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Do I need a construction phase plan?
Construction Phase Plans are sometimes treated as paperwork needed only for large building sites. This is incorrect.
Under the Construction (Design and Management) Regulations 2015, commonly known as CDM 2015, a suitable Construction Phase Plan must be prepared before construction work begins. This requirement applies to construction projects of every size, including short-duration work, domestic projects and projects involving only one contractor. and complexity of the document should be proportionate to the work. A one-day repair project will not require the same level of detail as a major development, but there must still be suitable evidence that the work has been properly planned.
At Lloyd Health & Safety, we help contractors, principal contractors and clients understand their CDM responsibilities. We can prepare project-specific Construction Phase Plans and provide complete, site-ready management folders containing the documentation needed to manage the project safely and professionally.
What is a Construction Phase Plan?
A Construction Phase Plan, often abbreviated to CPP, explains how health and safety will be planned, managed, monitored and coordinated during the construction phase of a project.
It should set out:
The arrangements for managing health and safety
The responsibilities of the organisations and individuals involved
The site rules that workers and visitors must follow
How contractors and different trades will cooperate
The arrangements for site induction, supervision and consultation
How significant project risks will be controlled
Emergency and rescue arrangements
Welfare arrangements
How the plan will be reviewed and updated
The CPP should provide a clear and practical framework for managing the site. It should not simply be a generic document produced to satisfy a tender requirement or stored in a folder without being used.
The Health and Safety Executive explains that the purpose of the document is to help plan, manage and monitor construction work so it can be carried out in a way that secures health and safety. is a Construction Phase Plan legally required?
A Construction Phase Plan is required for every project involving construction work covered by CDM 2015.
This includes:
New-build construction
Extensions and alterations
Refurbishment work
Demolition and dismantling
Structural alterations
Groundworks and excavations
Roofing work
Electrical and mechanical installations
Utility and infrastructure work
Installation of equipment that forms part of a structure
Many repair and maintenance activities
Construction work carried out for a domestic client
Short-duration and one-day projects
Projects involving only one contractor
CDM 2015 applies to all construction work, including domestic projects. The duties of a domestic client will normally pass to the contractor on a single-contractor project or to the principal contractor where more than one contractor is involved. t does not become exempt from the requirement simply because:
It is a small job
It will only take a few hours or days
There is only one contractor
The project is not notifiable to the HSE
Planning permission is not required
The client is a homeowner
The contract value is low
The work is described as maintenance
The amount of planning and documentation should, however, remain proportionate to the nature, complexity and risks of the work. HSE guidance specifically confirms that small builders must record their planning in a Construction Phase Plan and that the effort devoted to planning should reflect the project’s complexity and risks. would a project not require a Construction Phase Plan?
A CPP will not normally be required where the activity does not fall within the legal definition of construction work under CDM 2015.
For example, CDM does not apply where a householder carries out genuine DIY work entirely themselves rather than engaging a contractor. tine maintenance activities may also fall outside the definition of construction work. However, this must be considered carefully. Repairing, altering, refurbishing, dismantling or maintaining a structure can fall within CDM, depending on the nature of the activity.
Businesses should not assume that describing a project as “maintenance” removes the CDM requirements. Where there is uncertainty, competent advice should be obtained before work starts.
The practical question is not:
“Is this job large enough to need a CPP?”
The correct question is:
“Does this activity constitute construction work under CDM 2015?”
Where the answer is yes, a proportionate Construction Phase Plan must be prepared.
Who is responsible for preparing the CPP?
Responsibility depends on how many contractors are involved.
Projects involving one contractor
Where only one contractor will carry out the construction work, that contractor is responsible for preparing the Construction Phase Plan.
This can include a self-employed builder or tradesperson working alone.
Projects involving more than one contractor
Where a project involves, or is likely to involve, more than one contractor, the client must appoint a principal contractor.
The principal contractor is responsible for preparing the CPP before the construction phase begins. The principal contractor must then implement, review and revise the plan throughout the project. cipal contractor must also plan, manage, monitor and coordinate the construction phase, liaise with the client and principal designer, provide appropriate inductions, maintain welfare facilities and take reasonable steps to prevent unauthorised access. client’s responsibility
A commercial client must ensure that the contractor or principal contractor prepares a suitable Construction Phase Plan before construction starts. a competent health and safety consultant can assist with preparing the document, the legal dutyholder must still ensure that it is:
Suitable for the project
Based on accurate information
Properly implemented
Communicated to the workforce
Reviewed as the work changes
Commissioning someone to author the plan does not remove the contractor’s or principal contractor’s legal responsibility.
