What records must a principal contractor keep under CDM 2015?

CDM 2015 requires principal contractors to maintain: a Construction Phase Plan; records of site inductions for all workers; evidence of worker competence and qualifications (including CSCS card status); site attendance records showing who was on site and when; welfare facility records; risk assessments and method statements; and records of any accidents, near-misses or dangerous occurrences. The Health and Safety file must be compiled and handed to the client at project completion.

What is a Construction Phase Plan?

A Construction Phase Plan (CPP) is a document prepared by the principal contractor before construction begins. It must describe the project, identify significant site risks and how they will be managed, set out arrangements for managing CDM 2015 duties, and include welfare facility arrangements. The CPP is a live document that must be kept up to date throughout the project. It does not need to be submitted to the HSE but must be available on site for inspection.

CDM 2015 Guide for Contractors: Duties, Records and Compliance

Q: What are the main duties of a principal contractor under CDM 2015?

Under CDM 2015, the principal contractor must: plan, manage, monitor and coordinate the construction phase; prepare and maintain a Construction Phase Plan; organise cooperation between contractors; ensure suitable welfare facilities are provided; restrict site access to authorised persons; ensure all workers have site inductions; and compile information for the Health and Safety file. The PC is also responsible for ensuring that all contractors and workers on site have the required skills, knowledge, training and experience for their roles.

Q: When must you notify the HSE under CDM 2015?

An F10 notification must be submitted to the HSE before work starts on a construction project that will last longer than 30 working days with more than 20 workers simultaneously, or exceed 500 person-days of construction work. The notification is submitted online via the HSE website. The F10 must be displayed on site and updated if project details change materially.

Q: Does CDM 2015 apply to small projects?

CDM 2015 applies to all construction work in Great Britain, regardless of project size or duration. Even a small renovation project must comply with the basic duties. However, the requirements scale with project complexity. Projects below the notification threshold do not need a principal designer or principal contractor appointment, and the duty holder structure is simpler. All projects still require suitable risk management, worker competence, and safe working arrangements.

What CDM 2015 requires

CDM 2015 replaced CDM 2007 and applies to all construction work in Great Britain - commercial, residential, civil engineering, and demolition. Its core purpose is to integrate health and safety into the design and construction process, reducing the number of construction workers killed or seriously injured each year. The HSE enforces CDM 2015 and has powers to issue improvement notices, prohibition notices, and prosecute duty holders for non-compliance.

The regulations create a hierarchy of duty holders, each with defined responsibilities. The most significant change from CDM 2007 was replacing the CDM Coordinator role with the Principal Designer and clarifying the duties of the Principal Contractor on notifiable projects.

CDM 2015 duty holders explained

Every construction project has at least one client and at least one contractor. Larger projects require additional appointments:

Duty holder	When required	Core responsibility
Client	Every project	Appoint duty holders; ensure sufficient time and resources
Principal Designer	More than one contractor	Plan, manage, monitor and coordinate pre-construction phase
Principal Contractor	More than one contractor	Plan, manage, monitor and coordinate construction phase
Designer	Any design work	Eliminate or reduce foreseeable risks through design
Contractor	Every project	Plan, manage and monitor own work; ensure worker competence

Principal contractor duties

The principal contractor (PC) has the most extensive duties on a construction site. Under Regulation 13, the PC must:

Plan, manage, monitor and coordinate the construction phase in a way that ensures construction work is carried out without risks to health or safety
Prepare, and as necessary revise, a written Construction Phase Plan
Organise cooperation between contractors and coordinate their activities
Ensure that, before a worker begins construction work, the worker has been given a suitable site induction
Ensure suitable welfare facilities are provided from the start and maintained throughout
Take reasonable steps to prevent access by unauthorised persons
Liaise with the principal designer for the duration of the project

The PC is also responsible for ensuring that every contractor they engage has the skills, knowledge, experience and organisational capability to fulfil their duties. This includes checking that workers have the relevant qualifications, inductions, and CSCS cards for their roles.

F10 notification: when and how

A project is notifiable under CDM 2015 if the construction phase will last longer than 30 working days with more than 20 workers simultaneously, or if it will involve more than 500 person-days of construction work.

Notifiable projects require the client to submit an F10 notification to the HSE before the construction phase begins. The F10 is submitted via the HSE website and must include: project description, client and duty holder details, estimated start date, duration, and peak worker numbers.

The F10 notice must be displayed on site in a prominent position. If project details change materially - for example if the project is extended or the principal contractor changes - the F10 must be updated. CDM 2015 does not specify a deadline for updating but the HSE expects the notice to reflect current project reality.

Records you must keep on site

CDM 2015 does not provide an exhaustive list of records to be kept, but the HSE expects principal contractors to maintain records that demonstrate they are managing the site safely. In practice, an HSE inspector arriving unannounced will ask to see:

Construction Phase Plan - current version, specific to the project, not a generic template
Site attendance records - who was on site, when they arrived and left, for the entire project duration
Induction records - signed evidence that every worker received a site-specific induction before starting work
Worker competence records - CSCS cards, trade qualifications, and certifications relevant to the work being done
Risk assessments and method statements (RAMS) - for significant tasks, signed by workers before work starts
Welfare facility records - evidence that adequate facilities were in place from day one
Accident and near-miss records - RIDDOR-reportable events plus near-miss log
F10 notification - displayed on site for notifiable projects

HSE inspector tip: The most common failure point during an HSE inspection is attendance records. Paper sign-in books are frequently incomplete, illegible, or cannot prove that CSCS cards were valid at the time of entry. Digital attendance records that include timestamped CSCS verification are significantly more defensible.

