Plenty of small contractors become the principal contractor without anyone announcing it. You win a job direct from a client, you bring in a couple of trades, and the duties arrive with the work.
When it applies to you
Under the Construction (Design and Management) Regulations 2015, where a project involves more than one contractor, regulation 5 requires the client to appoint a principal designer and a principal contractor in writing, as soon as is practicable and in any event before the construction phase begins. Where a commercial client fails to appoint a principal contractor, regulation 5 provides that the client must fulfil the duties in regulations 12 to 14 itself.
Domestic clients work differently. Regulation 7 provides that the client duties in regulations 4(1) to (7) and 6 are carried out instead by the contractor — or, where there is more than one contractor, by the principal contractor. And where a domestic client makes no appointment, regulation 7 states that the contractor in control of the construction phase is the principal contractor. No letter, no announcement. If you are running the job, the duties are yours.
Two other points decide what you have to produce:
- A construction phase plan is required on every project, however small. Regulation 12 puts it on the principal contractor, to be drawn up during the pre-construction phase and before setting up a construction site; where you are the only contractor, regulation 15 puts the same requirement on you. HSE's own position is that it should be proportionate to the size and scale of the job.
- Notifiable work must be notified to HSE on form F10 before the construction phase begins. HSE states the thresholds as work expected to last longer than 30 working days and have more than 20 workers working at the same time at any point on the project, or to exceed 500 person days. Every day on which construction work is likely to be carried out counts, including weekends and holidays.
We are not going to tell you which of these applies to your job. That is a judgement about your project, and it belongs to a competent person who knows it. What we can do is give you the documents each duty expects, with the regulation printed on the form so you can check the position yourself or put it in front of an adviser.
What running the site actually requires
A construction phase plan before work starts, proportionate to the job — the risks that are genuinely on your project, the arrangements to control them, and how the site is managed. Plans commonly come back because they are a generic document describing hazards nobody on that site will meet.
Control of who works where. Induction, competence checks and the arrangements for coordinating trades who are on each other's toes.
Permits for the high-risk activities. Hot works, confined spaces, excavation, work at height, roof work, lifting, electrical isolation. A permit system is not a stack of forms — it is a controlled sequence with a named issuer, a named acceptor, an isolation record, a register, and a hand-back. Our Permit to Work Suite is that sequence, with the appointment certificates and the audit checklist that make it real.
A health and safety file at the end, passed to the client for whoever works on the structure next.
What is available
The Permit to Work Suite is on sale, as are the RAMS library and the New build housing set. The CDM 2015 bundle — construction phase plan, pre-construction information, notification, appointment and competence records, and the health and safety file — is the next one being built, and the waitlist is how you find out when it lands.