Guide
Create a construction phase plan
How to prepare a construction phase plan under CDM 2015 Regulation 12. Covers what must be included, when it must be ready, who is responsible, and how to keep it updated throughout the project.
Before any construction work can begin, there must be a written construction phase plan in place. This is a legal requirement under the Construction (Design and Management) Regulations 2015 (CDM 2015), regardless of project size.
The construction phase plan sets out how health and safety will be managed during the construction phase. It is not just a document to satisfy an inspector - it is a practical tool for coordinating work safely on site.
Starting construction without a plan is a criminal offence. The Health and Safety Executive (HSE) can prosecute, and recent fines have exceeded GBP 100,000 for CDM failures.
Who must prepare the construction phase plan
The responsibility for preparing the construction phase plan depends on how many contractors are involved:
- Multi-contractor projects: The Principal Contractor must prepare, review, and update the construction phase plan
- Single-contractor projects: The sole contractor prepares the plan and effectively takes on the Principal Contractor role for CDM purposes
The Principal Designer must assist by providing pre-construction information relevant to planning the construction phase safely.
When the plan must be ready
The construction phase plan must be prepared during the pre-construction phase and must exist before the construction site is set up.
Critical timing:
- No construction work may begin until the plan exists
- The plan must be complete enough to address risks of initial work activities
- The client has a duty to ensure the plan is in place before allowing construction to start
This means you cannot start work and then produce a plan retrospectively. Even simple enabling works require the plan to be in place first.
What the construction phase plan must contain
CDM 2015 Regulation 12(2) specifies the minimum content. The plan must include:
Regulation 12(2) requirements explained
Arrangements for managing health and safety: This includes who is responsible for what, the management structure, reporting lines, communication arrangements, and how health and safety will be monitored.
Site rules: Specific rules for this site that all contractors and workers must follow. This includes access arrangements, prohibited activities, PPE requirements, permit-to-work procedures, and behaviour standards.
Arrangements for welfare facilities: Location and type of toilets, washing facilities, rest areas, drinking water, and changing facilities. These must be in place before work begins.
Information for the health and safety file: How information will be collected and provided to the Principal Designer for inclusion in the health and safety file.
Specific measures for Schedule 3 work: If the project involves any of the ten categories of high-risk work listed in Schedule 3, the plan must include specific measures to address these risks.
High-risk work requiring specific measures
CDM 2015 Schedule 3 lists ten categories of work involving particular risks. If your project includes any of these, the construction phase plan must include specific control measures:
For each Schedule 3 activity on your project, the plan must describe the specific hazards, the control measures to be implemented, who is responsible for implementing them, and how compliance will be monitored.
HSE recommended contents
Beyond the statutory minimum, HSE guidance (CIS80 and L153) recommends the construction phase plan includes:
- Project description
- Work scope, location, key dates, planned duration, phases
- Project team contacts
- Client, Principal Designer, Principal Contractor details with phone numbers
- Health and safety aims
- Overall safety objectives and targets for the project
- Site-specific risks
- Risk assessments for significant hazards on this site
- Cooperation arrangements
- How contractors will coordinate work to avoid creating risks
- Worker involvement
- How workers will be consulted on health and safety matters
- Site induction details
- What induction covers, who provides it, when it must happen
- Emergency procedures
- Fire points, assembly points, first aid, emergency contacts
- Training requirements
- Required qualifications, certifications, and competencies
- Traffic management
- Pedestrian and vehicle separation, delivery arrangements
Proportionality principle: The plan should be proportionate to the project. A simple refurbishment needs a simpler plan than a major construction project. What matters is that the plan addresses the actual risks of this project, on this site, with these contractors.
How to create the construction phase plan
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Gather pre-construction information
Obtain all relevant information from the client and Principal Designer before starting the plan. This includes site surveys, asbestos reports, existing drawings, ground conditions, underground services, and previous health and safety files. You cannot plan safely without this information.
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Identify the project risks
Based on pre-construction information, identify significant health and safety risks for this project. Consider: working at height, excavations, lifting operations, hazardous materials, demolition, existing services, traffic, public access, and any Schedule 3 activities.
