Topic: CDM
Construction phase plan: what it is and when it is required
A construction phase plan is a written plan setting out how health and safety will be managed during the construction phase of a project. Under the Construction (Design and Management) Regulations 2015 (CDM 2015), a construction phase plan is required for every construction project before the construction phase begins.
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The plan should be proportionate to the project. A small, straightforward job may only need a simple plan, while a larger or higher-risk project will need more detail. The purpose is not to create paperwork for its own sake, but to record the arrangements needed to plan, manage and monitor the work safely.
What is a construction phase plan?
The construction phase plan records the health and safety arrangements for the construction phase, the site rules and, where relevant, specific measures for work involving the particular risks listed in Schedule 3 of CDM 2015. Read Regulation 12 on legislation.gov.uk: construction phase plan and health and safety file (opens in a new tab)
HSE guidance describes the plan as the basis for communicating the arrangements for managing significant health and safety risks during the construction phase. It should therefore be easy to understand, relevant to the project and proportionate to the scale, complexity and risks involved. HSE L153 guidance: Managing health and safety in construction, Appendix 3, the construction phase plan, PDF (opens in a new tab)
When is a construction phase plan required?
A construction phase plan must be prepared before the construction phase begins. In practical terms, it must be in place before construction work starts. HSE guidance: planning for construction work (opens in a new tab)
The requirement applies to projects of all sizes. It is not limited to large projects, projects involving several contractors or projects that meet the F10 notification thresholds. HSE CIS80 guidance: Construction Phase Plan (CDM 2015), PDF (opens in a new tab)
Who is responsible for preparing the construction phase plan?
Responsibility depends on the number of contractors involved in the project.
Where a project involves more than one contractor, the Principal Contractor is responsible for drawing up the construction phase plan or arranging for it to be drawn up. HSE guidance: planning for construction work (opens in a new tab)
Where there is only one contractor, that contractor is responsible for ensuring the construction phase plan is drawn up.
The client must ensure that a suitable construction phase plan is in place before the construction phase begins. HSE L153 guidance: Managing health and safety in construction, Appendix 3, the construction phase plan, PDF (opens in a new tab)
On projects involving more than one contractor, the Principal Designer must assist the Principal Contractor by providing relevant information they hold, including pre-construction information and information from designers about risks that have not been eliminated through design. Read Regulation 12 on legislation.gov.uk: construction phase plan and health and safety file (opens in a new tab)
What should a construction phase plan contain?
The plan should contain enough information to show how the construction phase will be managed safely without becoming a collection of generic paperwork. HSE L153 guidance: Managing health and safety in construction, Appendix 3, the construction phase plan, PDF (opens in a new tab)
- A brief description of the project and key dates.
- The key members of the project team and relevant responsibilities.
- The health and safety arrangements for managing the construction phase.
- The site rules.
- Arrangements for cooperation and coordination between contractors and others involved.
- Arrangements for communicating relevant information and changes.
- Site induction arrangements.
- Arrangements for consulting and engaging workers.
- Welfare facilities.
- Fire and emergency arrangements.
- Site security and prevention of unauthorised access.
- Arrangements for supervision.
- The principal risks associated with the work and how they will be managed.
- Specific measures for Schedule 3 work where relevant.
What are Schedule 3 risks?
Schedule 3 identifies categories of work involving particular risks. Where any of these are relevant to the project, the construction phase plan must include the specific measures needed to manage them. Read Schedule 3 on legislation.gov.uk: work involving particular risks (opens in a new tab)
Examples include work exposing workers to risks such as burial under earthfalls, engulfment in swampland, falling from height where the risk is particularly aggravated, work near high-voltage power lines, work involving explosives, work involving the assembly or dismantling of heavy prefabricated components, and certain work involving diving, caissons or compressed air.
Does a small project still need a construction phase plan?
Yes. Small projects still require a construction phase plan. However, CDM expects the plan to be proportionate.
For straightforward small-scale work, a short plan covering the key dates, relevant site information, main risks, welfare, supervision, communication and site rules may be sufficient. HSE specifically provides a simple construction phase plan format for small builders. HSE CIS80 guidance: Construction Phase Plan (CDM 2015), PDF (opens in a new tab)
Does a single-contractor project need a construction phase plan?
Yes. Where there is only one contractor, that contractor must ensure a construction phase plan is prepared before setting up the site. HSE L153 guidance: Managing health and safety in construction, Appendix 3, the construction phase plan, PDF (opens in a new tab)
This is an important distinction because a single-contractor project does not require a Principal Contractor appointment, but it still requires construction-phase planning.
Is a construction phase plan the same as an F10 notification?
No. The two requirements are separate.
