Every construction project in Great Britain requires a Construction Phase Plan (CPP) under the Construction (Design and Management) Regulations 2015. That requirement is not limited to large projects, notifiable projects or jobs that meet the F10 threshold. The plan must set out how health and safety will be managed during construction and must be proportionate to the scale, complexity and risks of the work. A short refurbishment may justify a concise document. A major multi-contractor project may require a far more developed management system. What CDM 2015 does not support is treating the CPP as a generic template completed once and forgotten.
Construction works at 75 London Wall in the City of London, illustrating the active construction phase in which project-specific planning, site controls and CDM management arrangements must remain live. Image: London Construction Magazine.
Every Construction Project Needs a Construction Phase Plan
One of the most persistent CDM myths is that a Construction Phase Plan is only required where a project is notifiable to the Health and Safety Executive. It is not. F10 notification and the CPP are separate requirements. The current notification thresholds determine whether a project must be notified to HSE; they do not determine whether construction-phase planning is required. LCM's guide to CDM F10 notification explains that distinction in detail.
On a project involving more than one contractor, CDM 2015 Regulation 12 places the duty on the Principal Contractor to draw up the Construction Phase Plan during the pre-construction phase and before setting up the construction site. Where there is genuinely only one contractor, Regulation 15 applies instead. The contractor must ensure that a Construction Phase Plan is drawn up before the construction phase begins.
That distinction matters. If a project expected to use one contractor later brings another contractor into the construction work, the project no longer operates as a single-contractor arrangement and the CDM management structure needs to reflect that change. Domestic projects are not exempt either. CDM 2015 transfers domestic-client duties through Regulation 7. On a multi-contractor domestic project, where the homeowner has not made the required appointments, the statutory mechanism can place Principal Contractor duties on the contractor controlling the construction phase.
What Must a Construction Phase Plan Actually Contain?
The legal minimum is narrower than many commercial templates suggest. Regulation 12 requires the CPP to set out the health and safety arrangements and site rules for the construction phase and, where applicable, specific measures concerning the higher-risk activities identified in Schedule 3. Those Schedule 3 matters include activities where workers may be exposed to risks such as burial, engulfment, falls from height, hazardous substances, high-voltage power lines, drowning, underground work, diving, compressed-air work and the assembly or dismantling of heavy prefabricated components.
HSE's L153 guidance, Managing health and safety in construction, goes further by recommending practical information that helps make the plan usable. Depending on the project, that can include management arrangements, responsibilities, inductions, cooperation between contractors, emergency procedures, welfare, site security, traffic routes and arrangements for significant construction risks.
The distinction is important: not every heading commonly found in a commercial CPP template is itself an individual statutory requirement. A project organogram, contact directory or lengthy corporate policy section may be useful, but the purpose of the CPP is to control the actual project risks — not to create the largest document possible. A 250-page plan containing generic company policies but saying little about a live excavation, occupied-building interface or temporary support system can therefore be less useful than a concise project-specific plan that clearly identifies who controls those risks and how.
A CPP Is Not RAMS, PCI or the Health and Safety File
The Construction Phase Plan sits within a wider CDM information chain but should not be confused with the documents around it.
Pre-Construction Information (PCI) is information provided before and during pre-construction to help designers and contractors understand the project, site and foreseeable risks. The CPP uses that information to establish how the construction phase will be managed.
RAMS deal with particular activities and work methods. A lifting operation, demolition sequence, confined-space entry or specialist installation may require its own assessment and method statement, but a folder containing subcontractor RAMS is not itself a Construction Phase Plan.
The Health and Safety File has a different purpose again: it records information likely to be needed to manage health and safety during future use, maintenance, alteration or demolition of the completed structure. The CPP does not simply become the Health and Safety File when the project finishes.
Temporary works also require their own structured control system. A CPP might state how the project will manage temporary works, but it should not attempt to replace the temporary works register, design briefs, design checks or permit process. LCM's guide to temporary works compliance under BS 5975 and CDM 2015 explains that separate control framework.
The Construction Phase Plan Must Remain Live
A compliant CPP is not completed at mobilisation and then left unchanged for the rest of the programme. Regulation 12 requires the Principal Contractor to review, update and revise the plan so that it continues to remain sufficient for the construction work being carried out. Triggers can include a major design change, new contractors, changed site logistics, unexpected ground conditions, asbestos discoveries, revised lifting arrangements, altered temporary works, changed emergency procedures or a new interface with an occupied building or members of the public.
Welfare is another area where the written plan must match reality. CDM Schedule 2 requires suitable welfare facilities, including appropriate sanitary, washing, drinking-water and rest arrangements. A statement in the CPP that facilities are available is of little value if workers arrive and cannot actually use them. Emergency arrangements should also reflect the work being undertaken. For higher-risk activities, generic wording such as “call 999” may not address the immediate rescue or stabilisation measures needed before the emergency services arrive. The same principle applies to work at height, where site-specific rescue arrangements may be necessary rather than relying solely on external emergency response.
For Higher-Risk Buildings in England, another distinction becomes important. The CDM Construction Phase Plan remains an occupational health and safety document. It should not be confused with the separate Construction Control Plan required under the Building Regulations regime for relevant Higher-Risk Building work. The two systems may need to coordinate, but they exist for different statutory purposes. The practical test is straightforward: the Construction Phase Plan should describe how the project being built today will actually be managed safely today. If the site, sequence, contractors or risks have changed but the CPP has not, the document is no longer doing its job.
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Expert Verification & Authorship: Mihai Chelmus Founder & Editor, London Construction Magazine | Construction Testing & Investigation Specialist |