Construction is one of the most dangerous industries in the UK. Falls from height, being struck by vehicles, and structural collapse account for most fatalities. The regulations reflect this - CDM 2015 places specific duties on everyone involved in construction projects.
This guide explains what applies to you, whether you're a client commissioning work, a contractor doing the work, or somewhere in between.
CDM 2015: The basics
The Construction (Design and Management) Regulations 2015 apply to virtually all construction work in Great Britain - from major developments to domestic extensions.
What counts as construction work?
| Included | Not Included |
|---|---|
| Building and civil engineering | General maintenance of fixed plant |
| Alteration, conversion, fitting out | Surveys and inspections (alone) |
| Renovation, repair, upkeep | Cleaning (unless part of construction) |
| Redecoration and external cleaning (scaffolding) | Mineral extraction |
| Demolition | Manufacturing off-site |
| Dismantling structures | |
| Site preparation and clearance | |
| Installation of services (electrics, plumbing, HVAC) |
If it involves physical construction, alteration, or demolition of a structure, CDM almost certainly applies. The definition is deliberately broad.
CDM duty holders
CDM creates specific roles with specific duties:
| Role | Who | Key Duties |
|---|---|---|
| Client | Person commissioning work | Make suitable arrangements, provide pre-construction info, appoint duty holders |
| Principal Designer | Designer in control of pre-construction phase | Plan, manage, coordinate design health and safety |
| Principal Contractor | Contractor in control of construction phase | Plan, manage, coordinate construction health and safety |
| Designer | Anyone who prepares designs | Eliminate hazards, reduce risks, provide information |
| Contractor | Anyone doing construction work | Plan and manage own work safely, cooperate with others |
When appointments are needed
| Project Type | Principal Designer? | Principal Contractor? |
|---|---|---|
| Single contractor, domestic client | No | No |
| Single contractor, commercial client | No | No |
| Multiple contractors, any client | Yes | Yes |
"Multiple contractors" means more than one contractor working on the project at any time - even if not simultaneously. A groundworker followed by a builder followed by an electrician = multiple contractors.
Client duties
If you're commissioning construction work, you're a CDM client - even as a homeowner.
Commercial clients
Commercial clients (businesses, landlords, organisations) have full CDM duties:
Before work starts:
- Make suitable arrangements for managing the project
- Ensure sufficient time and resources are allocated
- Provide pre-construction information to designers and contractors
- Appoint principal designer and principal contractor (if multiple contractors)
- Ensure a construction phase plan is in place before work begins
During construction:
- Ensure welfare facilities are provided
- Ensure principal designer and contractor carry out their duties
- Take reasonable steps to ensure arrangements are maintained
At completion:
- Ensure health and safety file is prepared and handed over
Domestic clients
Homeowners and residential occupiers commissioning work on their own home are "domestic clients" with reduced duties. Your duties automatically transfer to:
- The principal contractor (if appointed), or
- The contractor in control of the work, or
- The principal designer (by written agreement)
Domestic clients don't escape CDM entirely - the duties still exist, they just sit with others. You still shouldn't obstruct safety measures or create hazards.
Principal contractor duties
If you're appointed principal contractor, you're responsible for the construction phase.
Key responsibilities
Planning:
- Prepare the construction phase plan before work starts
- Plan, manage, monitor construction work
- Organise cooperation between contractors
Site management:
- Ensure suitable site inductions
- Prevent unauthorised access
- Ensure welfare facilities provided and maintained
- Arrange consultations and engagement with workers
Coordination:
- Liaise with principal designer on design matters
- Ensure contractors cooperate with each other
- Ensure safe working where activities overlap
Information:
- Provide relevant parts of construction phase plan to contractors
- Ensure contractors provide information for health and safety file
- Pass information to principal designer for the file
Construction phase plan
The construction phase plan is a practical document setting out how health and safety will be managed. It must be in place before construction begins.
Minimum content:
- Description of project
- Management arrangements (who's responsible for what)
- Arrangements for controlling significant risks
- Site rules
- Welfare arrangements
Common sections:
| Section | Content |
|---|---|
| Site set-up | Access, traffic routes, storage, welfare facilities |
| Risk management | Key risks and controls (height, excavations, services) |
| Emergency procedures | First aid, fire, rescue, incident reporting |
| Permits | Confined space, hot work, excavation permits |
| Inductions and training | What workers must complete before starting |
| Monitoring | Inspections, audits, safety tours |
Contractor duties
All contractors - from large firms to sole traders - have CDM duties.