Worker inductions under CDM 2015

CDM 2015 Regulation 13(4) places a clear duty on the principal contractor to ensure that every worker receives a suitable site induction before beginning work. "Suitable" means the induction must be specific to the site, cover the significant risks present, and be given before the worker is exposed to those risks.

A compliant site induction should cover: site layout and emergency evacuation routes; site rules and prohibited areas; significant hazards and control measures; first aid and accident reporting arrangements; welfare facilities; personal protective equipment requirements; and who to report concerns to.

Induction records must be retained. The HSE expects a record that shows: who received the induction, when, and who delivered it. For workers who return to site on a later date, the induction record remains valid unless site conditions have changed materially - in which case a refresher induction is required.

Worker competence and CSCS

CDM 2015 requires principal contractors to take reasonable steps to ensure that workers engaged on the project have the appropriate skills, knowledge and experience for the work they are doing. For most on-site trades, the Construction Skills Certification Scheme (CSCS) card is the primary evidence of competence.

While CSCS cards are not a legal requirement under CDM 2015 itself, the HSE's Approved Code of Practice (ACoP) L153 acknowledges CSCS as an appropriate method of verifying competence, and virtually all principal contractors require valid CSCS cards as a condition of site access.

The PC must verify cards - not just check that a worker has one. An expired CSCS card does not constitute evidence of competence. The CSCS Smart Check tool allows site managers to verify any CSCS-scheme card live against the CSCS database.

Supply chain responsibilities

The principal contractor is responsible for the health and safety of everyone on their site, including workers employed by subcontractors. This does not mean the PC takes on direct employer duties, but it does mean the PC must ensure that subcontractors are competent, have been given the necessary information, and are working in accordance with the Construction Phase Plan.

In practice this means: checking contractor competence before engagement; sharing the Construction Phase Plan and site rules; ensuring subcontractors brief their own workers on site-specific risks; and monitoring subcontractor compliance on an ongoing basis.

Pre-arrival compliance checks - verifying that a supply chain company's workers have valid CSCS cards, current inductions, and required competencies before they arrive on site - significantly reduce the risk of an unqualified worker accessing the site.

What an HSE inspector will ask for

HSE inspectors carry out both planned inspections of notifiable projects and unannounced visits following complaints, incidents, or as part of sector-wide enforcement initiatives. An inspector arriving on site will typically:

Ask to see the F10 notification (if the project is notifiable)
Ask to see the current Construction Phase Plan
Walk the site and observe working conditions, PPE, and welfare facilities
Ask to see induction records for workers currently on site
Ask for CSCS card evidence for workers in relevant trades
Ask about risk assessments and method statements for significant tasks
Review the accident and near-miss log

Inspectors have powers to issue improvement notices requiring specific corrective actions within a deadline, prohibition notices stopping work immediately where there is risk of serious personal injury, and to initiate prosecution. The average fine for a construction safety conviction in 2023 was £107,000.

The best defence against enforcement action is a site where records are comprehensive, accessible, and up to date - and where the site manager can produce any required document in minutes, not hours.

Frequently asked questions

What are the main duties of a principal contractor under CDM 2015?

The PC must plan, manage, monitor and coordinate the construction phase; prepare and maintain a Construction Phase Plan; ensure all workers receive site inductions before starting work; verify worker competence; provide welfare facilities; restrict site access; and compile the Health and Safety file for handover to the client.

When must you notify the HSE under CDM 2015?

An F10 notification is required before work starts on any project that will last more than 30 working days with more than 20 simultaneous workers, or that will involve more than 500 person-days of construction work. The F10 is submitted online via the HSE website and must be displayed on site.

Does CDM 2015 apply to small projects?

Yes. CDM 2015 applies to all construction work regardless of size. Basic duties - risk management, worker competence, welfare - apply to every project. The requirement for a principal contractor and principal designer appointment only applies when more than one contractor is engaged. F10 notification only applies above the notification thresholds.

What records must I keep under CDM 2015?

The Construction Phase Plan, site attendance records, worker induction records, competency evidence (including CSCS), risk assessments and method statements, welfare facility records, and accident and near-miss logs. The Health and Safety file must be completed and handed to the client at project end.

How long must CDM 2015 records be kept?

CDM 2015 does not specify retention periods for most records, but the Health and Safety at Work Act 1974 requires records relating to health and safety matters to be kept for at least three years. Accident records must be kept for three years under RIDDOR. Health records for workers exposed to hazardous substances under COSHH must be kept for 40 years. Best practice is to retain all project records for at least six years to align with the Limitation Act 1980.

CDM 2015: a practical guide for principal contractors and subcontractors