CDM 2015 Compliance Checklist for Construction Projects

The Construction (Design and Management) Regulations 2015 apply to all construction work in Great Britain. There are no exemptions based on project size or value. Whether you are building a skyscraper or fitting a kitchen, CDM 2015 applies. The regulations establish a framework of duty holders with specific responsibilities aimed at ensuring that health and safety is considered from the earliest design stages through to completion and beyond. Non-compliance is a criminal offence that can result in unlimited fines and imprisonment. This checklist provides a practical, actionable summary of the key requirements for each duty holder, along with the documentation that demonstrates compliance.

Understanding CDM 2015

CDM 2015 replaced the previous CDM 2007 regulations with the aim of simplifying the regulatory framework while maintaining, and in some areas strengthening, the requirements for managing health and safety in construction. The key changes from 2007 include the replacement of the CDM coordinator role with the principal designer, the extension of the regulations to cover domestic clients, and simplified notification requirements.

The regulations identify five duty holder roles: client, principal designer, principal contractor, designer, and contractor. On projects with only one contractor, the principal designer and principal contractor roles are not required, but the remaining duties still apply. On projects with more than one contractor, which is the vast majority of commercial construction projects, all five duty holder roles must be appointed and their duties fulfilled.

Client Duties Checklist

The client is the person or organisation for whom the construction work is being carried out. Under CDM 2015, the client has significant duties that cannot be delegated, although they can appoint others to help discharge them.

• Appoint a principal designer in writing before the design work begins, ensuring they are competent and adequately resourced for the role
• Appoint a principal contractor in writing before the construction phase begins, ensuring they are competent and adequately resourced
• Ensure adequate time and resources are allocated for all stages of the project, including planning, design, and construction
• Provide pre-construction information to designers and contractors, including information about existing structures, hazardous materials, ground conditions, and any other relevant health and safety information
• Ensure a construction phase plan is prepared by the principal contractor before construction begins
• Ensure the health and safety file is prepared and updated throughout the project, and is available for inspection by anyone who needs it
• Notify the HSE via Form F10 if the project will last longer than 30 working days with more than 20 workers working simultaneously, or exceed 500 person-days of construction work
• Ensure adequate welfare facilities are provided from the start of the construction phase

Principal Designer Duties Checklist

The principal designer is responsible for planning, managing, monitoring, and coordinating health and safety during the pre-construction phase. They must be a designer and must have the skills, knowledge, experience, and organisational capability to carry out the role.

• Plan, manage, and coordinate health and safety during the pre-construction phase
• Identify, eliminate, or reduce health and safety risks through design decisions
• Ensure all designers comply with their duties under the regulations
• Prepare and provide relevant pre-construction information to designers and contractors
• Liaise with the principal contractor to coordinate design and construction activities
• Prepare the health and safety file and pass it to the client at the end of the project

Principal Contractor Duties Checklist

The principal contractor manages the construction phase and is responsible for coordinating health and safety on site. On most projects, this is the main contractor.

• Prepare the construction phase plan before the construction phase begins, and keep it updated throughout
• Organise cooperation between all contractors on site
• Coordinate the implementation of the relevant legal requirements for health and safety
• Ensure suitable site inductions are provided to every worker before they start on site
• Take steps to prevent unauthorised access to the construction site
• Ensure adequate welfare facilities are provided and maintained throughout the construction phase
• Consult and engage with workers on health and safety matters
• Display the Form F10 notification on site (if applicable)
• Liaise with the principal designer for the duration of their appointment
• Ensure the health and safety file is updated with information from the construction phase

Contractor Duties Checklist

Every contractor on the project, including subcontractors of any tier, has duties under CDM 2015.

• Plan, manage, and monitor their own work to ensure it is carried out safely
• Not start work until satisfied that a construction phase plan has been prepared and adequate welfare facilities are in place
• Provide information to the principal contractor for the health and safety file
• Comply with any directions given by the principal designer or principal contractor
• Provide supervision, instructions, and information to their workers
• Not employ or appoint anyone who does not have or is not in the process of obtaining the necessary skills, knowledge, training, and experience
• Report anything they are aware of that is likely to endanger health or safety

Documentation Checklist

CDM 2015 requires specific documentation to be produced, maintained, and retained. This checklist covers the key documents.

Pre-construction information pack. Compiled by the client with assistance from the principal designer. Includes existing survey reports, asbestos survey, structural information, information about existing services, ground investigation reports, and any other information relevant to health and safety during construction.

Construction phase plan. Prepared by the principal contractor before the construction phase begins. Must include a description of the project, the management structure, arrangements for controlling significant risks, and arrangements for consultation, cooperation, and coordination.

Health and safety file. Compiled by the principal designer and updated by the principal contractor throughout the project. Contains information about the completed structure that will be needed for future maintenance, alteration, or demolition. Handed to the client at completion.

Form F10 notification. Submitted to the HSE before the construction phase begins on notifiable projects. Must include project details, client details, principal designer details, principal contractor details, and the planned start and end dates.

Induction records. Evidence that every person who has worked on site received a suitable site-specific induction. Include name, employer, date, content covered, and confirmation of attendance.

Risk assessments and method statements. While not specifically required by CDM 2015, they are required by the Management of Health and Safety at Work Regulations 1999 and are an essential part of demonstrating compliance with CDM requirements for planning and managing work safely.

Common Compliance Failures

Late or missing appointments. The principal designer and principal contractor must be appointed before their respective phases begin. Appointing them after work has started is a breach, and it is one of the most common failures found during HSE inspections.

Inadequate construction phase plan. A generic or template-based construction phase plan that has not been tailored to the specific project does not comply with the regulations. The plan must be specific, relevant, and proportionate to the risks of the actual project.

No pre-construction information. Clients have a duty to provide pre-construction information, and designers and contractors have a right to receive it. The failure to compile and share pre-construction information is a breach that creates genuine risk because designers and contractors make decisions without knowledge of existing hazards.

Incomplete health and safety file. The health and safety file is often treated as an afterthought, compiled hastily in the final weeks of the project. This typically results in an incomplete file that does not serve its purpose of informing future construction work. Start compiling it at the beginning of the project and populate it progressively.

Domestic client duties not transferred. On domestic projects, the client's duties automatically transfer to the contractor or principal contractor. But if the domestic client appoints a principal designer, the duties transfer to the principal designer during the pre-construction phase. Many small contractors working on domestic projects are unaware that they have assumed the client's CDM duties by default.

CDM 2015 compliance is not about creating paperwork for its own sake. It is about ensuring that health and safety is properly planned, managed, and coordinated from the start to the finish of every construction project. The checklist above provides a practical framework. The commitment to making it work must come from the people responsible for delivering the project.