Article — 6 min read
The test is proportionality, not length
Regulation 12 of CDM 2015 requires the principal contractor to draw up a construction phase plan before the construction phase begins. It does not specify a page count, and that is the source of most of the trouble. Plans arrive either as a four-page statement of intent that could describe any project, or as a 120-page document assembled from a template library that nobody on site has read.
The test applied in practice is whether the plan addresses the specific risks of this project, at a level of detail proportionate to those risks, and whether the arrangements it describes are actually in place. A short plan for a low-risk project is entirely defensible. A long plan that describes activities not present on the site is not.
What inspectors look for first
- The site-specific hazards, not the generic ones
- The arrangements for managing the significant risks, with named responsibilities
- Welfare arrangements, and evidence they exist from day one
- Emergency arrangements appropriate to the site, including access for emergency services
- Arrangements for the control and coordination of subcontractors
- How the plan will be reviewed and updated as the works progress
The last of those is the one most often missing. A construction phase plan is a live document. If the version on site is the one issued before mobilisation and the works have moved on substantially, the plan has stopped describing the project.
Common shortfalls
Welfare described but not provided
A plan that specifies welfare arrangements which are not on site on the first day is a straightforward enforcement issue and an easy one to avoid.
Generic risk content
Sections describing hazards that do not arise on the project dilute the sections that matter and suggest, correctly, that the document was not written for this job.
No coordination arrangements
Where several trades work in the same area, the plan needs to say who coordinates them and how. This is frequently left implicit.
Unreviewed after a significant change
A change in method, sequence or subcontractor should trigger a review. If the revision history is empty six months into a twelve-month programme, that is a finding.
A workable approach
Write the plan from the programme and the drawings, not from a template. Address each significant risk on the programme once, properly. Name the person responsible for each arrangement rather than the role in the abstract. Set a review interval and a list of triggers, and record each review even where nothing changed. And keep it short enough that the site manager will genuinely read it.
If you would like an independent review of a construction phase plan before it is issued, or before a client audit, we can turn one around within a few working days.