Principal Contractor Duties Under CDM 2015

The Principal Contractor is one of the five key duty holder roles under the CDM Regulations 2015. They plan, manage, monitor and coordinate health and safety during the construction phase of notifiable projects, ensuring all contractors work together safely and that site risks are properly controlled.

Do you need a Principal Contractor on your project?

Answer a few questions to find out.

What is a Principal Contractor?

The Principal Contractor is a contractor appointed by the client on notifiable projects to plan, manage, monitor and coordinate health and safety during the construction phase.

The role was updated in the CDM Regulations 2015 to clarify responsibilities and strengthen the focus on active site management. The Principal Contractor is the focal point for all construction health and safety activities on site.

Key Point

The Principal Contractor isn't just responsible for their own work — they coordinate health and safety across all contractors on site. They set the standards, establish the rules, and ensure everyone works together safely.

Key functions of the Principal Contractor

The Principal Contractor has three primary functions:

Plan, manage, monitor and coordinate health and safety during the construction phase — ensuring all contractors work together safely and risks are properly controlled
Prepare and maintain the Construction Phase Plan — creating a comprehensive strategy for managing site health and safety
Liaise with the Principal Designer and client — ensuring smooth handover of information and coordination throughout the project

The Principal Contractor acts as the site leader for health and safety, working closely with:

The client
The Principal Designer
All contractors and subcontractors
Workers on site
Designers (when design work continues during construction)

When is a Principal Contractor required?

A Principal Contractor must be appointed on notifiable projects only.

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)

Multiple contractor requirement

For Principal Contractor appointment to be required, the project must also involve more than one contractor at any point.

If only a single contractor carries out all the work:

No Principal Contractor appointment is needed
The sole contractor must still plan, manage and monitor their work
A Construction Phase Plan is still required (prepared by the contractor)
The contractor has direct duties under Regulation 13

Note:

"More than one contractor" means at any point during the project, not necessarily working simultaneously. If you have different trades working sequentially (e.g., groundworks contractor followed by builder followed by services contractors), this counts as multiple contractors.

Appointment timing

The client must appoint the Principal Contractor before the construction phase begins.

In practice, this means:

Early enough for the Principal Contractor to prepare the Construction Phase Plan
Before any construction work starts on site
Allowing time to establish site arrangements and conduct handover meetings
Usually at least 2-4 weeks before planned start date (depending on project complexity)

Warning:

Construction work must not start until a Principal Contractor is appointed and a suitable Construction Phase Plan is in place. Starting work without these arrangements is a breach of CDM Regulations.

When the appointment ends

The Principal Contractor's appointment normally continues until the construction phase is complete. This includes:

All construction work on site
Commissioning and testing
Snagging and remedial work
Final inspections and handover

The appointment may continue if:

There are multiple phases with gaps between them
Post-completion remedial work is required
The client wants ongoing site management during defects liability period

Who can be appointed as Principal Contractor?

The Principal Contractor must be:

A contractor — an organisation or individual that carries out, manages, or controls construction work
Competent — having the necessary skills, knowledge, training and experience
Adequately resourced — able to dedicate sufficient time, people and facilities to fulfil the role

Contractor qualification

The CDM Regulations define a contractor as anyone who:

Carries out, manages or controls construction work
This includes main contractors, specialist contractors, construction managers, and managing contractors

Typical Principal Contractor appointments:

Main contractors
Construction management companies
Managing contractors
Specialist contractors (on specialist projects)
Design and build contractors
Framework contractors

The Principal Contractor does NOT need to:

Carry out all the physical work themselves
Be the largest contractor on site
Have design capabilities (though this can be beneficial)

Key Point

The Principal Contractor must be able to demonstrate construction site management experience. Pure consultancy firms, project managers without contracting experience, or designers cannot be appointed as Principal Contractor unless they also carry out contracting work.