Does a non-notifiable project still need a CPP?
Yes.
One of the most common CDM misunderstandings is confusing the requirement for a Construction Phase Plan with the requirement to notify the HSE using an F10 notification.
A project is currently notifiable to the HSE where it is expected to:
Last longer than 30 working days and have more than 20 workers working simultaneously at any point; or
Exceed 500 person-days of construction work. resholds relate only to whether the project must be notified to the HSE.
They do not determine whether a Construction Phase Plan is required.
A project involving one builder for one day may not be notifiable, but if it involves construction work, it will still require a proportionate CPP.
What should a Construction Phase Plan contain?
The contents should reflect the scope, environment and risks of the individual project. A suitable plan will commonly cover the following areas.
Project information
The plan should clearly identify:
The client
The principal designer, where applicable
The principal contractor or contractor
The project location
The scope of work
Planned dates and duration
Key project contacts
The anticipated number of workers and contractors
Health and safety responsibilities
The CPP should establish who is responsible for:
Managing the site
Supervising the work
Reviewing RAMS
Delivering inductions
Inspecting work areas
Coordinating contractors
Managing temporary works
Responding to emergencies
Reporting incidents and near misses
Clear responsibilities help prevent important tasks from being overlooked or incorrectly assumed to belong to somebody else.
Site rules
The site rules should be relevant to the work and communicated through the induction process.
Depending on the project, they may address:
Minimum PPE
Signing in and out
Smoking and vaping
Mobile phone use
Restricted areas
Traffic and pedestrian routes
Hot works
Permit-to-work systems
Housekeeping
Waste management
Fire prevention
Drugs and alcohol
Working hours
Security
Emergency arrangements
HSE guidance confirms that all construction sites require appropriate site rules and site inductions. gement of significant risks
The CPP should explain how significant project risks will be controlled and coordinated.
These may include:
Work at height
Excavations and trenching
Underground services
Overhead power lines
Demolition and structural instability
Temporary works
Lifting operations
Mobile plant and vehicle movements
Public protection
Confined spaces
Hot works
Asbestos
Silica and construction dust
Hazardous substances
Noise and vibration
Electrical work
Fire and explosion
Interface with occupied buildings
Work near roads, schools, businesses or residential properties
The plan should not attempt to reproduce every risk assessment or method statement. Instead, it should explain how the risks will be managed, who will control them and what supporting documents, permits, inspections or hold points will be required.
Cooperation and coordination
Where several trades or contractors are involved, the plan should explain how their work will be coordinated.
This can include:
Pre-start meetings
Daily briefings
Programme coordination
RAMS reviews
Permit systems
Design coordination
Temporary works controls
Delivery arrangements
Shared access equipment
Contractor monitoring
Change management
Poor coordination can result in one contractor creating risks for another. A suitable CPP helps identify and manage these interfaces before they lead to an incident or project delay.
Competence, training and supervision
The plan should describe how the project will confirm that workers and contractors have the appropriate skills, knowledge, training and experience.
Records may include:
CSCS or relevant competency cards
Plant operator qualifications
Trade qualifications
Asbestos awareness
Face-fit testing
First-aid training
Temporary works appointments
Lifting appointments
Electrical authorisations
Site-specific briefings
The required level of supervision should reflect the work, the workforce and the risks involved.
Welfare arrangements
Suitable welfare must be available from the beginning of the construction phase and maintained throughout the project.
Depending on the project, this may include:
Toilets
Hot and cold or warm running water
Soap and suitable drying facilities
Drinking water
Rest and eating facilities
Changing facilities
Facilities for drying wet clothing
Showers where required
HSE guidance confirms that Schedule 2 of CDM 2015 establishes minimum welfare requirements for construction sites. gency arrangements
The CPP should explain what will happen in foreseeable emergencies, including:
Fire
Serious injury or illness
Service strikes
Structural collapse
Excavation collapse
Work-at-height rescue
Confined-space rescue
Environmental spills
Severe weather
Security incidents
It should identify the emergency contacts, first-aid arrangements, assembly points and any specialist rescue equipment or trained personnel required.
