevant information from pre-construction information
• Residual risks from design
• Information about existing structures and services
• Ground conditions and contamination
• Asbestos location and management
• Access and egress arrangements

7. Welfare facilities

• Location and provision of welfare facilities
• Sanitary conveniences
• Washing facilities
• Drinking water
• Rest facilities and meals
• Facilities for changing and storing clothing

8. Emergency procedures

• Fire safety arrangements and evacuation procedures
• First aid provision and location of facilities
• Accident and emergency contact details
• Procedures for serious incidents
• Location of emergency equipment

9. Consultation and engagement

• How workers will be consulted
• Arrangements for site meetings
• Communication methods and frequency
• Worker representation

10. Specific requirements for the project

• Particular risks specific to the project type
• Specialist activities and controls
• Environmental constraints
• Overlap with client's ongoing operations
• Traffic management and logistics

Proportionality

The level of detail should be proportionate to:

• The size and duration of the project
• The complexity of the work
• The level of risk involved
• The number of contractors and workers
• The nature of the site and surroundings

Simple, low-risk project: The plan might be 10-20 pages covering the essential arrangements clearly and concisely.

Large, complex, high-risk project: The plan might be 50-100+ pages with detailed method statements, drawings, and appendices.

How the Construction Phase Plan differs from pre-construction information

The Construction Phase Plan and pre-construction information are related but distinct documents with different purposes and authors.

Pre-construction information

What it is: Information about the site, existing structures, and project requirements that designers and contractors need to plan work safely.

Who prepares it: The client (usually with help from the Principal Designer on notifiable projects).

When: Compiled during the pre-construction phase and provided to designers and contractors before they start work.

What it contains:

• Information about the site and existing structures
• Hazards and risks already present
• Previous Health and Safety Files
• Survey information (asbestos, structural, ground conditions)
• Client requirements and constraints
• Information about the client's ongoing operations

Purpose: To inform design decisions and enable contractors to plan construction work safely.

Construction Phase Plan

What it is: The plan for managing health and safety during the construction phase.

Who prepares it: The Principal Contractor (or contractor on non-notifiable projects).

When: Prepared before construction starts and updated throughout construction.

What it contains:

• How construction work will be managed
• Site rules and procedures
• Controls for specific risks
• Welfare and emergency arrangements
• Contractor coordination arrangements
• Method statements and risk assessments

Purpose: To manage health and safety during construction work on site.

The relationship between the two

The Construction Phase Plan should:

• Reference pre-construction information provided by the client
• Address risks identified in the pre-construction information
• Build upon information about existing hazards and constraints
• Explain how residual design risks will be managed during construction

Example flow:

1. Client commissions asbestos survey (pre-construction information gathering)
2. Survey identifies asbestos in existing building (pre-construction information)
3. Client provides survey to Principal Designer and Principal Contractor
4. Principal Designer ensures design minimizes asbestos disturbance (design risk management)
5. Principal Contractor includes asbestos management procedures in Construction Phase Plan (construction phase management)
6. Contractors follow procedures in Construction Phase Plan when working near identified asbestos

Preparing an effective Construction Phase Plan

Creating a Construction Phase Plan that actually helps manage the project requires careful thought and planning.

Start early

Begin developing the Construction Phase Plan as soon as practicable after appointment as Principal Contractor.

Why:

• It takes time to gather information and understand the project
• Design information may still be developing
• Early preparation identifies gaps in information or planning
• Allows time for client review before construction starts

When to start: Ideally, the Principal Contractor should be engaged during design development so they can begin planning construction before designs are finalized.

Gather and review information

Collect all relevant project information:

From the client:

• Pre-construction information package
• Project brief and requirements
• Programme and constraints
• Information about ongoing operations

From the Principal Designer:

• Design risk register or residual risk information
• Design intent documents
• Specifications and drawings
• Information about design assumptions affecting construction

From your own knowledge:

• Site visits and inspections
• Understanding of construction methods
• Experience of similar projects
• Supply chain capabilities and constraints

Identify significant risks

Based on the information gathered, identify the significant risks for the construction phase:

Consider:

• Work at height (roof work, scaffolding, edge protection)
• Structural work (temporary works, demolition, alterations)
• Services (live services, buried services, new installations)
• Hazardous materials (asbestos, lead, contamination)
• Confined spaces
• Lifting operations
• Public interface (occupied buildings, public highways)
• Environmental risks (noise, dust, vibration, pollution)
• Fire risks during construction
• Site-specific hazards

