CDM compliance checklist: what should you check on a project?

What does CDM compliance mean?

CDM compliance means meeting the duties that apply to the project under CDM 2015. Which checks matter will depend on the type of project, the number of contractors, the people appointed and the stage the project has reached. HSE L153 guidance: Managing health and safety in construction: practical interpretation of the CDM 2015 duties, PDF (opens in a new tab)

For most projects, the review should look beyond whether documents exist and consider whether responsibilities are clear, information is being exchanged, risks are being managed and the relevant duty holders are actually carrying out their functions.

1. Confirm whether CDM 2015 applies

Start by confirming the project is within the scope of CDM 2015 and identifying the basic project structure.

• Is the work ‘construction work’ within the meaning of CDM 2015?
• Is the client a commercial client or a domestic client?
• Will the project involve one contractor or more than one contractor?
• Is it reasonably foreseeable that more than one contractor will be involved?
• Is the project notifiable to HSE under the F10 thresholds?

2. Check the client’s management arrangements

The client must make suitable arrangements for managing the project, including allocating sufficient time and other resources. Those arrangements should be maintained and reviewed throughout the project. Read Regulation 4 on legislation.gov.uk: client duties in relation to managing projects: management arrangements, pre-construction information, and construction phase plan and health and safety file oversight (opens in a new tab)

• Are the client’s CDM responsibilities understood by the people making project decisions?
• Has enough time been allowed for planning, design, mobilisation and construction?
• Are sufficient resources available for the health and safety arrangements?
• Are responsibilities, reporting lines and escalation routes clear?
• Are the arrangements being reviewed as the project develops?

3. Check duty-holder appointments

Where a project involves more than one contractor, the client must appoint a Principal Designer and Principal Contractor in writing as soon as practicable and before the construction phase begins. Read Regulation 5 on legislation.gov.uk: appointment of the principal designer and the principal contractor, and the client fallback (opens in a new tab)

• Has a Principal Designer been appointed where required?
• Has a Principal Contractor been appointed where required?
• Are the appointments in writing?
• Were the appointments made early enough to influence the project?
• Do the appointment scopes match the role each party is actually expected to perform?
• Have domestic-client arrangements been dealt with correctly where relevant?

4. Check capability before appointment

Appointments should not be based on title or price alone. Those making appointments should take reasonable steps to establish that designers and contractors have the capability needed for the work and role. Read Regulation 8 on legislation.gov.uk: general duties: capability, the duty on appointing parties, and cooperation between duty holders (opens in a new tab)

• Has relevant skills, knowledge and experience been considered?
• Has training been considered where it is relevant to the work being undertaken?
• Has organisational capability been considered where an organisation is appointed?
• Is there evidence of relevant project or role experience?
• Are the proposed resources proportionate to the project’s scale, complexity and risk?
• Has the basis for the appointment been recorded?

5. Check pre-construction information

The client must provide pre-construction information as soon as practicable to designers and contractors appointed, or being considered for appointment, to the project. Read Regulation 4 on legislation.gov.uk: client duties in relation to managing projects: management arrangements, pre-construction information, and construction phase plan and health and safety file oversight (opens in a new tab)

• Has relevant information about the project, site and existing structures been identified?
• Has information about known hazards and constraints been provided?
• Has the information been issued early enough to influence design and planning?
• Is missing information clearly identified and being obtained?
• Is new information being shared as it becomes available?

6. Check design risk management and coordination

Designers must eliminate foreseeable risks where reasonably practicable and take steps to reduce or control risks that cannot be eliminated. On multi-contractor projects, the Principal Designer coordinates health and safety during the pre-construction phase. Read Regulation 9 on legislation.gov.uk: duties of designers, including eliminating, reducing and controlling foreseeable risks (opens in a new tab)

• Are designers considering health and safety as part of design decisions?
• Are significant design risks being discussed and coordinated?
• Are design interfaces between disciplines being managed?
• Are relevant residual risks being communicated rather than simply transferred to construction?
• Are design changes reviewed for health and safety implications?
• Is the Principal Designer actively coordinating the pre-construction phase where appointed?

Read Regulation 11 on legislation.gov.uk: duties of a principal designer during the pre-construction phase (opens in a new tab)

7. Check the construction phase plan

A construction phase plan is required for every project. Before the construction phase begins, the client must ensure that one has been drawn up by the contractor on a single-contractor project or by the Principal Contractor on a multi-contractor project. Read Regulation 12 on legislation.gov.uk: construction phase plan and health and safety file (opens in a new tab)

• Is there a construction phase plan before construction starts?
• Does it reflect the actual project rather than generic company procedures?
• Does it address the arrangements needed to manage the work safely?
• Has relevant pre-construction information informed the plan?
• Is the plan being reviewed and updated as the project changes?

8. Check Principal Contractor construction-phase arrangements

On a project with more than one contractor, the Principal Contractor must plan, manage, monitor and coordinate health and safety during the construction phase. Read Regulation 13 on legislation.gov.uk: duties of a principal contractor during the construction phase (opens in a new tab)

• Are contractors being coordinated rather than working in isolation?
• Are suitable site rules and management arrangements in place?
• Are workers receiving suitable site inductions?
• Are welfare facilities provided as required?
• Is access to the site controlled so far as reasonably practicable?
• Are contractors being consulted and information shared where work interfaces create risk?
• Are site arrangements being monitored and adjusted where necessary?