Competence requirements

The Principal Contractor must demonstrate competence in:

Construction site management:

Understanding of construction processes, methods and sequencing
Experience managing multiple contractors and trades
Knowledge of construction site logistics and planning
Ability to identify and control construction risks

Construction health and safety:

Understanding of construction hazards and risk control measures
Knowledge of CDM Regulations and other relevant legislation
Experience implementing construction health and safety management systems
Awareness of industry standards and good practice

Communication and coordination:

Ability to organize and coordinate multiple parties
Skills to communicate effectively with workers, contractors, and clients
Capability to consult and engage with workforce
Leadership to enforce site rules and standards

Planning and documentation:

Ability to prepare Construction Phase Plans
Skills to develop method statements and risk assessments
Capability to maintain site documentation
Understanding of construction programme and planning

Proportionate experience:

Experience appropriate to the size and complexity of the project
Track record managing similar types of construction work
Understanding of the specific risks relevant to the project
Demonstrable health and safety performance record

Can an individual or organisation be appointed?

Either an individual or an organisation can be appointed as Principal Contractor.

Organisation appointment (most common):

A contracting company is appointed and assigns staff to fulfil the role
The organisation remains legally responsible even if individuals change
Common on all but the smallest projects
Allows for team resources and continuity

Individual appointment:

A named person (typically self-employed contractor) takes on the role and duties
May be appropriate on very small notifiable projects
Individual must have adequate PI insurance, resources and capacity
Less common due to resource implications

Tip:

When appointing a contracting organisation, ensure they designate a specific individual as site manager or project manager responsible for Principal Contractor duties. This ensures clear accountability and a consistent point of contact.

Principal Contractor duties

The Principal Contractor has specific duties set out in Regulation 12 of CDM 2015.

1. Plan, manage, monitor and coordinate the construction phase

The Principal Contractor must:

Develop a comprehensive construction phase strategy for health and safety management
Plan the sequence of work to minimize risks and ensure safe working
Coordinate all contractors to ensure they work together safely
Hold regular coordination meetings to discuss health and safety
Monitor site activities to ensure compliance with the Construction Phase Plan
Enforce site rules and take action when standards aren't met
Review and approve contractor method statements and risk assessments
Ensure cooperation between contractors working in proximity or on interfacing work

This is an active, hands-on role. The Principal Contractor is responsible for ensuring the site runs safely day-to-day.

Key Point

Effective Principal Contractors don't just sit in the site office. They're visible on site, monitoring activities, challenging unsafe practices, and ensuring contractors understand and follow the Construction Phase Plan.

2. Prepare the Construction Phase Plan

The Construction Phase Plan is the core document for managing construction health and safety.

The Principal Contractor must prepare it before construction work starts and keep it updated throughout.

The plan must set out:

Description of the project and programme
Management arrangements and responsibilities
Health and safety aims for the project
Site rules and standards
Arrangements for controlling significant site-wide risks
Arrangements for coordinating contractors
Site induction and training requirements
Emergency procedures and first aid provision
Welfare facilities location and arrangements
How health and safety information will be communicated
Arrangements for consulting workers
Site security and access control

The plan should address specific risks including:

Work at height arrangements
Temporary works coordination
Services identification and protection
Traffic management and vehicle movements
Lifting operations
Confined spaces
Excavations and groundworks
Hazardous materials (asbestos, lead, etc.)
Noise, dust and environmental controls
Interface with occupied premises

Tip:

The Construction Phase Plan should be proportionate and practical. A 5-page plan that's actually used is more valuable than a 50-page plan that sits in a drawer. Focus on the key risks and how they'll be controlled.

3. Liaise with the Principal Designer

Effective liaison between Principal Contractor and Principal Designer is essential for project safety.

The Principal Contractor must:

Receive and review pre-construction information and design risk information
Understand design intent and critical safety aspects of the design
Raise buildability concerns with the Principal Designer
Request clarification about design details or specifications
Coordinate design changes during construction
Provide feedback on constructability and lessons learned
Share site information needed for the Health and Safety File
Attend handover meetings to ensure smooth transition from design to construction

This liaison continues throughout the project, not just at handover.

Success Story(anonymised)

Early liaison prevents work at height risk

The Situation

A commercial office refurbishment required extensive M&E work in ceiling voids. The Principal Contractor reviewed design information during pre-construction phase and identified significant work at height risks.