Emergency arrangements should be realistic and suitable for the site. Simply stating “call 999” may not be enough where workers are operating at height, inside an excavation, in a confined space or at a remote location.
Monitoring and review
A CPP is a live management document.
It should be reviewed when:
The scope changes
New contractors are appointed
The design changes
Different work activities begin
New hazards are identified
An incident or near miss occurs
The programme changes
The site layout changes
The existing controls are found to be ineffective
The principal contractor is expected to regularly review and revise the plan so that it remains suitable for the project.
CPP the same as RAMS?
No.
A Construction Phase Plan and risk assessments and method statements perform different but connected functions.
The CPP explains the overall arrangements for managing the construction phase. It establishes the management structure, responsibilities, rules, coordination arrangements, welfare, emergency procedures and approach to controlling significant risks.
RAMS normally address a particular task or activity, such as:
Excavating a trench
Installing roof sheets
Operating a mobile elevating work platform
Lifting a transformer
Installing underground cables
Carrying out demolition
The RAMS should support the arrangements established in the CPP. A collection of generic risk assessments does not automatically constitute a suitable Construction Phase Plan.
Can a CPP be simple?
Yes. A CPP should be proportionate.
For a straightforward, low-risk project involving one contractor, the plan may be relatively concise. It could include the project details, key risks, welfare arrangements, emergency information, site rules and the arrangements for managing the work.
For a complex project involving multiple contractors, high-risk activities, temporary works, public interfaces or significant design risks, the CPP will need to be considerably more detailed.
A good plan is not measured by its page count. It is measured by whether it:
Reflects the actual project
Identifies the relevant risks
Defines responsibilities
Establishes workable controls
Can be understood and used on site
Remains current throughout the work
How Lloyd Health & Safety can help
Preparing a suitable CPP can be challenging, particularly for small contractors who may understand how to complete the work safely but are unsure how to demonstrate their arrangements in writing.
Lloyd Health & Safety can prepare a tailored Construction Phase Plan using information about your project, including:
The scope and programme
Client and contractor arrangements
Drawings and specifications
Pre-construction information
Site conditions
Planned work methods
Significant risks
Welfare and emergency arrangements
Interfaces with the public or other businesses
We can also review an existing CPP to identify missing information, generic content or areas that do not adequately reflect the project.
Our approach is practical and proportionate. We aim to create documents that can be understood and used by the people managing and completing the work, rather than producing paperwork that simply sits in an office.
Complete site-ready management folders
In addition to authoring the CPP, Lloyd Health & Safety can produce a complete site-ready management folder tailored to the requirements of the project.
Depending on the scope, the folder may contain:
Construction Phase Plan
Site-specific induction
Site rules
Emergency plan
Fire and evacuation arrangements
First-aid information
Site contact sheet
Risk assessments and method statements
COSHH assessments
Site inspection forms
Plant and equipment inspection records
Competence and training register
Toolbox talk records
Permit-to-work forms
Temporary works register
Lifting operation documentation
Accident and near-miss forms
Daily briefing records
Visitor and contractor sign-in sheets
Environmental controls
Waste management information
Welfare inspection records
Public protection arrangements
Traffic management information
The exact contents will be selected according to the project. This helps ensure that site management has the documents needed from the beginning rather than trying to develop them after work has already started.
Start your project properly
A Construction Phase Plan is more than a legal document. When prepared properly, it gives the project team a clear structure for managing health, safety and site coordination.
Effective planning can help prevent injuries, reduce disruption, improve contractor coordination, avoid enforcement action and prevent expensive delays caused by risks that should have been identified before work began.
Lloyd Health & Safety provides practical support to contractors, principal contractors, developers and construction clients across Wales and the wider UK.
For assistance with a Construction Phase Plan, CDM compliance or a complete site-ready management folder, contact:
Lloyd Health & Safety Website: www.lloydhs.co.ukTelephone: 07414 047477
This article provides general information about CDM 2015 and should not be treated as project-specific legal advice. Every project should be assessed according to its particular scope, duty holder arrangements and risks.
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