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Determine the management structure
Define who is responsible for health and safety on site. Document the reporting lines, who workers should report hazards to, who can stop unsafe work, and how decisions will be made. Include contact details for key personnel.
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Develop site rules
Create specific rules for this site. Include PPE requirements, access control, prohibited activities, permit-to-work requirements, smoking/alcohol policies, and any client-specific requirements. Site rules must be communicated to all workers.
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Plan welfare facilities
Determine what facilities are needed (based on workforce size) and where they will be located. Ensure toilets, washing facilities, rest areas, and drinking water will be in place before work begins.
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Plan emergency arrangements
Document fire escape routes, assembly points, first aid provision, emergency contacts, and procedures for serious injuries. Consider how emergencies will be communicated on a noisy site.
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Address Schedule 3 activities
For each high-risk activity on the project, document specific control measures, method statements, permit requirements, and who is responsible for implementation and supervision.
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Document coordination arrangements
Explain how contractors will communicate, coordinate work to avoid conflicts, and share information about risks they create for others. Include arrangements for regular site meetings.
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Plan site induction
Define what the site induction will cover, who will deliver it, and ensure no one works on site before receiving induction. The induction must cover site rules, emergency procedures, and specific hazards.
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Set up information collection for H&S file
Establish how information will be gathered from contractors for the health and safety file, including as-built drawings, materials used, and residual hazards.
Reviewing and updating the plan
The construction phase plan is a living document. CDM 2015 Regulation 12(4) requires the Principal Contractor to review, update, and revise the plan throughout the project.
Update the plan when:
- New contractors come onto site
- The sequence of work changes
- New risks are identified
- Design changes affect site safety
- Incidents occur that require control measures to be revised
- Welfare arrangements change
- New high-risk activities are introduced
Regular reviews: At minimum, review the plan monthly on longer projects, or when significant phases of work complete. Document when reviews occurred and what changes were made.
Communication: When the plan is updated, ensure all relevant contractors and workers are informed of changes that affect them. Changes to site rules or emergency procedures must be communicated immediately.
Common mistakes to avoid
Using a generic template: A construction phase plan with just the project name changed is not compliant. The plan must address the specific risks of this project, on this site. Inspectors can easily spot template documents.
Starting work before the plan exists: This is a criminal offence. Even if the project is simple or you are under time pressure, construction cannot begin until the plan is in place.
Treating it as a one-off document: The plan must evolve as the project progresses. A plan that sits in a drawer is not being used properly. It should be a practical, working document referenced regularly.
Not including Schedule 3 measures: If your project involves high-risk activities, generic statements are not sufficient. You need specific measures documented in the plan.
Missing welfare arrangements: Workers need toilets, washing facilities, rest areas, and drinking water from day one. Do not assume these will sort themselves out.
No arrangements for cooperation: On multi-contractor sites, you must explain how contractors will coordinate. Accidents often occur at interfaces between different trades.
Penalties for non-compliance
Failing to prepare a compliant construction phase plan, or starting work without one, is a criminal offence under CDM 2015.
HSE actively inspects construction sites and can issue Improvement Notices requiring plan deficiencies to be corrected, Prohibition Notices stopping work until compliance is achieved, or prosecute for serious failures.
Beyond criminal penalties, inadequate planning can lead to civil claims if workers are injured, increased insurance premiums, loss of future work, and reputational damage.
Single-contractor and domestic projects
Single-contractor projects: If you are the only contractor on a project, you are responsible for preparing the construction phase plan. The plan can be simpler for lower-risk work, but it must still exist.
Domestic clients: When working for a homeowner (domestic client), CDM duties transfer to you as the contractor. You are responsible for the construction phase plan, even though the client is not a commercial organisation.
The plan should be proportionate - a kitchen fit-out needs a simpler plan than a house extension with structural work. But you cannot skip the requirement entirely.
Related guidance
The construction phase plan is part of the wider CDM compliance framework. You may also need to understand:
- CDM duty holder responsibilities - understand the full scope of Principal Contractor duties
- CDM client duties - what clients must do to support the Principal Contractor