What Went Right

✓Principal Contractor raised concerns with Principal Designer before work started
✓Design team re-sequenced work to allow scaffold installation before ceiling work
✓Specification changed to use modular systems reducing time working at height
✓Access strategy agreed allowing safe working platforms throughout
✓Construction Phase Plan developed with designer input on critical sequences
✓Method statements aligned with design intent and available access

Outcome

The early collaboration eliminated over 400 hours of ladder work. Installation time reduced by 20% due to better access planning. Zero accidents or near misses during high-risk ceiling work.

Key Lesson

Principal Contractor liaison with the Principal Designer before work starts allows risks to be designed out or managed more effectively. Don't wait until you're on site to identify problems.

4. Organize cooperation between contractors

Site coordination is a core Principal Contractor duty.

The Principal Contractor must:

Schedule work to minimize clashes and allow safe working
Hold coordination meetings with all contractors
Ensure contractors communicate about interfacing work
Manage shared facilities (access, welfare, storage)
Coordinate temporary works that affect multiple contractors
Ensure permit systems are understood and followed
Manage the interface between different work packages
Resolve conflicts when contractors' activities impact each other

Key Point

Good coordination prevents most site accidents. Ensuring contractors know what others are doing, where they're working, and what risks might affect them is fundamental to the Principal Contractor role.

5. Ensure suitable site inductions

Every person working on site must receive site induction.

The Principal Contractor must:

Provide comprehensive site induction for all workers before they start work
Cover site-specific risks and how they're controlled
Explain site rules and emergency procedures
Show welfare facilities and explain how to access them
Ensure understanding through questions and discussion
Keep records of who has been inducted and when
Provide refresher briefings when circumstances change
Ensure contractors conduct their own task-specific inductions

Site induction should cover:

Site access and parking arrangements
Welfare facilities (toilets, washing, breaks, drinking water)
Site rules and standards of behavior
Emergency procedures (fire, evacuation, first aid)
Key site risks and control measures
Permit systems and authorization requirements
Environmental controls (dust, noise, waste)
Reporting accidents, near misses and hazards
Who to contact for health and safety issues

Warning:

Allowing workers on site without proper induction is a serious breach. The Principal Contractor is responsible for ensuring everyone on site knows the basic safety information they need.

6. Ensure welfare facilities are provided and maintained

Adequate welfare facilities are a fundamental requirement.

The Principal Contractor must ensure:

Sanitary facilities:

Sufficient toilets (1 per 7 workers up to 100 workers)
Washing facilities with hot and cold (or warm) water, soap and towels
Separate facilities for male/female workers where practicable
Facilities kept clean and properly maintained

Rest facilities:

Heated accommodation for taking breaks
Facilities to make hot drinks and heat food
Tables and seating
Protection from weather during meal breaks

Changing facilities:

Secure areas to store workers' own clothing and PPE
Facilities to dry wet clothing
Separate facilities where work is particularly dirty or involves contamination

Drinking water:

Fresh drinking water readily available
Clearly marked and hygienic

The facilities must be:

Available from day one of construction
Maintained throughout the project
Adequate for the number of workers on site
Accessible without unreasonable travel time

Note:

Welfare facilities are often overlooked but are a legal requirement. Poor welfare facilities contribute to low morale, reduced productivity, and can result in enforcement action. Budget for proper facilities from the start.

7. Prevent unauthorized access to the site

The Principal Contractor must ensure only authorized people can access the site.

This includes:

Secure perimeter fencing or hoarding appropriate to the site
Controlled access points with sign-in procedures
Visitor management system and escort arrangements
Clear signage warning of construction site hazards
Monitoring to identify and remove trespassers
Coordination with client for access by occupants or public
Protection of public from construction activities (scaffolds, hoists, deliveries)

Site security prevents:

Injury to members of the public (especially children)
Theft and vandalism
Unauthorized interference with plant or materials
Liability issues if someone is injured

8. Display the F10 notice

On notifiable projects, the Principal Contractor must display the F10 (HSE notification) in a prominent location.