Planning your work
- Plan work to avoid risks where possible
- Don't start work unless reasonable steps have been taken to prevent risk
- Provide relevant information to principal contractor
- Follow the construction phase plan
On site
- Cooperate with principal contractor and other contractors
- Follow site rules
- Report hazards and safety concerns
- Comply with directions from principal contractor
Workers
- Ensure workers are competent (or supervised if developing competence)
- Provide appropriate supervision
- Provide necessary information and instruction
Contractor vs Principal Contractor
Contractor
- •Responsible for own work and workers
- •Follow site rules and construction phase plan
- •Cooperate with others
- •Provide information when requested
- •Report hazards
Principal Contractor
- •Responsible for whole site
- •Create and enforce site rules
- •Coordinate all contractors
- •Produce construction phase plan
- •Manage site access and security
Bottom line: On a multi-contractor project, one contractor takes the PC role. On single-contractor jobs, you're just 'the contractor'.
Working at height
Falls from height are the biggest killer in construction. The Work at Height Regulations 2005 apply to all work where someone could fall and be injured.
Hierarchy of control
You must follow this hierarchy - in order:
- Avoid working at height if possible
- Prevent falls using guardrails, scaffolds, MEWPs
- Mitigate falls using nets, airbags, harnesses (last resort)
Harnesses and fall arrest are last resort - they don't prevent falls, they limit injury. If someone falls on a harness, that's a failure of the hierarchy.
Common situations
| Work | Typical Control |
|---|---|
| Roof work (long duration) | Scaffold with edge protection |
| Roof work (short duration) | Scaffold, MEWP, or roof ladder with safety harness |
| Gutter cleaning | Tower scaffold, MEWP, or ladder (short duration, low risk) |
| Work above 2m inside | Podium steps, tower scaffold |
| Fragile roofs | Crawling boards, nets, harness system |
Ladders
Ladders are only acceptable for:
- Low-risk, short-duration work (typically under 30 minutes)
- Where more suitable equipment isn't reasonably practicable
- Where three points of contact can be maintained while working
Ladder checklist:
- Correct angle (1 in 4 / 75 degrees)
- Secured or footed
- Extends 1m above landing point
- Sound condition, no damage
- On firm, level base
Scaffolding
Scaffolds must be:
- Designed for the loads they'll carry
- Erected by competent persons
- Inspected before first use, after substantial modification, after weather that could affect stability, and at least every 7 days
- Inspections recorded and kept on site
Asbestos in construction
Asbestos is still present in most buildings built before 2000. Anyone doing construction work needs basic asbestos awareness.
Duty to manage
If you're doing work on a building, ask the client/building owner for the asbestos register and management plan. They have a duty to provide this information.
Before disturbing materials
Before breaking into any surface in a pre-2000 building:
- Check the asbestos register
- If not surveyed, assume it may contain asbestos
- Get it tested or get a refurbishment and demolition survey
Materials commonly containing asbestos:
- Insulating board (wall linings, ceiling tiles, fire protection)
- Cement products (roof sheets, gutters, flue pipes)
- Textured coatings (Artex-type finishes)
- Floor tiles and adhesives
- Pipe insulation and lagging
If you find asbestos
- Stop work immediately
- Keep people away from the area
- Don't disturb it further
- Report to the principal contractor / client
- Get professional advice on removal or management
Unlicensed asbestos work (lower risk materials) can be done by trained workers. Licensed work (high-risk materials) requires licensed contractors. Get this wrong and you face prosecution.
Silica dust
Silica dust from cutting, grinding, or drilling concrete, brick, stone, or morite is a serious health hazard causing silicosis and lung cancer.
Control measures
Hierarchy:
- Eliminate - Can you avoid cutting? Use different materials?
- Substitute - Can you use a less dusty method?
- Engineering controls - Water suppression, on-tool extraction, enclosure
- RPE - Respiratory protective equipment (last resort)
Minimum standards:
- Water suppression when cutting with power tools
- On-tool extraction for drilling and grinding
- Suitable RPE as backup (FFP3 disposable or P3 half-mask)
- No dry sweeping - use vacuum with H-class filter
Notification to HSE
Some construction projects must be notified to HSE before work starts.
Notification triggers
Projects must be notified if they will:
- Last more than 30 working days AND have more than 20 workers at any one time, OR
- Exceed 500 person days of construction work
Example:
- 4 workers for 50 days = 200 person days (no notification)
- 10 workers for 60 days = 600 person days (notify HSE)
How to notify
- Use HSE's online F10 notification form
- Submit before construction phase begins
- Display the notification on site
Site welfare
Welfare facilities must be provided on construction sites. This is usually the principal contractor's responsibility but applies to all sites.
