How to Prepare a Construction Phase Plan

Before drafting the CPP, obtain and read the pre-construction information (PCI) provided by the client (CDM 2015 reg 4(4)). The PCI is the client's compilation of information about the site and project that could affect health and safety during construction. It typically includes: existing services, known ground conditions and contamination, asbestos surveys and registers, the design risk register, and any site-specific rules or restrictions.

The PCI is the foundation of your CPP. Any site-specific risks identified in the PCI must be reflected in the CPP's risk controls. If the PCI is incomplete or unclear, raise this with the client and the principal designer before construction starts — you cannot plan effectively for risks you have not been told about.

The CPP must be in place before construction work begins (CDM 2015 reg 12(1)). At this stage, the plan needs to address the Schedule 3 matters at a level appropriate to what is known at project start. This includes: a clear description of the project and the construction phase; the management structure (who is the principal contractor, who are the site managers and supervisors, what is the chain of command for safety decisions); site rules (hours of work, vehicle and pedestrian segregation, PPE requirements, restricted areas); emergency arrangements (assembly point, nearest hospital with A&E, emergency contact numbers, fire warden arrangements); welfare facilities arrangements; and a summary of the known significant risks and how they will be controlled.

A common error is to create a detailed CPP for all phases of the project at the outset. This is unnecessary and often counterproductive — it fills the document with speculative content that becomes inaccurate as the project evolves. Start with what you know; develop the plan as you proceed.

CDM 2015 Schedule 3 lists the matters the plan must address. Work through each one explicitly: the project description (scope, programme, and key milestones); management arrangements including induction procedure, site rules, and communication arrangements; the arrangements for managing specific site risks (working at height, excavations, hazardous substances, services, temporary structures, fire, and plant management); welfare facility arrangements; and the arrangements for coordinating subcontractors.

For each significant risk, the plan should cross-reference the method statements and risk assessments that address it. The CPP does not need to contain all risk assessments in full — it should reference them and confirm they exist. However, it must demonstrate that each significant risk has been addressed by specific controls, not just acknowledged.

The CPP must be communicated to all those who need it. CDM 2015 reg 12(7) requires the principal contractor to ensure every worker receives suitable induction before starting work on site. The induction must cover the key elements of the CPP: site rules, emergency procedures, welfare locations, known significant risks, and reporting arrangements.

For subcontractors, the principal contractor must communicate the site rules and any relevant CPP provisions before the subcontractor starts work on site. The subcontractor's own method statements and risk assessments must align with the CPP. Where they do not, the principal contractor must resolve the inconsistency before work starts.

The CPP must be kept up to date as the project progresses (CDM 2015 reg 12(3)). This means reviewing and updating the plan when: new subcontractors come on site; the scope or programme changes; a new significant risk emerges; an incident or near miss occurs; a specific risk phase (e.g. structural steelwork, deep excavations, asbestos removal) begins; or the emergency arrangements change.

Date-stamp every review and update. Keep a version history so that earlier versions can be retrieved if needed. The HSE or a court may want to see the plan as it existed at the time of an incident — having a clear version history demonstrates active management rather than a plan that was written at the start and forgotten.

The CPP is not the same as the health and safety file (HSF), but it contributes to it. The HSF is the document handed to the client at project completion, containing the information needed for future construction, maintenance or demolition work on the structure. The principal contractor contributes information to the HSF throughout the project, and the CPP may provide a useful source for the management and emergency arrangements sections.

Ensure the HSF is compiled and handed to the client before the construction phase is formally closed. The client has duties under CDM 2015 reg 4(5) to make the HSF available for any future project involving the structure.