For each significant risk, determine:

• What controls will be applied
• Who is responsible for implementing controls
• What method statements or procedures are needed
• What competence or training is required
• How compliance will be monitored

Define management arrangements

Set out clearly how the project will be managed:

Organizational structure:

• Who is the Principal Contractor's responsible person on site
• Site management team and responsibilities
• Reporting lines and accountability
• Contractor coordination arrangements

Communication:

• Site meetings (frequency, attendees, agenda)
• Toolbox talks and briefings
• Method statement review and approval process
• Incident reporting procedures
• Liaison with Principal Designer and client

Monitoring and review:

• Site inspections and audits
• Performance monitoring (incidents, near misses, observations)
• Compliance checks
• Plan review and update procedures

Make it usable

The Construction Phase Plan should be a practical working document:

Good practice:

• Use clear, plain language (avoid jargon)
• Structure logically with contents page and sections
• Use diagrams, plans, and photos where helpful
• Highlight key site rules prominently
• Make it easy to find specific information
• Include only relevant, useful information
• Keep it concise while covering requirements
• Make relevant sections available to those who need them

Avoid:

• Generic template text that doesn't relate to the project
• Excessive length that obscures key information
• Technical language that workers won't understand
• Repeating entire regulations or guidance documents
• Including irrelevant information "just in case"

Get it reviewed

Before finalizing the plan:

Internal review:

• Site management team review
• Commercial and planning team input
• Health and safety adviser review

External review:

• Provide to client for review and acceptance
• Share relevant sections with specialist contractors for input
• Consider Principal Designer review of design risk management aspects

Act on feedback:

• Address gaps or concerns identified
• Clarify ambiguities
• Add missing information
• Improve clarity and usability

Keep it alive

The Construction Phase Plan is not a static document:

Update when:

• Programme or phasing changes significantly
• Construction methods or sequences change
• New risks are identified
• Contractors are added or changed
• Design changes occur during construction
• Incidents or near misses reveal planning gaps

Review regularly:

• Scheduled reviews (e.g., monthly or at phase boundaries)
• Check plan remains current and relevant
• Confirm arrangements are working in practice
• Incorporate lessons learned

Communicate updates:

• Inform site team of changes
• Brief contractors on revised arrangements
• Update any standalone documents (e.g., emergency procedures)
• Maintain version control

Construction Phase Plans on non-notifiable projects

While CDM 2015 doesn't explicitly require a "Construction Phase Plan" on non-notifiable projects, Regulation 8 requires all contractors to plan, manage, and monitor construction work.

What's required

On non-notifiable projects with multiple contractors, the main contractor should prepare written arrangements covering:

Essential content:

• Who is responsible for coordinating health and safety
• Key site rules and procedures
• Controls for significant risks
• Welfare facilities location and provision
• Emergency procedures (fire, first aid, incidents)
• How contractors will be coordinated
• Communication arrangements

Can be simpler than notifiable project plans:

• Shorter and more concise
• Focus on key risks and controls
• Less formal structure acceptable
• Can be integrated with other project documents
• Proportionate to project size and duration

Single contractor projects

When there's only one contractor (no matter the project size):

• No formal Construction Phase Plan requirement
• The contractor must still plan their work (Regulation 8)
• Risk assessments and method statements typically suffice
• Should still consider welfare, emergencies, and site rules
• Level of documentation should be proportionate

For very small, simple work: A brief written risk assessment covering the work may be adequate.

For larger or higher-risk single-contractor projects: More detailed planning documentation similar to a simple Construction Phase Plan is good practice.

Common Construction Phase Plan mistakes

1. Using a generic template without customization

Copying a template plan from another project without adapting it to the specific project, site, and risks.

Problem: The plan doesn't address actual project risks or arrangements. Generic text doesn't help manage real situations.

Solution: Use templates as a starting point, but thoroughly customize every section to reflect the actual project.

2. Making it too long and unusable

Creating a 300-page document filled with generic policies, copied regulations, and irrelevant information.

Problem: No one reads it. Key information is buried. It becomes a compliance tick-box rather than a working tool.

Solution: Be concise. Focus on what's relevant and useful. Quality over quantity.

3. Preparing it too late

Rushing to complete the plan just before construction starts, without proper thought or information.

Problem: Inadequate planning, missed risks, no time for review, no opportunity to influence design or method.

Solution: Start early. Begin planning during design development. Allow time for proper preparation and review.

