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Principal contractor duties under CDM 2015 and the records they need
If you run the site, the CDM regulations put the duty to coordinate health and safety on you. Here is what that covers, and the records that show you did it.
Who is the principal contractor
Under the Construction (Design and Management) Regulations 2015, the client must appoint a principal contractor and a principal designer on any project with more than one contractor. The principal contractor is usually the main or managing contractor. If you are the only contractor on a project, you take on the principal contractor duties yourself.
If the client is a domestic client, such as a homeowner, the client duties normally pass to the contractor, or to the principal contractor where there is one. Do not assume the client will deal with it.
What the principal contractor must do
In short, you plan, manage and monitor the construction phase and coordinate health and safety for everyone working on the project. In practice, that means:
- Prepare the construction phase plan before the construction phase starts, and keep it up to date as the work changes.
- Organise cooperation and coordination between all the contractors on site.
- Provide a suitable site induction for everyone who works on the site.
- Prevent unauthorised access, through fencing, signage and controlled entry.
- Provide welfare facilities from the start of the work and for the duration.
- Make sure workers are consulted on health and safety and are told what they need to know.
- Liaise with the client and principal designer and share information that affects their work.
- Make sure contractors are competent, have the right skills, knowledge and experience, and are given the information and time to plan.
- Check subcontractors' risk assessments and method statements and make sure they fit your plan.
- Provide information for the health and safety file that the principal designer is assembling for the client.
Notifying HSE
Larger projects must be notified to HSE using the F10 form. A project must be notified if the construction work is expected to last more than 30 working days and have more than 20 workers working at the same time at some point, or if it exceeds 500 person days. The client is responsible for notifying, but check that it has been done and display the notice on site.
The records that show you have done it
CDM does not give you a list of documents to hold, but when something goes wrong, you are asked to show that the duties were met. The records that do most of that work are:
| Duty | Record that evidences it |
|---|---|
| Plan and manage the construction phase | Construction phase plan, with revisions and the date of each |
| Coordinate contractors | Meeting minutes, programme, and a record of who was told what |
| Site induction | Induction record for each person: date, who delivered it and what it covered |
| Competence of contractors | Pre-start checks, cards and qualifications with expiry dates, insurance |
| Risk assessments and method statements | Approved versions, with sign-off by the people doing the work |
| Control of access | Site register for workers and visitors, with times in and out |
| Monitoring | Inspection records, toolbox talks, near misses and accidents |
| What happened each day | The site diary |
The principal contractor is the one asked first. After an accident or an inspection visit, inspectors look to the principal contractor for the site-wide picture. Subcontractors' paperwork matters, but if it is scattered across emails and vans, you cannot show it was checked.
Common failings
- A generic construction phase plan copied from a template and never updated.
- Subcontractor RAMS received but never reviewed, or reviewed but with no record that it was.
- Inductions given but not recorded, or recorded on sheets that cannot be found.
- Nobody checking competence beyond looking at a card on the way in.
- Records that do not match what is happening on site.
The free 3-minute assessment looks at three of these records, the diary, the register and inductions, and shows where yours would be hard to produce.
Keep the records that show you did it
SiteHub keeps your diary, site register, inductions, card expiry dates and RAMS sign-off in one place, and every site's records can be exported as PDFs. It does not write your construction phase plan for you, but it holds the day-to-day evidence that the plan was followed.
No card needed. £19 a month for your first site and £15 for each extra site after the trial.
This guide is a summary for contractors, not legal advice. The CDM regulations and HSE's guidance (L153) are the authority, and your duties depend on your role and project. Check them or take advice from a health and safety consultant.