Every construction project needs a construction phase plan before the construction phase begins. Not every project needs to be notified to HSE. Those two facts are separate, and confusing them is the most common CDM mistake on small jobs: a two-week refurbishment with three trades needs a plan and does not need an F10.
Who writes it and when
Where there is more than one contractor, the principal contractor draws it up under regulation 12(5) before the construction phase begins. Where there is only one contractor, that contractor draws it up. In both cases it has to exist before work starts, not be assembled afterwards for a file.
The main headings of a construction phase plan
A workable plan covers the project description and programme, the management structure with names and responsibilities, the arrangements for communication and coordination between duty holders, the arrangements for consulting workers, the site rules, the site induction, welfare and emergency arrangements including fire and first aid, and the arrangements for controlling the significant site risks. The last of those is the substance and the rest is scaffolding around it.
Proportionality is the test, not length
A plan for a domestic loft conversion should be a few pages that a working foreman can act on. A plan for a hospital refurbishment cannot be. HSE has been explicit that a plan padded with generic material is worse than a short one, because the significant risks get lost in it and nobody on site reads any of it.
The F10 form: notifying HSE
F10 is the client's notice to HSE that a project is notifiable, submitted as soon as practicable before the construction phase begins. Under regulation 6 a project is notifiable if it is scheduled to last longer than 30 working days and have more than 20 workers working simultaneously at any point, or to exceed 500 person days. The notice has to be displayed in the site office where workers can read it.
Risk assessment in construction, and the three documents it sits between
On site the assessment does not stand alone. Above it is the pre construction information, which tells the contractor what the client knows: the asbestos register, the existing services, the structure, the neighbours. Beside it is the method statement, which is the sequence of work the assessment's controls are built into, and the two together are what everybody calls the RAMS. Below it is the point of work check, the short card the person doing the task fills in when the site does not match the plan. A construction phase plan that contains assessments and no sequence has the middle document missing.
A painting risk assessment on a live site, and the four things it names
Solvents and the coating's own data sheet, because the substances are the whole COSHH half of the job: vapour in an enclosed room, ventilation, gloves, and whether spraying turns it into a different exercise entirely. Access, because most painting injuries are falls rather than poisonings, so the ladder or tower decision is in here. Other trades, since a sprayed finish and a grinder in the same space is an ignition question. And the public or the occupants where the work is in an occupied building, which is signage, wet floors and overnight drying. A generic painting assessment misses all four because it was written for nobody's site.
Questions people ask about construction phase plan
Does every project need a construction phase plan?
Yes. Every construction project needs one before the construction phase begins, whatever its size and whether or not it is notifiable.
Who submits the F10?
The client, under regulation 6(2). On a domestic project that duty normally passes to the contractor or principal contractor.
What is the difference between the plan and the health and safety file?
The plan governs how the construction phase will be run. The file is the record handed to the client at the end, carrying the information anyone doing future work on the structure will need.
How long does the plan have to be?
As long as the risks require and no longer. HSE's own guidance warns against generic padding, because it buries the significant risks the plan exists to control.
What should a construction phase plan checklist cover?
The plan's own required contents rather than a generic list: the description of the project and the key dates, the management arrangements including who does what and how they are told, the arrangements for controlling the significant risks of this job, and the site rules including the welfare arrangements. A checklist is useful for the second half, which is the significant risks: the existing services, the asbestos register, the traffic and pedestrian separation, the work at height, the excavations, the lifting operations, the temporary works, and the neighbours. What no checklist can supply is the sequence, which is the part that makes a plan a plan rather than a folder.
How does the construction phase plan CDM asks for differ from a risk assessment?
The plan is the management document and the assessments are inputs to it. The regulations require the principal contractor to draw up a plan before the construction phase begins, and what it has to contain is the health and safety arrangements for the project: the description and key dates, who holds which role, how information flows, the site rules, the welfare arrangements, and the arrangements for controlling the significant risks of this particular job. A folder of generic assessments is not a plan, and a plan that reads the same as the last one is evidence nobody planned this job.