Fire Safety Plans for Construction Sites: CDM 2015 Requirements

Construction site fires cause tens of millions of pounds of damage in the UK every year. They destroy partially completed structures, delay projects by months, and -- at their worst -- kill workers and members of the public. Fire safety on construction sites requires a fundamentally different approach from fire safety in occupied buildings, because the fire protection measures built into the permanent structure (compartmentation, detection, sprinklers) are not yet in place. This guide covers the legal requirements for fire safety plans on construction sites, how to carry out a fire risk assessment, and practical measures for preventing and responding to fires during construction.

Legal Framework for Construction Site Fire Safety

Fire safety on construction sites is governed by several overlapping pieces of legislation:

• Regulatory Reform (Fire Safety) Order 2005 (FSO) -- the primary fire safety legislation in England and Wales. It applies to all workplaces, including construction sites. The "responsible person" (usually the principal contractor on a construction site) must carry out a fire risk assessment and implement appropriate fire precautions.
• Construction (Design and Management) Regulations 2015 -- CDM 2015 requires the principal contractor to plan, manage, and monitor fire safety as part of overall site safety management. Schedule 2 of CDM 2015 specifically requires provisions for emergency routes and exits, fire detection and firefighting measures, and emergency procedures.
• Management of Health and Safety at Work Regulations 1999 -- requires employers to have procedures for serious and imminent danger, including fire evacuation.
• Dangerous Substances and Explosive Atmospheres Regulations 2002 (DSEAR) -- applies where flammable substances are stored or used on site (LPG, solvents, fuel).

Joint Code of Practice on the Protection from Fire of Construction Sites and Buildings Undergoing Renovation (FPA/BRE) provides detailed guidance on fire safety during construction. While not legally binding, it represents industry best practice and is referenced by insurers and the HSE.

Fire Risk Assessment for Construction Sites

The fire risk assessment must be specific to the construction site and must be reviewed as the project progresses (fire risks change significantly between groundworks, superstructure, and fit-out phases). The assessment should identify:

Sources of Ignition

• Hot work -- welding, flame cutting, grinding, brazing. The single biggest cause of construction site fires.
• Electrical -- temporary electrical installations, overloaded circuits, damaged cables, portable heaters.
• Arson -- construction sites are frequent targets for arsonists, particularly outside working hours. Arson is the leading cause of large construction site fires.
• Smoking -- discarded smoking materials in areas with combustible waste.
• Plant and equipment -- overheating engines, exhaust systems near combustible materials, refuelling operations.
• LPG and fuel storage -- gas cylinders, diesel tanks, petrol generators.

Sources of Fuel

• Timber formwork, scaffolding boards, and structural timber
• Insulation materials (some are highly flammable before being enclosed)
• Packaging materials (cardboard, polythene, polystyrene)
• Solvents, adhesives, and paints
• Construction waste (particularly mixed waste containing plastics and timber)
• Temporary accommodation and site offices

People at Risk

• Construction workers (especially those working in enclosed areas with limited escape routes)
• Visitors and delivery drivers who may not be familiar with the site layout
• Neighbours and members of the public adjacent to the site
• Emergency responders who may need to access the site

Fire Prevention Measures

Hot Work Controls

Hot work is responsible for more construction site fires than any other single cause. Effective hot work controls include a formal hot work permit system (see our guide to permit to work systems on the FORGE Command blog), fire extinguisher within 2 metres of any hot work, a fire watch for a minimum of 60 minutes after hot work ceases (120 minutes is preferable), removal or protection of combustible materials within 10 metres of hot work, and smoke detector isolation and reinstatement procedures.

Site Security

Arson prevention requires robust site security: secure perimeter fencing, CCTV with monitoring, security lighting, security guard patrols outside working hours (particularly for high-value projects and projects in urban areas), and securing combustible materials and ignition sources (locking away LPG cylinders, removing portable heaters) at the end of each shift.

Housekeeping

Poor housekeeping is a significant fire risk. Accumulated waste, particularly packaging and off-cuts, provides fuel for fire. Implement a strict housekeeping regime: clear waste daily, do not allow waste to accumulate near buildings under construction or site boundaries, maintain clear access routes for firefighting, and segregate flammable waste from general waste. Effective waste management is directly linked to fire risk reduction.

Electrical Safety

Temporary electrical installations must be designed, installed, and maintained by a competent person. PAT test portable equipment regularly, do not overload circuits, use RCD protection, and inspect cables for damage (particularly in areas where they cross traffic routes or are exposed to mechanical damage).

Emergency Procedures

Fire Detection

During construction, the permanent fire detection system is typically not yet operational. Temporary fire detection may be needed, particularly in enclosed areas where a fire could develop undetected. Options include battery-operated smoke detectors in site offices and welfare facilities, temporary fire alarm systems with manual call points at key locations, and thermal imaging cameras for night-time monitoring of areas where hot work has been carried out.

Means of Escape

Construction sites must have adequate means of escape from fire at all times. This is challenging because the layout changes constantly as the building progresses. Key requirements include a minimum of two escape routes from any area (wherever reasonably practicable), escape routes that are kept clear of obstructions and debris, emergency lighting on escape routes (particularly in enclosed areas), stairways that are usable (not blocked by materials, formwork, or construction debris), and assembly points clearly identified and communicated to all workers.

Firefighting Equipment

Fire extinguishers should be provided at regular intervals throughout the site: on every floor of a building under construction, adjacent to all hot work locations, in site offices and welfare facilities, and near LPG and fuel storage areas. Extinguishers must be the correct type for the fire risk (water for solid materials, CO2 or powder for electrical, foam for liquids). Workers should receive basic fire extinguisher training during site induction.

Emergency Plan

The fire emergency plan should cover how the alarm is raised (air horn, whistle, site-wide PA system), the evacuation procedure, assembly point locations, fire warden roles and responsibilities, procedure for calling the fire service (including the site address, access points, and any specific hazards on site), procedures for accounting for all persons on site (sign-in/sign-out registers), and arrangements for meeting and briefing the fire service on arrival.

The plan should be communicated to all workers during induction and reinforced through regular fire drills (at least quarterly on larger sites). AI tools like Site Manager AI can generate site-specific fire safety documentation and integrate it with other safety management documentation.

Phase-Specific Fire Risks

Fire risks change dramatically as a construction project progresses:

• Groundworks -- lower fire risk. Main concerns are fuel storage for plant and vegetation clearance (burning is not permitted on most sites).
• Superstructure -- increasing fire risk as combustible materials (formwork, insulation, temporary weather protection) are introduced. Hot work for steel connections is a major risk.
• Fit-out -- highest fire risk phase. Large quantities of combustible materials (timber, insulation, floor coverings, packaging), extensive hot work, and temporary electrical installations all present significant fire hazards simultaneously.
• Commissioning -- the permanent fire protection systems should be commissioned as early as possible during fit-out to provide protection during this high-risk phase.

The fire risk assessment and fire safety plan must be updated at each phase transition to reflect the changing risk profile.