CDM 2015 site records: what UK contractors must keep

Why site records matter

Construction is consistently the industry with the highest number of workplace deaths in Great Britain. In 2024/25, 35 construction workers were killed at work - that is 28% of all worker fatalities, from an industry that employs just 6% of the workforce. Source: HSE Construction Statistics 2025.

HSE enforcement reflects this risk. In 2024/25, HSE achieved a 96% conviction rate and collected £33 million in fines. Construction is one of the most frequently inspected sectors. When an inspector arrives on your site, the first thing they ask for is your records. If you cannot produce them, the outcome is rarely good.

CDM 2015 records are not bureaucracy for its own sake. They are evidence that you planned the work safely, briefed the workers, and managed the risks. An incomplete or missing record suggests the opposite.

The Construction Phase Plan

The Construction Phase Plan (CPP) is the central CDM document. It must be prepared before work starts on site and updated as the project develops. This requirement applies to every construction project - not just notifiable ones. This changed from the previous CDM 2007 regulations, where a CPP was only required on notifiable projects.

The CPP records the health and safety arrangements for the project. It sets out:

• A description of the project and the key contractors involved
• Site management arrangements and lines of responsibility
• Emergency procedures - where workers muster, who calls the emergency services, first aid provision
• Site rules - PPE requirements, vehicle management, visitor procedures
• Arrangements for monitoring and reviewing health and safety
• How hazardous work will be managed (working at height, confined spaces, excavation)

The CPP is a live document. It should be updated when new contractors arrive, when the scope of work changes, or when a new hazard is identified. An inspector who finds a CPP that has not been updated since the project started will question whether it is being used at all.

Site induction records

Under CDM 2015 Regulation 15(7), the principal contractor must ensure that every person who works on the site receives a suitable site-specific induction before they begin work. This applies to directly employed workers, subcontractors, agency workers, and visitors who will be working on site.

For each induction, you must record:

• The worker's full name
• Their employer
• The date the induction was given
• The content covered in the induction
• Confirmation that the worker received and understood the induction (signature or equivalent acknowledgement)

The induction content should be site-specific. It is not sufficient to give every worker an identical generic briefing. Workers carrying out high-risk activities (hot works, confined space entry, working at height) need an induction that addresses those specific risks.

Return-to-site workers need a new induction if they have been absent for a significant period, or if the site conditions have changed materially since their last visit. Keeping a record of when each worker was last inducted makes this easy to manage.

On busy sites with subcontractor workers coming and going, induction records are often the most disorganised part of the site file. A digital system that records inductions automatically and allows you to export a list of all inducted workers - and when - makes this straightforward. AttendIQ handles digital site inductions with automatic records and a live list of who is currently inducted on each site.

Risk assessments and method statements

CDM 2015 does not require RAMS in so many words, but the Management of Health and Safety at Work Regulations 1999 requires employers to conduct suitable risk assessments for all significant work activities. On a construction site, this means RAMS for every trade and task where there is a meaningful risk.

The principal contractor's responsibility is to:

• Ensure that every contractor working on the site has provided RAMS before starting work
• Review those RAMS and confirm they are suitable and sufficient
• Brief workers on the content of the RAMS relevant to their work
• Keep a record that the briefing took place and who attended
• Maintain a current and superseded version control system

RAMS records without evidence of briefing are a common weakness. Having a document does not demonstrate that workers knew about it. The record of the briefing - who attended, when, and what was covered - is often what separates a well-prepared site file from one that attracts improvement notices.

F10 notification

An F10 notification must be submitted to HSE before work starts on any notifiable project. A project is notifiable when:

• The construction phase will last longer than 30 working days, with more than 20 workers working simultaneously at any point, or
• The project will exceed 500 person-days of work

The principal contractor is responsible for ensuring the F10 is submitted. It is submitted online through the HSE website. The completed F10 confirmation must be displayed on site where it can be seen by workers.

Keep a copy of the submitted F10 in the site file. This is one of the first documents an HSE inspector will check on a notifiable project.