Requirements:

Must be clearly visible to workers entering site
Must be readable (protected from weather)
Must be displayed throughout the construction phase
Should be near the main site entrance

The notice informs workers of:

The notifiable nature of the project
Who the duty holders are
That HSE has been notified and may inspect

9. Provide information and training to workers

The Principal Contractor must ensure:

Workers have necessary information about site risks and control measures
Task-specific training has been completed before high-risk work
Toolbox talks are held on relevant topics
Briefings are given when work changes or new risks arise
Language barriers are addressed with translated materials or interpreters
Competence is checked before allowing specialist work
Records are maintained of training and briefings

Information should be:

Clear and understandable to the workforce
Available in appropriate formats (posters, briefings, written)
Specific to the actual work being done
Updated when circumstances change

10. Consult and engage with workers

The Principal Contractor must consult workers about health and safety matters.

This means:

Providing opportunities for workers to raise concerns
Listening to feedback about site conditions and risks
Involving workers in risk assessment and planning
Responding to concerns raised by workers or their representatives
Facilitating worker representation where workers want it
Encouraging reporting of hazards and near misses
Acting on information provided by the workforce

Workers often have the best insight into practical risks. Engaging with them:

Identifies risks that might otherwise be missed
Improves buy-in to safety measures
Creates a positive safety culture
Reduces accidents and incidents

Key Point

Worker engagement isn't a box-ticking exercise. The best Principal Contractors actively seek worker input, respond to concerns promptly, and demonstrate that safety feedback is valued.

11. Provide information for the Health and Safety File

The Principal Contractor must:

Identify information that should be included in the Health and Safety File
Gather relevant information from contractors and specialists
Provide information to the Principal Designer for inclusion in the file
Collect as-built information showing what was actually constructed
Obtain operating and maintenance information for installed systems
Document residual risks from the construction phase

Information the Principal Contractor should provide includes:

As-built drawings and specifications
Location of buried services and utilities
Details of structural elements and loading
Information about hazardous materials used
Lifting equipment and access requirements
Specific maintenance requirements with safety implications
Details of specialist installations

This information should be provided throughout the project, not all at the end.

Construction Phase Plan responsibilities

The Construction Phase Plan is central to the Principal Contractor's duties. It deserves special attention.

Planning before work starts

The plan must be prepared before construction work begins. This means:

Receiving and reviewing pre-construction information from the client/Principal Designer
Understanding the design and significant risks
Developing the site strategy for health and safety management
Identifying site-wide arrangements needed
Establishing communication and coordination procedures
Consulting with contractors who will work on the early phases

The client must not allow construction to start without a suitable plan in place.

What makes a suitable plan

A suitable Construction Phase Plan:

Is proportionate:

Appropriate to the project size, complexity and risks
Focuses on significant risks, not trivial hazards
Detailed where needed, high-level where that's appropriate

Is specific:

Addresses the actual project, not generic scenarios
Considers the actual site conditions and constraints
Identifies the real risks based on the work being done

Is practical:

Can actually be implemented and followed
Provides clear direction to contractors
Contains information that's genuinely useful

Is accessible:

Available to everyone who needs it
Written in clear language
Structured for easy reference

Is maintained:

Updated when circumstances change
Reflects the current state of the project
Reviewed regularly and revised as needed

Warning:

A generic template plan with minimal customization is not suitable. The HSE expects the Construction Phase Plan to demonstrate active planning for the specific project and its risks.

Communicating the plan

The Principal Contractor must ensure:

All contractors receive relevant sections of the plan
Contractors understand what's required of them
Site rules and standards are clearly explained
Method statements align with the plan's requirements
Workers are briefed on relevant aspects
Updates are communicated when the plan changes

Maintaining and updating the plan

The plan is a living document. It should be reviewed and updated:

When the scope of work changes
When new risks are identified
When contractors' method statements reveal issues
When incidents or near misses indicate problems
When the programme changes significantly
When site conditions differ from what was expected
At regular intervals throughout the project (monthly on longer projects)

Updates should be documented, and affected parties should be informed.

Relationship with other duty holders

The Principal Contractor works closely with all other duty holders throughout the construction phase.

