Manage the CDM health and safety file

What is the health and safety file

The health and safety file is a record of information about the structure that will be useful for anyone carrying out future work on it. The file is required under CDM 2015 Regulation 12(5).

When the file is required: the regulation 12(5) duty sits on the Principal Designer, who is only appointed on projects involving more than one contractor. On single-contractor projects there is no statutory requirement for a health and safety file - although keeping one is good practice, especially where the work creates hazards (such as concealed services or structural alterations) that future workers will need to know about.

Its purpose is to ensure that people doing maintenance, repairs, refurbishment, cleaning or demolition in the future have the information they need to work safely. For example:

• A maintenance contractor needs to know about asbestos-containing materials
• A roofer needs to know about fragile roof panels
• A demolition contractor needs to know about structural design and pre-stressed elements
• A facilities manager needs to know about safe access for cleaning and maintenance

The file is not a record of the construction process itself. It contains only information relevant to future health and safety.

Who is responsible for the file

Responsibility for the health and safety file passes through several hands during and after a project:

Principal Designer

The Principal Designer must:

• Prepare the file during the pre-construction phase
• Review, update and revise it throughout their appointment
• Include information provided by designers about residual hazards
• Pass the file to the Principal Contractor if their appointment ends before project completion

Principal Contractor

If the Principal Designer's appointment ends before the project is complete, the Principal Contractor must:

• Take over the file from the Principal Designer
• Continue to update it during construction
• Ensure relevant information from construction activities is included
• Hand the completed file to the client at project completion

Client

At project completion, the client must:

• Receive the file and ensure it is complete
• Keep the file available for anyone who needs it for future work
• Pass the file to any new owner if the structure is sold
• Ensure the file is updated if further construction work takes place

If no Principal Designer is appointed

If the client fails to appoint a Principal Designer on a multi-contractor project, the client assumes Principal Designer duties, including preparing the health and safety file. This is rarely practical - most clients lack the technical knowledge to compile an adequate file.

When to start the file

Begin the health and safety file during the pre-construction phase, as soon as relevant information becomes available. Do not leave it until the end of the project.

Pre-construction phase

During design, gather and record:

• Design decisions that affect future work (such as structural load paths or pre-stressed elements)
• Residual hazards that could not be designed out
• Information about hazardous materials specified in the design
• Safe access arrangements for maintenance and cleaning

Construction phase

During construction, update the file with:

• As-built information where it differs from design
• Location and nature of services (especially those that are buried or concealed)
• Product data sheets for materials used
• Operation and maintenance manuals for installed plant and equipment
• Any unexpected hazards discovered during construction (such as contaminated ground)

Tip: Set up a process at project start for collecting file information. Make it a standing agenda item at design team meetings and site progress meetings.

What the file must contain

CDM 2015 requires the file to contain "information likely to be needed during any subsequent project to ensure the health and safety of any person". The HSE's L153 guidance recommends including:

What NOT to include

The health and safety file should be proportionate to the project. A file filled with irrelevant information is difficult to use and important hazards may be missed. Do not include:

• Construction phase plan: This is a separate document for managing construction-phase safety
• Risk assessments and method statements: These relate to construction, not future work
• Routine CDM paperwork: F10 notifications, competence checks, meeting minutes
• Generic product information: Include only data sheets for materials where there are specific health and safety implications
• Complete design packages: Include only the information relevant to safe future work

Golden rule: Ask yourself "Will this information help someone work safely on this structure in the future?" If yes, include it. If not, leave it out.

Format requirements

CDM 2015 does not specify a particular format for the health and safety file. HSE guidance says the file should be:

• Proportionate: File size and detail should match the project's complexity and risks
• Usable: Organised so users can find what they need quickly
• Accessible: Available to anyone who needs it for future work
• Updatable: Capable of being revised as future work is carried out

Electronic vs paper files

Either format is acceptable. Electronic files offer advantages:

• Easier to share with contractors
• Searchable
• Easier to update
• Less likely to be lost

If using electronic format, ensure the client can access and read the files (common formats like PDF are preferable to proprietary software).

Suggested structure

A typical file might be organised as follows:

1. Project introduction and contacts
2. Residual hazards register
3. Hazardous materials schedule
4. Key structural principles
5. Services information and drawings
6. Maintenance access strategy
7. As-built drawing register
8. Operation and maintenance manuals
9. Relevant surveys and reports

Handover to client

At project completion, the file must be handed to the client. This is a formal handover, not just emailing some documents.

Client duties: keeping and updating the file

Once the client receives the file, they have ongoing CDM duties regarding it:

Keep the file available

The client must keep the file available for inspection by anyone who needs it for future construction work, maintenance or cleaning. This includes:

• Maintenance contractors
• Cleaning contractors
• Designers and contractors for future alterations
• Building surveyors
• Demolition contractors

"Available" means the client must be able to produce it when asked. A file buried in an archive that nobody can find does not meet the requirement.

Update the file

If further construction work takes place on the structure, the health and safety file must be updated to reflect that work. The client should:

• Provide the existing file to designers and contractors at the start of any future project
• Ensure the Principal Designer (or contractor on smaller projects) updates the file
• Receive the updated file at the end of each project

Pass it on when selling

If the client sells or otherwise disposes of the structure, they must pass the file to the new owner and explain its purpose. This is a legal duty under CDM 2015 Regulation 4(7).

Making the file available for future work

The whole point of the health and safety file is that it is used. If contractors cannot access the file, it provides no benefit.

Best practice for clients:

• Know where the file is stored (this sounds obvious but files often get lost)
• Include file location in your building management or facilities records
• Make the file available to any contractor quoting for future work
• Include the file as pre-construction information for any future CDM project
• Review the file periodically to ensure it remains usable and up to date

For leased premises: If you are a tenant, check whether the landlord holds the health and safety file and can provide it. If you carry out construction work, ensure the updated file reaches whoever should hold it (often the freeholder).

Common problems with health and safety files

HSE inspectors frequently identify these issues with health and safety files:

• File not created at all: Some projects complete without any file being prepared. This is a breach of CDM 2015.
• File created at the last minute: Rushing to assemble a file at handover typically results in missing information. Start the file during design.
• File is a generic template: A template with project name filled in is not acceptable. Content must be specific to the actual structure.
• Too much irrelevant information: Files stuffed with every document generated on the project are unusable. Include only information relevant to future health and safety.
• Missing as-built information: Drawings showing the design, not what was actually built, are dangerous. Ensure as-built drawings are accurate.
• File not handed over: The file sits in a filing cabinet in the contractor's office. Ensure formal handover to the client.
• Client loses the file: Once handed over, files frequently go missing. Clients should have a system for keeping the file accessible.
• File not updated: After subsequent construction work, the file does not reflect the current state of the structure. Update after every project.

Penalties for non-compliance

Failing to prepare, update or keep a health and safety file is a breach of CDM 2015 and a criminal offence. HSE can prosecute:

• Principal Designers who fail to prepare or maintain the file
• Principal Contractors who fail to provide information for the file or hand it over
• Clients who fail to ensure the file is prepared, or who fail to keep it available

Health and safety file checklist

Use this checklist to ensure your file is complete:

Related guides

For more information about CDM duties and compliance:

• CDM 2015: your duties as a construction client - client responsibilities including appointments and notifications
• Comply with CDM Regulations for construction projects - comprehensive overview of CDM 2015 requirements