Health and safety file: what it is and when it is required

Its purpose is practical: to make sure people carrying out later work such as maintenance, cleaning, refurbishment, alteration or demolition can understand significant risks and the features of the structure that may affect how that work should be planned.

What is the health and safety file under CDM 2015?

HSE describes the health and safety file as a file appropriate to the characteristics of the project containing relevant health and safety information to be taken into account during any subsequent project. HSE L153 guidance: Managing health and safety in construction, Appendix 4, the health and safety file, PDF (opens in a new tab)

The file should therefore focus on information that someone may genuinely need when planning or carrying out future construction work on the structure.

When is a health and safety file required?

Under CDM 2015, the health and safety file is required for projects involving more than one contractor. Read Regulation 12 on legislation.gov.uk: construction phase plan and health and safety file (opens in a new tab)

This is different from the construction phase plan, which is required for every construction project. A single-contractor project needs a construction phase plan, but it does not require a CDM health and safety file solely under this requirement. Read Regulation 12 on legislation.gov.uk: construction phase plan and health and safety file (opens in a new tab)

Who is responsible for preparing the health and safety file?

On a project involving more than one contractor, the Principal Designer is responsible for preparing the health and safety file during the pre-construction phase. Read Regulation 12 on legislation.gov.uk: construction phase plan and health and safety file (opens in a new tab)

The Principal Designer must ensure the file is appropriately reviewed, updated and revised from time to time to reflect the project and the work carried out. Read Regulation 12 on legislation.gov.uk: construction phase plan and health and safety file (opens in a new tab)

What happens if the Principal Designer’s appointment ends before the project finishes?

If the Principal Designer’s appointment finishes before the end of the project, the Principal Designer must pass the health and safety file to the Principal Contractor. Read Regulation 12 on legislation.gov.uk: construction phase plan and health and safety file (opens in a new tab)

The Principal Contractor must then ensure that the file is reviewed, updated and revised as necessary for the remainder of the project before passing it to the client at completion. Read Regulation 12 on legislation.gov.uk: construction phase plan and health and safety file (opens in a new tab)

What is the client’s responsibility for the file?

The client must ensure the Principal Designer prepares the health and safety file and must take possession of it when the project is complete. Read Regulation 4 on legislation.gov.uk: client duties for managing projects, including the health and safety file (opens in a new tab)

The client must keep the file available for inspection by any person who may need it to comply with relevant legal requirements. If the client disposes of their interest in the structure, the file should pass to the person who acquires that interest. Read Regulation 4 on legislation.gov.uk: client duties for managing projects, including the health and safety file (opens in a new tab)

What should a CDM health and safety file contain?

The content should be project-specific and proportionate to the risks. HSE guidance says information such as the following should be considered for inclusion: HSE L153 guidance: Managing health and safety in construction, Appendix 4, the health and safety file, PDF (opens in a new tab)

• A brief description of the work carried out.
• Information about hazards that were not eliminated through design or construction and how they were addressed.
• Relevant surveys or information concerning hazards such as asbestos or contaminated land.
• Key structural principles, including bracing and significant stored-energy features.
• Safe working loads for floors and roofs where relevant.
• Information about hazardous materials used, such as lead paints or special coatings.
• Information about the safe removal or dismantling of installed plant and equipment.
• Health and safety information about equipment provided for cleaning or maintaining the structure.
• The nature, location and markings of significant services, including underground cables, gas supplies and fire-fighting services.
• Relevant information and as-built drawings showing the building, plant and equipment, including safe access to service areas where relevant.

What should not go in the health and safety file?

The file should not become a dumping ground for project paperwork. HSE guidance specifically says it should not include information that will be of no help when planning future construction work. HSE L153 guidance: Managing health and safety in construction, Appendix 4, the health and safety file, PDF (opens in a new tab)

• Pre-construction information simply because it existed earlier in the project.
• The construction phase plan.
• Contractual documents.
• Generic safety method statements.
• Routine records that are not relevant to future construction work.
• Information that duplicates material already available elsewhere without adding useful context.

