Pre-Construction Information Under CDM: What Clients Must Provide

Pre-Construction Information, usually shortened to PCI, is the health and safety information a client already holds or can reasonably obtain that designers and contractors need to plan construction work safely. Under CDM 2015, commercial clients must provide it as soon as practicable to every designer and contractor appointed to the project or being considered for appointment.

PCI is not simply a standard form or a folder issued immediately before site mobilisation. It should develop as design progresses, be proportionate to the project and reach designers and tendering contractors early enough for the information to affect design decisions, pricing, sequencing and construction planning.

Construction works with structural framing and temporary access systems in the City of London. Photograph: London Construction Magazine

What is Pre-Construction Information under CDM 2015?

The legal definition appears in Regulation 2 of the Construction (Design and Management) Regulations 2015. PCI is information in the client's possession, or reasonably obtainable by or on behalf of the client, which is relevant to the construction work, contains an appropriate level of detail and is proportionate to the risks involved.

That definition covers information about the project, its planning and management, health and safety hazards, design and construction risks and relevant information contained in an existing Health and Safety File. CDM 2015 applies to construction work across Great Britain, including projects well below the F10 notification threshold. LCM's guide to when CDM Regulations apply to construction work explains that wider distinction.

When must the client provide PCI?

Regulation 4(4) of CDM 2015 requires a client to provide Pre-Construction Information as soon as practicable to every designer and contractor already appointed or being considered for appointment. In practice, that means relevant information cannot routinely be held back until the Principal Contractor has been selected. HSE's L153 guidance says organisations bidding for work should receive enough information in good time to understand the nature of the work and prepare their bids. Designers need it early enough to eliminate foreseeable risks where reasonably practicable and reduce or control those that remain.

Not all PCI has to exist on day one. HSE's L153 guidance says the information should be gathered and added to as the design progresses. If new surveys, investigations or design information become available later, relevant information should be issued when it becomes available rather than waiting for one final PCI pack.

What should Pre-Construction Information include?

There is no universal document list for every project. The information should match the work and the risks. HSE identifies four broad areas: information about the project, project planning and management, site and construction hazards, and relevant information from any existing Health and Safety File.

PCI area Typical relevant information
Project and programme Client brief, scope, key dates, phasing, access restrictions and significant interfaces
Existing structure Relevant drawings, structural form, previous alterations, known defects, load information and existing temporary support
Hazardous materials Relevant asbestos information, contamination, hazardous substances and previous surveys
Services Known electrical, gas, water, drainage, telecoms and other above-ground or buried services
Site interfaces Occupied areas, neighbours, public routes, traffic, deliveries, restricted access and existing fire arrangements
Existing records Previous Health and Safety Files, surveys, investigations and other relevant asset information

LCM clarification: PCI should not become an uncontrolled document dump. Sending several hundred drawings, an old Health and Safety File and a generic hazard register does not necessarily give a contractor useful Pre-Construction Information. The relevant risks and constraints still need to be identifiable, current and understandable.

What if important information is missing?

This is one of the most important parts of the PCI duty. The legal definition includes information that is reasonably obtainable, not only information already sitting in the client's records. HSE guidance says the client and Principal Designer should assess the adequacy of existing information, identify significant gaps and take reasonable steps to obtain information needed to fill them. HSE specifically gives commissioning relevant surveys as an example. That does not mean CDM 2015 creates a fixed shopping list requiring every project to commission asbestos, structural, utility, ground, drainage and intrusive surveys. The test is whether the missing information is relevant to the project, proportionate to the risk and reasonably obtainable.

Refurbishment and asbestos

Where intrusive work may disturb asbestos-containing materials, separate asbestos legislation becomes important. HSE guidance on refurbishment and demolition asbestos surveys explains that these surveys are intended to locate material hidden within the building fabric before structural work begins. An old management survey may therefore be insufficient for the proposed intrusive scope.

Structural alterations and demolition

Unknown structure is another example where the information gap can directly affect safe design and sequencing. HSE guidance on structural stability during alteration and demolition says a competent person should carry out a full survey and assessment before potentially load-bearing parts are altered. Relevant information can include structural form, condition, previous alterations and nearby structures.

Excavation and buried services

For excavation work, HSE states that the client, assisted by the Principal Designer where one exists, should provide relevant Pre-Construction Information about underground services. Plans are only part of that process. HSE guidance also calls for locating devices and safe excavation practices where buried services may be present. These examples show why “information unavailable” should not automatically close the issue. Where an unknown could affect structural stability, live services, hazardous materials or another foreseeable serious risk, the project team should establish what can reasonably be found before design or construction proceeds.

Who is responsible for preparing PCI?

For a commercial project, the client has the main legal duty to provide Pre-Construction Information. On a project involving more than one contractor, the Principal Designer must help the client bring it together and make it available to designers and contractors. The Principal Designer should assess existing information, identify significant gaps, advise how those gaps can be filled and help obtain and organise the information. That role fits within the wider pre-construction duties described in LCM's guide to Principal Designer duties under CDM 2015. A consultant can assemble or administer the PCI pack, but appointing an adviser does not remove the commercial client's own duty under Regulation 4. For a single-contractor project there may be no Principal Designer, so the client must work directly with its designer and contractor to provide the information required.

What happens on domestic projects?

Domestic projects remain within CDM 2015, but the client duties normally transfer. HSE guidance says they pass to the contractor where there is one contractor, or to the Principal Contractor where more than one contractor is involved. A domestic client can instead agree in writing for the Principal Designer to carry out the client duties on a multi-contractor project. The amount of PCI should still be proportionate. A small household project may require only a concise set of relevant information, such as known services, asbestos information, structural details and access constraints. The regulations do not require a lengthy corporate-style PCI report simply because the work falls within CDM.

PCI is not the Construction Phase Plan or RAMS

Pre-Construction Information describes the existing project conditions, constraints and foreseeable health and safety information that designers and contractors need. The Construction Phase Plan has a different function: it sets out how the construction phase will be planned, managed, monitored and coordinated. RAMS are different again. Risk assessments and method statements normally deal with specific activities or work methods. An asbestos survey or structural survey is also not PCI by itself; it is a technical source that can form part of PCI where relevant.

The existing Health and Safety File can be a valuable source of PCI for later alteration, refurbishment or demolition work, but the two are not interchangeable. LCM's guide to Construction Phase Plans under CDM 2015 explains how PCI feeds into construction-phase planning and why a collection of RAMS does not replace the project-wide plan.

What good Pre-Construction Information looks like

Good PCI is specific enough for the recipient to act on it. It identifies what is known, what remains uncertain, what investigations have been undertaken and what information will follow later. Where an old drawing is known to be unreliable, the uncertainty should be stated rather than allowing the contractor to assume it is an accurate as-built record. It should also arrive early. Information about asbestos, unstable structures, buried services or occupation constraints has little value if it reaches the contractor after the work has already been priced and programmed on different assumptions. 

Before the next designer or contractor is appointed, the practical step for the client is to review what information already exists, identify significant gaps with the Principal Designer where one is appointed, commission proportionate investigation where necessary, and issue relevant information early enough for it to influence the design and tender. PCI should then continue to develop as new information becomes available.
Mihai Chelmus Expert Verification & Authorship: Mihai Chelmus
Founder & Editor, London Construction Magazine | Construction Testing & Investigation Specialist
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