Employer duties

What is a construction phase plan under CDM 2015?

Under CDM 2015 the construction phase plan must set out three things: the health and safety arrangements for the construction phase, the site rules, and — where applicable — specific measures for the high-risk work in Schedule 3. Headings beyond those (project description, objectives, cooperation arrangements, site induction) sit at guidance level in HSE's L153. The measurement keeps that distinction: of 15 items, 6 are binding and the rest are guidance or conditional.

What the regulation asks for

  1. The health and safety arrangements for the construction phase.
  2. The site rules. Contractors' duty to comply with the parts relevant to their work is set out separately.
  3. Where the work falls under Schedule 3, the specific measures for it.

Guidance versus regulation

HSE's L153 guidance lists headings it recommends putting in the plan: the project description and key dates, health and safety objectives, arrangements for cooperation and coordination between the project team, worker engagement, and site induction. These are guidance — but some become binding elsewhere: worker engagement and induction are direct duties of the principal contractor.

Other binding headings

  • Welfare facilities: Schedule 2 lists the minimum facilities.
  • Fire and emergency: emergency procedures, emergency routes and exits, and fire detection and firefighting are each regulated.
  • Review of the plan: the principal contractor reviews, updates and revises it throughout the project.

Why we write the distinction down

"It is in the guidance" and "it is in the regulation" are not the same. Substituting one for the other harms in both directions: treating guidance as law creates unnecessary work; treating law as guidance leaves work undone.

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