The test is whether the information is likely to help someone understand and manage health and safety during later construction work.

How detailed should the file be?

There should be enough detail for future users to identify and address likely risks, but the level of detail should be proportionate to the risks involved. HSE L153 guidance: Managing health and safety in construction, Appendix 4, the health and safety file, PDF (opens in a new tab)

Clear, concise and useful information is more valuable than a large file containing material that future designers or contractors are unlikely to use.

When should the file be started?

The file should be considered from the pre-construction phase rather than left until handover. Starting early allows relevant design information, residual risks and project decisions to be captured as they arise. Read Regulation 12 on legislation.gov.uk: construction phase plan and health and safety file (opens in a new tab)

Who contributes information to the file?

Although the Principal Designer has responsibility for preparing the file, other duty holders may need to provide relevant information.

• Designers should provide information about significant residual risks and design features likely to affect future work.
• The Principal Contractor and contractors may provide as-built information, details of installed systems, access arrangements and other relevant construction information.
• The client may provide existing information about the site or structure where this remains relevant to future work.

When is the file handed over to the client?

At the end of the project, the completed health and safety file should be passed to the client. Read Regulation 12 on legislation.gov.uk: construction phase plan and health and safety file (opens in a new tab)

The client then becomes responsible for retaining it and making it available to those who need the information for future construction work. Read Regulation 4 on legislation.gov.uk: client duties for managing projects, including the health and safety file (opens in a new tab)

Does the health and safety file need to be updated after completion?

Yes, where later construction work changes the structure or creates new relevant information. The file should remain a useful record of health and safety information for future projects rather than becoming an outdated snapshot. HSE commercial client guidance: commercial clients, roles and responsibilities under CDM 2015 (opens in a new tab)

Is the health and safety file the same as pre-construction information?

No. Pre-construction information is information supplied to designers and contractors to help them plan and manage the current project before and during its early stages.

The health and safety file is retained for future construction work. Relevant information from an existing health and safety file can, however, form part of the pre-construction information for a later project. HSE L153 guidance: Managing health and safety in construction, Appendix 4, the health and safety file, PDF (opens in a new tab)

Is the health and safety file the same as the construction phase plan?

No. The construction phase plan explains how health and safety will be managed during the construction phase of the current project.

The health and safety file contains relevant information likely to be needed when future construction work is carried out. HSE guidance specifically says the construction phase plan should not simply be included in the file. HSE L153 guidance: Managing health and safety in construction, Appendix 4, the health and safety file, PDF (opens in a new tab)

Health and safety file checklist

Before the file is handed over, check that:

• The project involved more than one contractor and therefore requires a health and safety file.
• The file reflects the actual completed project and structure.
• Significant residual hazards are clearly recorded.
• Relevant structural principles and loading information are included where needed.
• Important information about hazardous materials is included.
• Relevant details for safe maintenance, cleaning, removal or dismantling are included.
• Significant services and their locations are recorded.
• Relevant as-built drawings and access information are included.
• Unnecessary project paperwork has been excluded.
• The information is clear, concise and understandable.
• The file has been reviewed and updated before handover.
• The client knows where the file will be retained and how it will be made available for future work.

Common health and safety file mistakes

Treating the file as a project archive

The file should contain information useful for future construction work, not every document produced on the project.

Leaving preparation until handover

Relevant information should be identified and captured as the project develops.

Including generic method statements and plans

HSE specifically warns against including material that will not help future construction work.

Failing to update the file when the project changes

The file should reflect the completed structure and relevant final information.

Assuming the file is required on every project

Under CDM 2015, the health and safety file is required for projects involving more than one contractor.

Failing to pass the file on when ownership changes

The file should follow the structure so future duty holders can access the information they need.