A Construction Phase Plan is required for every construction project covered by the Construction (Design and Management) Regulations 2015, including projects with only one contractor. There is no minimum project value, duration or F10 notification threshold before the requirement applies.
The plan must be in place before the construction phase begins. On a project involving more than one contractor, the Principal Contractor prepares it. Where there is only one contractor, that contractor prepares it. The important qualification is proportionality: a one-day repair may need only a short, focused plan, while a complex demolition or refurbishment project will require considerably more detail.
Active construction works with scaffolding and cranes in the City of London. Photograph: London Construction Magazine
When is a Construction Phase Plan required?
The requirement comes from the Construction (Design and Management) Regulations 2015. Regulation 12 requires the Principal Contractor on a multi-contractor project to draw up the Construction Phase Plan, or arrange for it to be drawn up, during the pre-construction phase and before setting up the construction site. For a single-contractor project, Regulation 15(5) imposes the equivalent duty on the contractor. This is why the common assumption that a Construction Phase Plan is needed only on large or multi-contractor projects is wrong.
The Health and Safety Executive's CDM guidance states directly that a sole contractor or Principal Contractor must draw up a Construction Phase Plan, while the effort involved should remain proportionate to the size and scale of the job. This requirement is also separate from F10 notification. A project is normally notifiable to HSE only where construction work is scheduled to last more than 30 working days with more than 20 workers working simultaneously at any point, or exceeds 500 person-days. A project below those thresholds can still require a Construction Phase Plan. LCM's guide to when CDM 2015 applies to construction work explains that distinction in more detail.
Who prepares the Construction Phase Plan?
| Project arrangement | Who prepares the CPP? | Client responsibility |
|---|---|---|
| One contractor | The contractor | Client must ensure a suitable plan exists before construction begins |
| More than one contractor | The Principal Contractor | Client must ensure the Principal Contractor prepares the plan |
| Domestic project | Contractor or Principal Contractor, depending on contractor numbers | Domestic client duties normally transfer under CDM 2015 |
The client does not normally write the plan. Regulation 4 requires the client to ensure that a Construction Phase Plan has been drawn up before the construction phase starts. The responsibility for actually planning and controlling construction work sits with the contractor or Principal Contractor.
The Principal Designer also has an important but different role. On a multi-contractor project, Regulation 12 requires the Principal Designer to assist the Principal Contractor by providing relevant information, including pre-construction information and information received from designers. That does not transfer ownership of the Construction Phase Plan to the Principal Designer. This distinction fits the wider division of responsibilities explained in LCM's guide to Principal Contractor duties under CDM 2015: the Principal Designer coordinates health and safety during pre-construction, while the Principal Contractor leads the construction phase.
What must a Construction Phase Plan include?
The legal minimum is more concise than many templates suggest. Regulation 12(2) requires the plan to set out the project's health and safety arrangements and site rules. Where relevant, it must also include specific measures for work falling within the particular-risk categories in Schedule 3. HSE's L153 guidance on CDM 2015 then identifies subjects that should be considered when developing a suitable plan. These include the project description, key members of the team, management arrangements, cooperation between contractors, worker consultation, site induction, welfare, site rules, fire arrangements and emergency procedures.
| CPP area | What should be addressed |
|---|---|
| Health and safety arrangements | How construction will be planned, managed, monitored and coordinated |
| Site rules | Access, PPE, restricted areas, hot works, traffic, housekeeping and other rules relevant to the site |
| Project management | Key roles, communication, coordination, supervision and worker consultation |
| Site arrangements | Induction, welfare, security, emergency arrangements and fire precautions |
| Project-specific risks | Controls for relevant work such as demolition, temporary works, excavation, lifting, work at height, asbestos, services or traffic interfaces |
| Schedule 3 work | Specific measures where work involves one or more of the particular risks listed in Schedule 3 |
LCM clarification: not every heading above must become a lengthy section on every project. A Construction Phase Plan for minor low-risk works should not contain pages about explosives, diving, major excavations or tower cranes if none of those activities exists. The legal test is whether the plan is adequate for the actual project.
A good Construction Phase Plan should be proportionate
HSE's L153 guidance says the plan should be relevant to the project, contain enough detail to make the management arrangements clear and remain proportionate to the scale, complexity and risks involved. It should also be easy to understand. That is an important practical point. A plan is not improved simply by becoming longer. HSE guidance specifically warns against filling the Construction Phase Plan with material that obscures the arrangements needed to manage construction, including generic risk assessments and detailed method statements.
For small projects, HSE publishes its CIS80 Construction Phase Plan guidance and template. It is aimed at builders and trades carrying out work such as kitchens, bathrooms, roof works, structural alterations, extensions and loft conversions, demonstrating that a proportionate plan can be simple while still meeting CDM requirements.
Does a one-day job need a Construction Phase Plan?
Yes, where the activity is construction work under CDM 2015. There is no exemption simply because the job lasts one day. The definition of construction work includes building, alteration, fitting out, renovation, repair, upkeep, redecoration, maintenance, demolition and the installation or maintenance of fixed building services. The difference is the amount of planning required. A small maintenance task carried out by one contractor may justify a very short plan. A roof replacement, structural opening or demolition project may be physically small but still need detailed controls because the risks are greater.
RAMS do not replace the Construction Phase Plan
A Construction Phase Plan and RAMS serve different purposes. The CPP sets out how health and safety will be managed across the construction phase. Risk assessments and method statements normally address particular hazards, activities or sequences of work.
A Principal Contractor may therefore have detailed RAMS for scaffolding, lifting, demolition, drilling or temporary works, but collecting those documents into a folder does not by itself create the site-wide management arrangements required by Regulation 12. The plan must explain how those activities are coordinated and controlled together.
The same distinction applies to Pre-Construction Information and the Health and Safety File. PCI provides information that designers and contractors need before and during planning. The Construction Phase Plan explains how construction will be managed. The Health and Safety File contains information likely to be needed for health and safety during future work on the completed structure. LCM's earlier technical guide to Construction Phase Plan content examines these document interfaces in more detail.
The plan must change when the project changes
A Construction Phase Plan is not a document that is approved at mobilisation and then left unchanged. Regulation 12(4) requires the Principal Contractor to review, update and revise the plan throughout the project so that it remains sufficient to manage construction without risks to health or safety so far as reasonably practicable. That review becomes particularly important when the design changes, new contractors arrive, sequencing changes, temporary works are introduced or altered, demolition methodology changes, site logistics are revised, previously unknown asbestos or services are identified, or work creates new interfaces with occupants or the public. The practical next step before any construction phase begins is therefore not simply to obtain a template. The client should confirm who is controlling the construction phase, the contractor or Principal Contractor should prepare a project-specific plan using the available pre-construction information, and the arrangements should be reviewed whenever the work or risks materially change.
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Expert Verification & Authorship: Mihai Chelmus Founder & Editor, London Construction Magazine | Construction Testing & Investigation Specialist |