What is the health and safety file under CDM 2015?
The health and safety file is a record of the finished building for whoever does later work on it. It is only required where more than one contractor works on the project. The principal designer prepares it and it goes to the client at the end.
When a project needs one
Regulation 5 of CDM 2015 requires the client to appoint a principal designer and principal contractor in writing where there is more than one contractor, or it is reasonably foreseeable that more than one will work on the project. HSE guidance (L153) says the file is only required on those projects.
Contractors include sub-contractors, sole traders and self-employed workers, so a builder who brings in a self-employed electrician has a multi-contractor job. A single-contractor job needs a construction phase plan but not a file.
On a domestic job with several contractors, the client duties, including making sure the file is prepared, normally pass to the principal contractor (regulation 7). The principal designer can take them on instead by written agreement with the client.
Who prepares it
The principal designer must prepare the file in the pre-construction phase, then review and update it as the project goes on (regulation 12(5) and (6)). The principal contractor must pass over anything it holds that belongs in it (regulation 12(7)).
If the principal designer's appointment ends before the project does, the file passes to the principal contractor, who keeps it up to date (regulation 12(8) and (9)). At the end, the principal designer, or the principal contractor where there is no principal designer, passes it to the client (regulation 12(10)). On a commercial job with no principal designer appointed, the client must do the principal designer's duties (regulation 5(3)).
What goes in it
The test is whether information is likely to be needed for safe later work, such as maintenance, cleaning, refurbishment or demolition (regulation 12(5)). L153 lists what to consider including:
- a short description of the work
- hazards not eliminated by the design and construction, and how they were dealt with, such as asbestos or contaminated land surveys
- key structural principles, such as bracing, and safe working loads for floors and roofs
- hazardous materials used, such as lead paint
- how installed plant can be removed or dismantled
- safety information on equipment for cleaning or maintaining the structure
- the location and marking of significant services, including underground cables and gas supply
- as-built drawings, including safe access to service voids and fire doors
These are things to consider, not a form to fill in.
What stays out, and keeping it proportionate
L153 says to leave out anything that will not help plan future work, and names pre-construction information, the construction phase plan, contractual documents and safety method statements. The detail should be enough for later workers to spot the likely risks, in proportion to those risks, and the information should be clear, concise and easy to use.
On a small project that can be a short document: a description of the work, as-built drawings, surveys, and a note of where services and hazards are. L153 says the principal designer should agree the structure and content with the client early on.
Good practice: collect as you go, not in the last week. Ask each trade for isolation points, product data and hazardous materials when they finish, because L153 notes this is hard to get once people have left.
Handing it over, keeping it and passing it on
L153 says whoever hands over the file should make sure the client understands how it is set out and why it matters. It can be on paper, electronic or any other durable form.
The client must keep it available to anyone who needs it to comply with legal requirements, revised as appropriate (regulation 4(5)). L153 says that means for as long as it is relevant, normally the life of the building.
If the client disposes of their interest in the building, regulation 4(7) says they comply by giving the file to the new owner and making sure that person knows its nature and purpose. L153 adds that if only part is sold, the relevant information is passed or copied on, and tenants should be able to see it. The next project starts from it: the client gives it to the next principal designer.
Sources
- HSE: Managing health and safety in construction (L153), including appendix 4
- HSE: Principal designers, roles and responsibilities
- legislation.gov.uk: CDM 2015, regulation 12 (construction phase plan and health and safety file)
- legislation.gov.uk: CDM 2015, regulation 4 (client duties)
- legislation.gov.uk: CDM 2015, regulation 5 (appointments)
- legislation.gov.uk: CDM 2015, regulation 7 (domestic clients)