4. Not integrating pre-construction information

Ignoring or failing to address hazards and constraints identified in pre-construction information.

Problem: Known risks aren't properly controlled. Contractors unprepared for site conditions. Incidents occur from foreseeable hazards.

Solution: Systematically review pre-construction information and ensure the plan addresses each identified risk.

5. Failing to keep it updated

Creating the plan at the start then never reviewing or updating it despite changes to scope, methods, or risks.

Problem: The plan becomes out of date and irrelevant. Actual arrangements diverge from documented arrangements. Management loses control.

Solution: Regular reviews and updates. Version control. Communication of changes to site team.

6. Not making it accessible

Keeping the plan in the site office with no one aware of its contents or how to access relevant information.

Problem: Workers don't know site rules. Contractors aren't aware of coordination arrangements. The plan has no practical effect.

Solution: Include plan content in site inductions. Share relevant sections with contractors. Display key site rules. Make it available and known.

7. Treating it as a paper exercise

Creating the plan to satisfy regulatory requirements without intending to actually use it to manage the project.

Problem: The gap between plan and practice. Arrangements on paper don't match reality. HSE inspections reveal non-compliance.

Solution: The plan should document actual arrangements, not idealized ones. If the plan says something will happen, ensure it does.

8. Inadequate client review

Clients approving plans they haven't read or don't understand, or Principal Contractors submitting plans they know are inadequate.

Problem: Unsuitable plans approved. Work starts without proper arrangements. Client and Principal Contractor both liable.

Solution: Clients must review plans properly (or appoint someone competent to do so). Principal Contractors must ensure plans are genuinely suitable before submission.

Client review of the Construction Phase Plan

Clients have a legal duty under Regulation 4(5) not to allow construction work to start unless satisfied that a suitable Construction Phase Plan is in place.

What clients should check

When reviewing a Construction Phase Plan, consider:

Is it project-specific?

• Does it clearly relate to this project, site, and work?
• Are site locations, access arrangements, and facilities specific to this project?
• Does it address risks identified in pre-construction information?

Does it cover the key requirements?

• Management structure and responsibilities
• Site rules and procedures
• Controls for significant risks
• Welfare facilities
• Emergency arrangements
• Contractor coordination
• Consultation arrangements

Is it proportionate?

• Appropriate level of detail for project size and risk
• Not excessively long with irrelevant content
• Not inadequately brief for a complex project

Is it usable?

• Clear and understandable
• Logically structured
• Accessible to those who need it

Does it reflect reality?

• Arrangements described are achievable
• Resources allocated match what's needed
• Timescales are realistic

Does it address specific concerns?

• Overlap with ongoing operations (if relevant)
• Public safety and access
• Environmental constraints
• High-risk activities specific to the project

When the plan is inadequate

If the client (or their adviser) identifies that the Construction Phase Plan is inadequate:

Do not allow construction to start.

Communicate concerns specifically:

• What aspects are inadequate
• What needs to be addressed
• By when revised plan is needed

Review revised plan before allowing work to commence.

The client's duty is not just to check a plan exists, but to be satisfied it's suitable. Starting work with an inadequate plan breaches CDM and creates real safety risks.

Frequently asked questions

Resources and further guidance

Official guidance:

• HSE: Managing health and safety in construction (L153)↗ - The official guidance on CDM 2015, including detailed guidance on Construction Phase Plans (pages 45-50)
• HSE: Planning for construction work↗

What to include: Focus on arrangements specific to your project. Address the risks identified in pre-construction information. Make it usable for your site team and contractors. Keep it proportionate to project size and risk. Update it as circumstances change.

Getting help: If you're unsure about what should be in a Construction Phase Plan or how to review one, consider engaging a CDM consultant or health and safety adviser with construction experience. For Principal Contractors, professional bodies like the Construction Industry Training Board (CITB) and Chartered Institute of Building (CIOB) provide guidance and training.

Next steps

Want to understand all the CDM duty holder roles and how they work together?

What is CDM? Construction (Design and Management) Regulations explained →

Need to know if your project requires Principal Contractor appointment?

Do I need to notify my project? CDM notification requirements →

Understanding what the Principal Designer does and how they liaise with the Principal Contractor?

Principal Designer: Role, Duties and Responsibilities →

Related articles:

• What is CDM?
• Do I need to notify?
• Principal Designer duties
• Client duties under CDM
• HSG150: Complete Guide to Construction Safety

Useful tools:

• CDM Checker
• Responsibility Checker