Read Regulation 14 on legislation.gov.uk: principal contractor's duties to consult and engage with workers (opens in a new tab)

9. Check contractor arrangements

Each contractor retains its own CDM duties. Principal Contractor coordination does not remove the responsibilities of individual contractors. Read Regulation 15 on legislation.gov.uk: duties of contractors (opens in a new tab)

• Do contractors plan, manage and monitor the construction work under their control?
• Are workers given appropriate supervision, instructions and information?
• Are contractors cooperating with the Principal Contractor and other duty holders?
• Are foreseeable risks controlled through suitable working methods and arrangements?
• Are concerns and changes communicated promptly?

10. Check cooperation and information flow

CDM relies on cooperation and coordination between clients, designers and contractors. Information should move to the people who need it at the point when it can affect decisions. Read Regulation 8 on legislation.gov.uk: general duties: capability, the duty on appointing parties, and cooperation between duty holders (opens in a new tab)

• Is the Principal Designer liaising with the Principal Contractor where both roles are appointed?
• Is relevant design information reaching the construction team?
• Are construction constraints and changes fed back to designers where they affect design?
• Are significant health and safety decisions recorded and communicated?
• Are information gaps, actions and owners tracked to closure?

11. Check the health and safety file

Where a project involves more than one contractor, the Principal Designer must prepare a health and safety file appropriate to the project. The file should contain information likely to be needed to protect health and safety during future construction work. Read Regulation 12 on legislation.gov.uk: construction phase plan and health and safety file (opens in a new tab)

• Has the health and safety file been started early enough to be developed during the project?
• Is information being collected as the design and construction work progresses?
• Is the file focused on useful information for future work rather than becoming a document dump?
• Is it being reviewed, updated and revised as appropriate?
• Are arrangements clear for passing the file to the client at the end of the project?

12. Check F10 notification where required

A project being notifiable does not determine whether CDM applies, but where the notification thresholds are met the client must notify HSE in accordance with Regulation 6. Read Regulation 6 on legislation.gov.uk: notification of a project to the Executive (opens in a new tab)

• Has the project been checked against the notification thresholds?
• If notifiable, has the F10 notification been submitted?
• Is the notification displayed in the construction site office where required?
• Are material changes to the notified particulars being dealt with appropriately?

13. Check that arrangements are working in practice

A compliance review should test implementation, not just the existence of documents.

• Do site and design practices match the documented arrangements?
• Are recurring issues being identified and corrected?
• Are inspection or assurance findings tracked to closure?
• Are changes to design, programme, contractors or risk reflected in the arrangements?
• Are duty holders escalating issues where they cannot resolve them within their own control?

14. Check project handover and close-out

CDM duties continue through completion and handover. Closing the project should include confirming that information needed for future safe work has been transferred and that outstanding health and safety actions are appropriately resolved. Read Regulation 12 on legislation.gov.uk: construction phase plan and health and safety file (opens in a new tab)

• Has the health and safety file been completed and passed to the client where required?
• Have outstanding design or construction health and safety actions been closed or clearly handed over?
• Has relevant information been transferred to those responsible for the completed asset?
• Are records sufficient to explain important decisions or residual risks?

CDM compliance checklist by project stage

What evidence should a CDM audit look for?

There is no single prescribed ‘CDM compliance file’. Evidence should be proportionate to the project and should demonstrate how duties are actually being discharged. HSE L153 guidance: Managing health and safety in construction: practical interpretation of the CDM 2015 duties, PDF (opens in a new tab)

• Written duty-holder appointments.
• Capability assessment records.
• Pre-construction information.
• Design-risk and coordination records.
• Construction phase plan.
• Site-management and monitoring records.
• Records of cooperation and information exchange.
• Health and safety file where required.
• F10 information where the project is notifiable.
• Action, assurance and close-out records.

Common CDM compliance mistakes

Treating CDM as a paperwork exercise

Documents matter, but they need to reflect and support what is actually happening on the project.

Appointing Principal Duty Holders too late

Late appointments reduce their ability to influence planning, design and mobilisation.

Using generic pre-construction information

PCI should be relevant to the project and useful to those making design and construction decisions.

Leaving the construction phase plan untouched

The plan should remain suitable as the work, risks and arrangements change.

Assuming the Principal Contractor owns all site safety

Individual contractors retain duties for the work under their control.

Treating the health and safety file as an end-of-project task

Useful information is easier to capture and coordinate throughout the project.

Closing actions because a document exists

The real test is whether the intended improvement has been implemented and is working in practice.

How often should CDM compliance be reviewed?

There is no single review frequency that suits every project. The intensity of assurance should be proportionate to the project’s risks, complexity, duration and rate of change. HSE L153 guidance: Managing health and safety in construction: practical interpretation of the CDM 2015 duties, PDF (opens in a new tab)

Reviews are particularly useful at key project transitions, after significant design or programme changes, when new contractors are introduced, after incidents or recurring concerns, and before handover. The client must maintain and review the management arrangements throughout the project. Read Regulation 4 on legislation.gov.uk: client duties in relation to managing projects: management arrangements, pre-construction information, and construction phase plan and health and safety file oversight (opens in a new tab)