With the client

Reports on health and safety performance and any significant issues
Requests information needed for the Construction Phase Plan
Advises on health and safety implications of client decisions
Coordinates access to occupied premises if applicable
Escalates problems that require client action
Provides updates on programme and progress affecting health and safety

The Principal Contractor keeps the client informed but doesn't transfer client duties to them.

With the Principal Designer

Receives pre-construction information and design risk assessments
Discusses buildability concerns and design risks
Coordinates design changes during construction
Requests clarification on design intent and specifications
Provides site feedback on how design performs in practice
Supplies information for the Health and Safety File
Maintains ongoing communication throughout the project

Effective liaison ensures design intent is understood and construction reflects design assumptions.

With contractors and subcontractors

Coordinates work activities to prevent clashes and manage interactions
Reviews and approves method statements and risk assessments
Enforces site rules and Construction Phase Plan requirements
Provides briefings on site conditions and changes
Monitors compliance with health and safety requirements
Facilitates cooperation between different trades
Addresses concerns raised by contractors about site safety

The Principal Contractor manages contractors as the site health and safety coordinator.

With workers

Provides site induction and ongoing information
Consults on health and safety matters
Responds to concerns and feedback
Enforces standards and addresses unsafe behavior
Ensures welfare provision meets needs
Encourages reporting of hazards and near misses
Maintains visible presence on site

Worker engagement is essential for effective site health and safety management.

Principal Designer vs Principal Contractor

Principal Designer

•Coordinates pre-construction phase
•Manages design team health and safety
•Must be a designer
•Prepares Health and Safety File
•Focuses on design risk elimination
•Works mainly with design team and client

Principal Contractor

•Coordinates construction phase
•Manages site health and safety
•Must be a contractor
•Prepares Construction Phase Plan
•Focuses on construction risk control
•Works mainly with contractors and site workforce

Bottom line: Both roles coordinate their respective project phases. The handover between them is critical — the Principal Contractor needs information from the Principal Designer to plan construction effectively, and ongoing liaison ensures design changes are coordinated.

Principal Contractor vs Contractor

All contractors have duties under CDM 2015. So what's the difference between a contractor and the Principal Contractor?

Contractor duties (Regulation 13)

Every contractor must:

Plan, manage and monitor their own work
Ensure workers have necessary skills, training and knowledge
Not start work unless Construction Phase Plan is in place
Comply with Construction Phase Plan and site rules
Provide information about risks to others
Cooperate with other contractors and duty holders
Report obvious risks they identify

These duties apply to all contractors on all projects, whether notifiable or not.

Principal Contractor duties (Regulation 12)

The Principal Contractor has additional duties to:

Plan, manage and coordinate health and safety across the whole construction phase
Prepare and maintain the Construction Phase Plan
Coordinate all contractors on site
Provide site induction to all workers
Ensure welfare facilities are provided
Prevent unauthorized site access
Consult and engage with workers

These coordination duties only apply on notifiable projects where a Principal Contractor has been appointed.

Key Point

The Principal Contractor doesn't replace individual contractors' duties — they coordinate and oversee site-wide health and safety. All contractors remain responsible for planning and managing their own work safely.

On non-notifiable projects

Small projects that aren't notifiable don't require a Principal Contractor appointment. But someone still needs to:

Prepare a Construction Phase Plan
Coordinate work if multiple contractors are involved
Ensure welfare facilities are provided
Manage site safety

Typically, the main contractor takes on these responsibilities informally.

On single-contractor projects

If only one contractor carries out all the work:

No Principal Contractor appointment is needed (even if notifiable)
The contractor has duties under Regulation 13
The contractor must prepare a Construction Phase Plan
The contractor must ensure their work is planned and managed safely

Competence assessment: Appointing a Principal Contractor

Clients must check that the Principal Contractor they appoint is competent and adequately resourced.

