A construction phase plan is the document that says how a job will be run safely, written before the site is set up. Regulation 12 of the Construction (Design and Management) Regulations 2015 puts it on the principal contractor; where there is only one contractor on the job, regulation 15 puts the same duty on that contractor. Every project needs one, including a domestic extension. What changes with the size of the job is how long the plan is, not whether it exists.
Who has to write it, and when
The principal contractor draws up the plan during the pre-construction phase, before the construction phase begins. On a job with a single contractor, that contractor does it. The client's duty under regulation 4 is to make sure a plan is drawn up before the site is set up, which is why a principal contractor who cannot show one on day one has a client problem as well as an HSE problem.
The plan is a living document. Regulation 12(4) requires it to be reviewed, updated and revised as the job goes on, so a plan that still describes the groundworks when the roof is going on has stopped doing its job.
What HSE means by "proportionate"
HSE's guidance, L153, says the plan should be proportionate to the size and scale of the work and the risks involved. From the approving side of the desk, the plans that come back are rarely too short. They are generic: forty pages describing asbestos, confined spaces and overhead lines on a site that has none of them, and nothing about the thing that will actually hurt someone on that job. A two-page plan for a two-week job that names the real risks is a better plan than a template with the company name changed.
The sections a plan is expected to cover
Regulation 12(2) and Appendix 3 of L153 set out what the plan should contain. Written out as the sections a reviewer looks for, in order:
- The project — what is being built, where, for whom, the programme, and the key dates.
- Duty-holders and the site team — the client, the principal designer, the principal contractor, and who on site holds which role.
- The site as found — the constraints and the pre-construction information the client and designer handed over: services, ground, neighbours, access, existing structures.
- Management arrangements — how the work will be managed and monitored: who is in charge, how the site is supervised, how contractors are engaged and coordinated, how changes are controlled.
- Site rules — the rules everyone on site must follow, which regulation 12(2) specifically requires the plan to include.
- Site set-up, security and welfare — the boundary, access, traffic, storage, and the welfare facilities Schedule 2 requires from the first day.
- Induction, information and training — how people are inducted, how information reaches the workforce, and how the workforce is consulted.
- The significant risks on this project — not every hazard in construction: the ones on this job, and the document that controls each one.
- Work involving particular risks — the ten categories in Schedule 3, and which of them apply here. Where they do, the plan has to say how they are controlled.
- Emergency procedures and first aid — fire, evacuation, rescue from height or excavation, first aid cover, and who calls whom.
- The health and safety file — what will be collected for the file as the work goes on, and who holds it.
- Reviewing the plan — when it will be reviewed and who revises it.
That list is the structure of the KubitDocs construction phase plan, section for section. Each section is a guided field, so the plan is written for the job rather than inherited from the last one.
What sits around the plan
A construction phase plan on its own does not discharge CDM. On a real job it sits with:
- the pre-construction information the client and principal designer supplied
- the F10 notification, where the job is notifiable, and a record of the arithmetic if it is not
- the written appointments of the principal designer and principal contractor
- evidence that the client knows their duties, because regulation 15(1) says a contractor must not start work unless satisfied the client is aware of them
- skills, knowledge and experience checks for the people appointed
- site induction records, site rules for display, and a record of workforce consultation
- the health and safety file at the end
Those are the twelve documents in the CDM 2015 bundle, and the construction phase plan is the one you start with. Whether the job needs the full plan or the two-page small-works version is the proportionality judgement, and it is yours to make.
What a template does not do
A template gives you the structure and the regulation behind each section. It does not know your site, your people or your programme, and it cannot make anyone compliant. The plan becomes a plan when a competent person in your business fills the sections in for this job and signs it. Why we will never call a document "compliant".