How does the site plan duty differ from country to country?

Question

Accepted Answer

We measured four regimes side by side. Türkiye and the EU share the same threshold (30 working days plus 20 workers, or 500 person-days) and both have a plan, a separate file and a coordinator. The UK uses the same threshold but appoints a principal designer and principal contractor instead of a coordinator, and the burden returns to the client if nobody is appointed. The US has no general plan, no prior notice and no coordinator; the duty comes from work-specific conditional plans. One of the few shared items is the high-risk work list. Side by side Türkiye European Union United Kingdom United States General plan mandatory Yes Yes Yes No Notification threshold 30 working days + 20 workers · or 500 person-days 30 working days + 20 workers · or 500 person-days 30 working days + 20 workers · or 500 person-days None Coordination Health and safety coordinator Preparation and construction coordinators Principal designer + principal contractor Prime contractor joint responsibility Separate file Health and safety file File Health and safety file None High-risk work list Annex 2 (11 items) Annex II Schedule 3 (same 10 items as Annex II) Work-specific conditional plans Measured item counts Items derived from the source texts: Türkiye 19 (14 unconditional), European Union 10 (6), United Kingdom 15 (6 binding, the rest guidance or conditional), United States 9 (3 unconditional, the rest conditional). Two misleading similarities First : identical thresholds do not mean identical procedure — who is notified and how it is displayed differ. Second : overlapping high-risk lists do not mean measures transfer; the evidence expected for the same work differs. One Turkish addition Türkiye's Annex 5 — façade scaffolds, temporary edge protection, mast climbing work platforms, safety nets — has no counterpart in the EU directive. For a cross-border contractor this is where the assumption "we comply with the EU, so we comply with Türkiye" breaks.

Obligation	Legal basis	How the page covers it
The employer or the project supervisor must draw up, or have drawn up, the health and safety plan during the preparation stage, before construction work begins.	Regulation on OHS in Construction Work, art. 8(2)	Side-by-side table: on the row 'general plan mandatory?', Türkiye — yes.
Notification threshold: work lasting more than 30 working days with more than 20 workers employed continuously, or work requiring more than 500 person-days.	Regulation on OHS in Construction Work, art. 8(4)	Side-by-side table: 'notification threshold' row — 30 working days plus 20 workers, or 500 person-days.
Where more than one employer or subcontractor is on the same site, a health and safety coordinator must be assigned.	Regulation on OHS in Construction Work, art. 8(1)	Side-by-side table: 'coordination' row — health and safety coordinator.
The preparation-stage coordinator prepares a health and safety file containing the health and safety information to be taken into account during the project and in any subsequent work.	Regulation on OHS in Construction Work, art. 10(1)(c)	Side-by-side table: 'separate file' row — health and safety file.
Annex 2 lists, in eleven items, the work that may expose workers to particular risks.	Regulation on OHS in Construction Work, Annex 2	Side-by-side table: 'list of high-risk work' row — Annex 2, eleven items.

Obligation	Legal basis	How the page covers it
The client or the project supervisor shall ensure that a safety and health plan is drawn up before the site is set up.	Directive 92/57/EEC, art. 3(2)	Side-by-side table: European Union — general plan mandatory.
Prior-notice threshold: work scheduled to last longer than 30 working days with more than 20 workers occupied simultaneously, or a volume of work exceeding 500 person-days.	Directive 92/57/EEC, art. 3(3)	Side-by-side table: 'notification threshold' row — 30 working days plus 20 workers, or 500 person-days.
Coordinators are appointed for the preparation and execution stages on any site where more than one contractor is present.	Directive 92/57/EEC, art. 3(1)	Side-by-side table: 'coordination' row — preparation-stage and execution-stage coordinator.
The preparation-stage coordinator prepares a file appropriate to the characteristics of the project containing relevant safety and health information to be taken into account during any subsequent works.	Directive 92/57/EEC, art. 5(c)	Side-by-side table: 'separate file' row — the file.
Annex II lists work involving particular risks to the safety and health of workers.	Directive 92/57/EEC, Annex II	Side-by-side table: 'list of high-risk work' row — Annex II.

Obligation	Legal basis	How the page covers it
During the pre-construction phase and before setting up a construction site, the principal contractor must draw up a construction phase plan or arrange for one to be drawn up.	CDM 2015, reg. 12(1)	Side-by-side table: United Kingdom — general plan mandatory.
A project is notifiable if the construction work is scheduled to last longer than 30 working days and have more than 20 workers working simultaneously at any point, or to exceed 500 person days.	CDM 2015, reg. 6(1)	Side-by-side table: 'notification threshold' row — the same threshold.
Where there is more than one contractor, or it is reasonably foreseeable that there will be, the client must appoint in writing a principal designer and a principal contractor.	CDM 2015, reg. 5(1)	Side-by-side table: 'coordination' row — principal designer plus principal contractor.
During the pre-construction phase the principal designer must prepare a health and safety file appropriate to the characteristics of the project.	CDM 2015, reg. 12(5)	Side-by-side table: 'separate file' row — the health and safety file.
Schedule 3 lists work involving particular risks, and the plan must include specific measures concerning work falling within those categories.	CDM 2015, Schedule 3 and reg. 12(2)	Side-by-side table: 'list of high-risk work' row — Schedule 3.

Obligation	Legal basis	How the page covers it
It shall be the responsibility of the employer to initiate and maintain such programs as may be necessary to comply with this part, and such programs shall provide for frequent and regular inspections of the job sites, materials and equipment by competent persons designated by the employer.	29 CFR 1926.20(b)(1)-(2)	Side-by-side table: United States — no general plan; instead an accident prevention program and competent-person inspections.
In no case is the prime contractor relieved of overall responsibility for compliance for all work under the contract; prime and subcontractor are deemed to have joint responsibility.	29 CFR 1926.16(a) and 1926.16(c)	Side-by-side table: 'coordination' row — prime contractor joint responsibility.

How does the site plan duty differ from country to country?

Side by side

Measured item counts

Two misleading similarities

One Turkish addition

Legal basis

Türkiye — obligations and their legal basis

European Union — obligations and their legal basis

United Kingdom — obligations and their legal basis

United States — obligations and their legal basis

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	Türkiye	European Union	United Kingdom	United States
General plan mandatory	Yes	Yes	Yes	No
Notification threshold	30 working days + 20 workers · or 500 person-days	30 working days + 20 workers · or 500 person-days	30 working days + 20 workers · or 500 person-days	None
Coordination	Health and safety coordinator	Preparation and construction coordinators	Principal designer + principal contractor	Prime contractor joint responsibility
Separate file	Health and safety file	File	Health and safety file	None
High-risk work list	Annex 2 (11 items)	Annex II	Schedule 3 (same 10 items as Annex II)	Work-specific conditional plans

How does the site plan duty differ from country to country?

Side by side

Measured item counts

Two misleading similarities

One Turkish addition

Related answers

Legal basis

Türkiye — obligations and their legal basis

European Union — obligations and their legal basis

United Kingdom — obligations and their legal basis

United States — obligations and their legal basis

Manage this in Optifora