Checking competence

Ask about:

Qualifications and memberships:

Construction management qualifications
Health and safety qualifications (NEBOSH, IOSH, CITB, etc.)
Membership of professional bodies (CIOB, RICS, etc.)
Accreditations (Constructionline, CHAS, SafeContractor)

Experience:

Track record on similar projects in size and type
Examples of previous Principal Contractor appointments
Specific experience with the construction methods to be used
Understanding of the project's particular risks

Health and safety record:

RIDDOR accident record for last 3-5 years
HSE enforcement notices or prosecutions
Health and safety policy and management systems
Approach to incident investigation and learning

Management capability:

Systems for coordinating multiple contractors
Approach to site induction and training
Method for monitoring and enforcing compliance
Procedures for consultation and worker engagement
Resources for preparing Construction Phase Plans

Resources:

Staff with appropriate skills available for the project
Site management team structure and experience
Access to specialist advisors if needed
Equipment and facilities adequate for the project size
Public and employers' liability insurance

Red flags

Be cautious if:

They have no experience as Principal Contractor on similar projects
Their health and safety record includes serious incidents or enforcement
They're unclear about what the Principal Contractor role involves
They can't explain how they'll coordinate multiple contractors
They're being appointed too late to properly prepare
Their fee seems too low to provide adequate site management
They have no documented health and safety management system

Checking resources

Ensure:

Sufficient site management time is allocated (not stretched across too many projects)
Named individuals are assigned (site manager, health and safety advisor)
They have capacity to attend site regularly throughout the project
Adequate budget is included for welfare facilities and safety provisions
Insurance covers Principal Contractor duties adequately

Tip:

For smaller notifiable projects, a local contractor with good health and safety record and experience managing small sites may be more suitable than a large contractor without resource to provide hands-on management.

Common Principal Contractor mistakes

1. Generic Construction Phase Plan

Using a template plan with minimal customization demonstrates lack of planning. The plan must address the specific project, site conditions, and actual risks.

Solution: Develop a bespoke plan based on pre-construction information, design risks, site constraints, and the actual work programme.

2. Inadequate site induction

Rushed inductions that don't cover site-specific risks or check understanding are ineffective and breach regulations.

Solution: Allocate adequate time (typically 30-60 minutes), ensure it's face-to-face, cover all key risks, and confirm understanding before allowing work to start.

3. Poor coordination between contractors

Failing to hold coordination meetings or allowing contractors to work without knowing what others are doing creates significant risks.

Solution: Regular coordination meetings (weekly or more frequently), clear communication channels, and active management of interfaces between work packages.

4. Not enforcing site rules

Failing to challenge unsafe behavior or non-compliance with site rules undermines the entire safety management system.

Solution: Visible site presence, immediate intervention when rules are breached, and clear consequences for repeated non-compliance.

5. Inadequate welfare facilities

Insufficient, poorly maintained, or inaccessible welfare facilities are a common failing and result in enforcement action.

Solution: Provide adequate facilities from day one, maintain them throughout, and increase provision as workforce grows.

6. No worker consultation

Treating consultation as a box-ticking exercise rather than genuinely engaging with workers misses opportunities to identify and control risks.

Solution: Create regular opportunities for feedback, respond to concerns promptly, and demonstrate that worker input is valued and acted upon.

7. Construction Phase Plan not updated

Preparing a plan at the start then never updating it as circumstances change means it becomes irrelevant and unusable.

Solution: Review the plan monthly and whenever significant changes occur. Document updates and communicate them to affected parties.

8. Poor liaison with Principal Designer

Failing to communicate with the Principal Designer during construction means design changes aren't coordinated and buildability issues aren't addressed.

Solution: Establish regular communication (formal meetings and informal contact), raise issues promptly, and involve designers in resolving construction challenges.

9. Allowing work without method statements

Permitting contractors to start high-risk work without approved method statements removes a critical control measure.

Solution: Require method statements before work starts, review them against Construction Phase Plan requirements, and approve or require changes before giving authorization.

10. Not monitoring contractor compliance

Assuming contractors are following their method statements and site rules without checking means problems aren't identified until something goes wrong.

Solution: Active monitoring through site inspections, toolbox talks, review of records, and observation of work activities.

Frequently asked questions

Yes, this is common. The Principal Contractor can carry out construction work themselves while also fulfilling the coordination and management duties. However, they must ensure they have adequate resources to do both — management duties cannot be neglected when they're busy with their own work package.