Permits to work

A permit to work is a formal document authorising specific high-risk activities on site. It is not a legal requirement under CDM 2015 in all cases, but for certain activities it is a recognised control measure and should be used. Activities that commonly require a permit to work include:

• Hot works (welding, grinding, cutting - any activity producing heat or sparks)
• Confined space entry
• Working at height on fragile surfaces or near unprotected edges
• Excavation near buried services
• Electrical isolation and work on live systems

For each permit issued, you need a record of: who authorised it, who carried out the work, the exact work permitted, the start and end time, the controls in place, and that the permit was formally closed once the work was complete.

Unsigned or unclosed permits are a significant audit weakness. An open hot works permit at 5pm that was not formally closed is difficult to explain if a fire occurs overnight.

Incident and near miss records

Every injury on a construction site must be recorded. Injuries that result in more than seven consecutive days off work, fractures (other than fingers, thumbs, and toes), amputations, serious eye injuries, and specific other injuries are reportable to HSE under RIDDOR (Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013) within 15 days.

Your incident log should record: the date and time, location on site, who was injured, what happened, the nature of the injury, any immediate action taken, and any follow-up investigation or corrective action.

Near miss records are equally important. A near miss is an event that could have caused injury but did not. Recording near misses demonstrates that you have a proactive safety culture - and they are often early warning signs of the conditions that lead to accidents. An HSE inspector who sees a well-maintained near miss log is looking at a site that takes safety seriously.

Workforce competency records

CDM 2015 requires the principal contractor to ensure that all workers have the skills, knowledge, training, and experience necessary to carry out their work safely. In practice, this means keeping records that demonstrate competency for the work being done.

For most construction workers, this centres on:

• CSCS cards - the industry-standard qualification scheme. The principal contractor should verify that every worker on site holds a current, valid CSCS card appropriate to their trade and level. An expired card is not a valid card. See our guide to CSCS card types for a full breakdown of which card covers which trade.
• Specific equipment training - IPAF cards for MEWPs, CPCS or NPORS cards for plant operators, scaffold inspection certification for scaffolders
• Health surveillance records - where workers are exposed to vibration, noise, or hazardous substances, relevant monitoring and assessment records
• Right to work checks - evidence that every worker is entitled to work in the UK. See our guide to right to work checks in construction

Maintaining these records for every worker across multiple subcontractors, on a busy site with workers coming and going daily, is one of the most operationally demanding parts of running a compliant site. It is also one of the most common failure points identified in HSE inspections.

How long to keep records after the project ends

CDM 2015 does not set a single retention period that covers all records. In practice, the following is commonly applied guidance:

• General site records (CPP, inductions, RAMS, permits, incidents) - minimum 3 years after project completion
• Health and Safety File - passed to the client on project completion and retained for the life of the building
• Records involving exposure to hazardous substances (asbestos, silica, noise, vibration) - 40 years
• RIDDOR reports - minimum 3 years
• Right to work records - duration of employment plus 2 years

If in any doubt, keep records longer rather than shorter. The cost of storage is negligible. The cost of not having a record when it is needed is not.

What an HSE inspector will ask for

When an HSE inspector arrives on your site - whether for a planned visit, in response to a reported incident, or because something they have observed from the road concerns them - they typically ask for the following, in this order:

1. The Construction Phase Plan
2. The F10 notification confirmation (if the project is notifiable)
3. Evidence that every person on site has been inducted
4. Current RAMS for the activities in progress
5. Evidence that workers were briefed on those RAMS
6. Any active permit to work records
7. An incident and near miss log
8. CSCS card details for workers on site

They expect these to be produced immediately. Not emailed over later. Not found in a lever arch file in the welfare cabin. Immediately.

If you manage multiple sites, the ability to pull a complete compliance export for any site from a phone is not a luxury. It is the practical reality of what an inspection looks like. AttendIQ produces a full compliance export - all clock-in records, inductions, CSCS verification, and permits - in under a minute, from any device.