For contractors
What are the principal contractor's duties under CDM 2015?
Short answer
The principal contractor must plan, manage and monitor the construction phase and coordinate health and safety through it, under regulation 13. They must draw up the construction phase plan and keep it current under regulation 12, provide site inductions, keep unauthorised people out, make sure the Schedule 2 welfare facilities are provided, and consult and engage with workers under regulation 14. On a domestic project they also pick up the client's duties under regulation 7(1).
The duties
- Plan, manage and monitor the construction phase
Regulation 13(1), coordinating health and safety through it so the work is carried out without risks so far as is reasonably practicable.
- Draw up the construction phase plan
Regulation 12(1), before setting up the site, and keep it reviewed, updated and revised under regulation 12(4).
- Organise cooperation between contractors
And coordinate their work, so that one trade's activity does not create a risk for another's.
- Site induction, and keeping people out
Regulation 13: inductions for everyone working on site, and reasonable steps to prevent unauthorised access.
- Welfare
The Schedule 2 facilities: sanitary conveniences, washing facilities, drinking water, changing rooms and lockers where needed, and rest facilities.
- Consult and engage with workers
Regulation 14. Arrangements for workers to cooperate in developing, promoting and checking the effectiveness of health and safety measures, and consulting them on matters affecting their safety.
- Feed the health and safety file
Regulation 12(7): give the principal designer any information relevant to the file. If the principal designer leaves first, regulation 12(8) hands the file over to the principal contractor to finish.
The extra layer on domestic projects
Regulation 7(1) moves the domestic client's duties in regulations 4(1) to (7) and 6 onto the principal contractor, unless there is a written agreement for the principal designer to take them. So on a domestic project the principal contractor is carrying two sets of duties: their own, and the homeowner's.
And under regulation 7(2), if the homeowner appointed nobody, the contractor in control of the construction phase is the principal contractor by default, whether or not they know it.
What is not the principal contractor's job
- Coordinating the design. That is the principal designer, regulation 11.
- Assembling the pre-construction information. HSE guidance is explicit that the principal contractor has no specific duty in relation to it, though they must liaise with the principal designer.
- Preparing the health and safety file, unless the principal designer's appointment finishes first and the file is passed across under regulation 12(8).
Sources
- CDM 2015, regulation 12: construction phase plan and health and safety file legislation.gov.uk
- CDM 2015, regulation 13: duties of a principal contractor legislation.gov.uk
- CDM 2015, regulation 7: application to domestic clients legislation.gov.uk
- HSE: principal contractors, roles and responsibilities hse.gov.uk
- Managing health and safety in construction, L153 HSE guidance on the Regulations
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