There's no fixed rate. Some Principal Contractors include CDM coordination in their overall price, others charge separately. Expect additional costs of 1-3% of construction value for the coordination role on typical projects, more for complex or high-risk projects. Very low fees suggest inadequate time will be allocated to coordination duties.

No. CDM 2015 specifically prohibits the same organisation being both Principal Designer and Principal Contractor at the same time. This separation maintains checks and balances between design and construction coordination. However, the Principal Designer role can be transferred to the Principal Contractor in certain circumstances once design is substantially complete.

On notifiable projects with multiple contractors, if the client fails to appoint a Principal Contractor before construction starts, the client automatically becomes the Principal Contractor and takes on all the associated duties. Most clients lack the competence and resources to fulfil this role. The HSE can take enforcement action against clients for breach of these duties.

Before construction work starts. The plan must be in place before any construction activity begins on site. In practice, this means starting preparation as soon as the Principal Contractor is appointed, allowing time to review pre-construction information, understand the design, and develop site strategies.

Anyone working on the project should have access to relevant parts. All contractors need to see sections relevant to their work. Workers should be briefed on relevant aspects. The client should review it to ensure it's suitable. The HSE may request to see it during inspections. It's a working document, not a confidential one.

Separate toilets and changing facilities should be provided where reasonably practicable. On larger sites this is expected. On very small sites where separate facilities aren't practicable, individual lockable toilets and timing arrangements for changing facilities may be acceptable. The key is providing facilities that are suitable and maintain dignity and privacy.

There are no mandatory qualifications. However, look for: construction management experience, health and safety qualifications (NEBOSH Construction Certificate minimum, better if they have NEBOSH Diploma or equivalent), membership of professional bodies (CIOB, RICS), and relevant construction technical qualifications. Most importantly, they need demonstrable experience managing construction sites and coordinating contractors.

The Principal Contractor can delegate tasks (site supervision, plan preparation, etc.) to competent staff, but they remain legally responsible for ensuring duties are fulfilled. The organisation appointed as Principal Contractor is the duty holder, not individuals within it. However, individuals can be prosecuted for failures if they're directors or senior managers with responsibility.

Essential topics: site access and parking, welfare facilities location, emergency procedures (fire, first aid, evacuation), key site risks and controls, permit systems, site rules and standards, environmental controls, reporting procedures for accidents and hazards, and who to contact for health and safety issues. Tailor the content to site-specific risks. Typically takes 30-60 minutes.

Whenever circumstances change significantly: change in scope, new risks identified, change in site conditions, incident reveals a problem, or significant programme changes. On longer projects, review monthly even if no changes. The plan should always reflect the current state of the project, not just the initial intentions.

HSE inspectors can visit sites, request documents (including Construction Phase Plan), interview personnel, and assess compliance. They can issue improvement notices requiring specific actions within a timeframe, prohibition notices stopping work immediately if there's serious risk, or prosecute for breaches. Penalties include unlimited fines, and directors can be personally prosecuted. Serious breaches can result in imprisonment.

Resources and further guidance

Official guidance:

HSE: Managing health and safety in construction (L153) — The official guidance on CDM 2015
HSE: Principal Contractor responsibilities

Assessing competence:

Request examples of previous Construction Phase Plans
Check health and safety performance record
Ask about their approach to site coordination
Verify adequate public and employers' liability insurance

Professional bodies:

CIOB (Chartered Institute of Building)
RICS (Royal Institution of Chartered Surveyors)
IOSH (Institution of Occupational Safety and Health)
NEBOSH (National Examination Board in Occupational Safety and Health)

Next steps

Want to understand all the CDM duty holder roles?

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

Need to know if your project requires CDM appointments?

Do I need CDM? Project size and duty requirements →

Understanding what the Principal Designer does?

Principal Designer: Role, Duties and Responsibilities →

Not sure how to appoint a Principal Contractor or whether your Construction Phase Plan is adequate? A CDM specialist can review your arrangements, assess competence, and advise on your specific project requirements.

Speak to a professional

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