Walk into most site cabins and you'll find it on the shelf: a lever-arch file labelled Construction Phase Plan, signed off in week one and left alone ever since. The trouble usually starts around week six, when the roofer's insurance lapses and that file still says everyone on site is covered.
What is a construction phase plan?
A construction phase plan, or CPP, sets out how health and safety will be managed while a project is being built. Under the Construction (Design and Management) Regulations 2015, every construction project in Great Britain needs one before work starts on site, whatever its size.
You'll also see it called a construction phase health and safety plan, or CPHSP. It's the same document under a longer name.
CDM asks for three things in it: the health and safety arrangements, the site rules, and specific measures for any Schedule 3 work, which is the high-risk list covering falls from height, deep excavations and work near high-voltage lines. Everything else depends on the job in front of you, so a plan that covers those three properly can be a lot shorter than people expect.
Who is responsible for the construction phase plan?
The principal contractor writes it. Regulation 12 of CDM 2015 puts the duty on them, and paying someone else to draft it doesn't move that duty anywhere.
Other duty holders feed in along the way. The client has to make sure a plan exists before the construction phase starts, and the principal designer hands over pre-construction information about the site, its hazards and the design.
Two situations change who holds the pen. On a job with a single contractor there's no principal contractor, so that contractor takes it on. On a domestic job, the homeowner's client duties pass to the contractor, so the homeowner never touches it.
Plenty of contractors get a consultant to draft theirs, and that's fine. You still pick the subbies and decide who gets through the gate, though, so the plan is yours whoever typed it.
When is a construction phase plan required?
Every project needs one, and it has to be in place before the construction phase starts.
People sometimes mix this up with notification, which is a separate duty. A project has to be notified to HSE on form F10 if it'll last more than 30 working days with more than 20 workers on site at once, or if it'll run past 500 person days. Notifiable or not, the plan is still required. A fortnight's kitchen refit needs one as much as a 200-unit housing scheme does, although the kitchen's should fit on a few sides of A4.
The plan also has to keep up with the job. Regulation 12 requires the principal contractor to review, update and revise it as work moves on, so a new phase or a new subbie on site means another look at the plan.
What should a construction phase plan include?
A good plan covers the risks on your site and leaves out anything that's only there to look thorough. The detail varies from job to job, but plans that work on site tend to follow the same set of headings.
Construction phase plan example
Take a single-storey rear extension: ten weeks on site, one principal contractor and four subcontractors covering groundworks, brickwork, roofing and electrics. Its plan would cover the following.
Contents
- 01
Project description
- 02
Who runs the site
- 03
Subcontractor appointments and competence
- 04
Site induction
- 05
Communication
- 06
Site rules
- 07
Welfare
- 08
First aid, emergencies and fire
- 09
Significant risks, limited to the ones on this job
- 10
Schedule 3 work
- 11
Health and safety file
- 12
Review
That comes to a handful of pages. If yours runs to 40, it's worth asking what the other 35 are doing.
Why construction phase plans fail on site
They're templates with the name changed
You can usually spot one from the contents page. There's a section on tunnelling in the plan for a loft conversion, diving operations for a bungalow, and a line promising "all operatives will hold appropriate qualifications" with nothing about who checks or when.
A promise with no check behind it doesn't control anything. HSE wants the plan proportionate and specific to the project, which means a short plan that matches the site is worth more than a long one that never leaves the shelf.
They're written for the file
The plan gets signed before start and goes on the shelf. By week three the roofing firm has changed, a crane has arrived and the scaffold has been altered, yet the plan still describes week one. CDM treats it as a live document, but on most sites it was a box ticked at the pre-start meeting.
Subcontractor competence gets taken on trust
This is the one that matters most, because almost every promise in the plan is kept or broken by a subcontractor. Their operatives are the ones up the scaffold, their RAMS control the risk, and their insurance pays out when something goes wrong.
Regulation 8 of CDM 2015 says anyone appointing a contractor has to take reasonable steps to check that contractor has the skills, knowledge, experience and organisational capability for the work. Signing the plan says you've done that.
On a typical job, though, the checking looks like this. Insurance certificates arrive by email on day one and get saved to a folder. CSCS cards get a glance at the gate, if that, and RAMS come in as attachments that stay closed. Then the job overruns, a policy expires in week six, and an agency labourer turns up without a card. The plan still says everyone's competent and insured, and the folder can't prove it.
What a good construction phase plan looks like
The best plans are short, specific to the site and kept current. Two tests will tell you where yours stands.
First, could a new subbie read the sections that apply to them in ten minutes and know what you expect? Second, could you show today, without ringing anyone, that every firm on site is insured, carded and competent for what they're doing this afternoon?
If the first one fails, cut the plan down. If the second one fails, the work is in the evidence behind the plan.
The part your plan can't do on its own
A construction phase plan says what should be true on site, but it can't tell you whether it is. That's the job we built SubbyFlow for. Every subcontractor's insurance, CSCS cards and prequalification sit in one place, and you get flagged ahead of any expiry, while there's still time to chase it. [Link: see how SubbyFlow tracks subcontractor insurance and CSCS]
The lever-arch file can stay on the shelf. It won't be the only proof you've got any more.
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Construction phase plan FAQs
Is a construction phase plan a legal requirement?
Yes. Regulation 12 of CDM 2015 requires one for every construction project in Great Britain, in place before the construction phase starts. Northern Ireland has its own version of the regulations.
Who writes the construction phase plan on a domestic project?
The contractor, or the principal contractor if there's more than one contractor on the job. The homeowner's client duties pass to them automatically.
What is a pre-construction phase plan?
There's no document by that name in CDM 2015. People searching for it are usually after pre-construction information, which is what the client provides, with help from the principal designer, about the site, existing structures and known hazards. That information then feeds the construction phase plan.
How often should a construction phase plan be reviewed?
CDM sets no fixed interval. Review it whenever something material changes, such as a new phase, a new subbie, a change of method or an incident. On a busy site that can mean weekly.
What's the difference between a construction phase plan and RAMS?
RAMS cover one task and come from the subcontractor doing it. The construction phase plan covers the whole project and comes from the principal contractor, and a good one references the RAMS for each trade.
Is there a free construction phase plan template?
Yes. HSE publishes a short template aimed at small projects. It works well as a list of headings, but a plan that reads like everyone else's won't reflect your site.