A construction phase plan is required for every construction project. F10 notification only applies when the project meets the separate notification thresholds. A project can therefore require a construction phase plan without being notifiable to HSE. HSE CIS80 guidance: Construction Phase Plan (CDM 2015), PDF (opens in a new tab)
Is a construction phase plan the same as a risk assessment or method statement?
No. Risk assessments and method statements may support the management of particular risks and activities, but they are not a substitute for the construction phase plan.
HSE guidance specifically warns against filling the plan with generic risk assessments, records of how decisions were reached or detailed method statements if those documents make the plan harder to understand. The construction phase plan should clearly explain the arrangements for managing the construction phase. HSE L153 guidance: Managing health and safety in construction, Appendix 3, the construction phase plan, PDF (opens in a new tab)
When should the plan be reviewed and updated?
The plan is not a document that should be written once and then filed away. It must be reviewed, updated and revised as the project progresses so that it continues to reflect the work and remains sufficient to manage health and safety risks. Read Regulation 12 on legislation.gov.uk: construction phase plan and health and safety file (opens in a new tab)
Changes in design, sequencing, contractors, site conditions, methods of work or significant risks may all require the plan to be updated.
What is the client’s role?
The client does not normally write the construction phase plan, but the client must ensure that one is drawn up before the construction phase begins.
The client should also ensure the Principal Contractor, or the contractor on a single-contractor project, has the relevant information needed to prepare it. HSE guidance also expects the client to ensure the plan adequately addresses the arrangements for managing risks and is kept under review. HSE L153 guidance: Managing health and safety in construction, Appendix 3, the construction phase plan, PDF (opens in a new tab)
What is the Principal Designer’s role?
On projects involving more than one contractor, the Principal Designer assists the Principal Contractor by providing relevant pre-construction and design information. Read Regulation 12 on legislation.gov.uk: construction phase plan and health and safety file (opens in a new tab)
This helps ensure that risks identified during design and pre-construction planning are carried through into construction-phase arrangements rather than being lost at handover.
What is the Principal Contractor’s role?
The Principal Contractor takes the lead in preparing, implementing, reviewing and revising the plan on projects involving more than one contractor. HSE L153 guidance: Managing health and safety in construction, Appendix 3, the construction phase plan, PDF (opens in a new tab)
The plan should support the Principal Contractor’s wider duty to plan, manage, monitor and coordinate health and safety throughout the construction phase.
Construction phase plan checklist
Before construction work starts, check that:
- A construction phase plan has been prepared.
- The correct person is responsible for the plan: the Principal Contractor on a multi-contractor project or the contractor on a single-contractor project.
- The plan reflects the actual project rather than generic wording.
- Relevant pre-construction and design information has been considered.
- Health and safety management arrangements are clear.
- Site rules are recorded.
- Key project risks and controls are addressed.
- Schedule 3 measures are included where relevant.
- Welfare, induction, supervision and emergency arrangements are covered.
- Cooperation and communication arrangements are clear.
- The plan can be understood by those who need to use it.
- There is a process for reviewing and updating it as the project changes.
Common construction phase plan mistakes
Assuming only notifiable projects need a plan
A construction phase plan is required for every construction project.
Using a generic template without making it project-specific
The plan should reflect the actual work, risks, people and arrangements for the project.
Treating the plan as a pre-start formality
It must be reviewed and updated as the construction phase changes.
Filling it with unrelated paperwork
The plan should stay clear and proportionate instead of becoming a storage folder for generic documents.
Forgetting single-contractor projects
A single contractor must still ensure a construction phase plan is prepared.
Failing to carry design information into the plan
Relevant pre-construction information and significant design risks should inform construction-phase planning.
Frequently asked questions
Is a construction phase plan required for every project?
Yes. HSE states that a construction phase plan is required for every construction project under CDM 2015.
When must the construction phase plan be completed?
It must be prepared before the construction phase begins and before construction work starts.
Who writes the construction phase plan?
The Principal Contractor is responsible on projects involving more than one contractor. On a single-contractor project, the contractor is responsible.
Does a domestic project need a construction phase plan?
Yes, where the work is a construction project under CDM. The way the duties transfer on domestic projects affects who carries out the relevant responsibilities.
Can a construction phase plan be short?
Yes. The plan should be proportionate to the scale, complexity and risks of the project. A straightforward project may only require a simple plan.
Does a construction phase plan replace risk assessments and method statements?
No. Those documents may support the management of specific activities, but the construction phase plan records the overall arrangements for managing the construction phase.
Does the plan need to be updated?
Yes. It should be reviewed, updated and revised as necessary throughout the project so it remains fit for purpose.
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