Minimum requirements
| Facility | Requirement |
|---|---|
| Toilets | Adequate number, clean, with hand washing |
| Washing | Running water, soap, towels or dryers |
| Drinking water | Readily accessible, clearly marked |
| Rest area | Shelter from weather, seating, facility to heat food |
| Changing/drying | If workers need to change or dry clothing |
| First aid | Equipment and trained person as identified by assessment |
For small, short-duration jobs, using client facilities or nearby public facilities may be acceptable if agreed in advance.
Common compliance gaps
Based on HSE enforcement, these are frequent failures:
Planning failures
- No construction phase plan (or inadequate plan)
- Principal contractor not appointed on multi-contractor projects
- Starting work before arrangements are in place
- Inadequate pre-construction information from client
Site management failures
- Poor housekeeping (trip hazards, materials storage)
- Inadequate traffic management
- Unauthorised site access
- No site inductions
Working at height failures
- No edge protection on scaffolds
- Ladders used inappropriately
- Workers not trained in equipment use
- Incomplete scaffold inspections
Health failures
- No dust controls when cutting
- No asbestos checks before work
- No welfare facilities
- No health surveillance where needed
Frequently asked questions
Frequently Asked Questions
Yes. CDM 2015 applies to all construction work regardless of size. However, smaller single-contractor projects have simpler requirements - no need for principal designer or principal contractor appointments, and the construction phase plan can be simpler. The core duties to plan work safely and provide information still apply.
If you're the only contractor on the job, you don't need a formal construction phase plan document. However, you still need to plan your work safely and you should have method statements or risk assessments for higher-risk activities. If there are other contractors involved at any point, a construction phase plan is required.
The client must appoint the principal contractor in writing before the construction phase begins. For domestic clients (homeowners), this duty transfers to the contractor in control of the work. If you're a contractor and no PC has been formally appointed on a multi-contractor domestic job, you may have inadvertently inherited the PC duties.
Yes, if you have the skills, knowledge, and experience for both roles. This is common on smaller design-and-build projects. You'd need design competence (typically architectural or engineering background) plus construction management competence.
The construction phase plan is an overarching document covering how the whole project will be managed safely - site rules, coordination arrangements, emergency procedures. Risk assessments are detailed assessments of specific activities or hazards. The construction phase plan should reference key risk assessments but doesn't replace them.
Ladders are acceptable for low-risk, short-duration work (typically under 30 minutes) where more suitable equipment isn't reasonably practicable. The work must allow three points of contact to be maintained. For anything more than very light, brief work at height, scaffolding, tower scaffolds, or MEWPs are usually required.
For any building likely to contain asbestos (generally pre-2000 construction), you should check the asbestos register before disturbing any materials. The client or building owner has a legal duty to provide this information. If no survey exists and you'll be breaking into surfaces, assume asbestos may be present until tested.
There's no single mandatory qualification, but you need to be competent for the work you're doing. Most sites require CSCS cards as evidence of competence. Specific training is required for work at height, asbestos awareness (if working in older buildings), plant operation, and other high-risk activities. Many clients require SSSTS or SMSTS for supervisors and managers.
Domestic clients have their duties automatically transferred to contractors, so direct prosecution is rare. However, a homeowner could still be liable under general health and safety law if they create hazards, obstruct safety measures, or direct contractors to work unsafely. More commonly, the contractor would be held responsible.
There's no specific retention period in CDM, but good practice is to keep project records (construction phase plan, risk assessments, inspection records) for at least the duration of any limitation period for claims - typically 6 years, or longer for personal injury claims. The health and safety file should be kept for the life of the building.
Getting professional help
CDM compliance is manageable for most contractors, but professional input is valuable for:
- Complex projects - Multiple phases, multiple contractors, significant risks
- Principal contractor role - If you're new to the PC role or the project is complex
- Client duties - Commercial clients unsure of their obligations
- Health and safety file - Compiling technical information for handover
Unsure about your CDM duties or how to manage a complex project? A construction safety specialist can review your arrangements and ensure you're meeting your obligations.
Related content
Topics:
- Working at Height - Fall prevention guidance
- Asbestos - Asbestos awareness and management
- CDM Regulations - Construction design and management
Articles:
Related sectors:
- Builders - General building work
- Roofers - Roofing-specific guidance
- Electricians - Electrical contractor safety
- Plumbers - Plumbing contractor safety
Tools:
- Responsibility Checker - Find out what applies to you
External resources:
- HSE CDM guidance
- CITB - Training and qualifications
- HSE F10 notification
*This guidance covers key health and safety requirements for UK construction businesses. It is not exhaustive and does not constitute legal advice.