CDM Regulations 2015 - What is a health and safety file?
For the new CDM 2015 Regulations, the health and safety file is defined as a file appropriate to the characteristics of the project, containing relevant health and safety information to be taken into account during any subsequent project. The file is only required for projects involving more than one contractor.
The file must contain information about the current project that is likely to be needed to ensure health and safety during any subsequent work such as maintenance, cleaning, refurbishment or demolition. When preparing the health and safety file, information on the following should be considered for inclusion:
a) a brief description of the work carried out;
b) any hazards that have not been eliminated through the design and construction processes, and how they have been addressed (e.g. surveys or other information concerning asbestos or contaminated land);
c) key structural principles (e.g. bracing, sources of substantial stored energy – including pre- or post-tensioned members) and safe working loads for floors and roofs;
d) hazardous materials used (e.g. lead paints and special coatings);
e) information regarding the removal or dismantling of installed plant and equipment (e.g. any special arrangements for lifting such equipment);
f) health and safety information about equipment provided for cleaning or maintaining the structure;
g) the nature, location and markings of significant services, including underground cables; gas supply equipment; fire-fighting services etc;
h) information and as-built drawings of the building, its plant and equipment (e.g. the means of safe access to and from service voids and fire doors).
There should be enough detail to allow the likely risks to be identified and addressed by those carrying out the work and be proportionate to those risks
What must duty holders do?
5. The client must ensure that the principal designer prepares the health and safety file for a project. As the project progresses, the client must ensure that the principal designer regularly updates, reviews and revises the health and safety file to take account of the work and any changes that have occurred. The client should be aware that if the principal designer’s appointment finishes before the end of the project, the principal designer must pass the health and safety file to the principal contractor, who then must take on the responsibility for the file.
6. Once the project is finished, the client should expect the principal designer to pass them the health and safety file. In cases where the principal designer has left the project before it finishes, it will be for the principal contractor to pass the file to the client.
7. The client must then retain the file and ensure it is available to anyone who may need it for as long as it is relevant – normally the lifetime of the building - to enable them to comply with health and safety requirements during any subsequent project. It can be kept electronically, on paper, on film, or any other durable form.
8. If a client disposes of their interest in the building, they must provide the file to the individual or organisation who takes on the client duties and ensure that the new client is aware of the nature and purpose of the file. If they sell part of a building, any relevant information in the file must be passed or copied to the new owner. If the client leases out all or part of the building, arrangements should be made for the file to be made available to leaseholders. If the leaseholder acts as a client for a future construction project, the leaseholder and the original client must arrange for the file to be made available to the new principal designer.
9. Where it is not possible to eliminate health and safety risks when preparing or modifying designs, designers must ensure appropriate information is included in the health and safety file about the reasonably practicable steps they have taken to reduce or control those risks. This will involve liaising with:
a) the principal designer in helping them carry out their duty to prepare, update, review and revise the health and safety file. This should continue for as long as the principal designer’s appointment on the project lasts; or
b) the principal contractor where design work is carried out after the principal designer’s appointment has finished and where changes need to be made to the health and safety file. In these circumstances, it will be the principal contractor’s duty to make those changes, but the designer must ensure that the principal contractor has the appropriate information to update the file.
This information should be provided to the principal designer and principal contractor as early as possible before the designer’s work ends on the project.
The principal designer
10. The principal designer is responsible for preparing the health and safety file. They are accountable to the client and should liaise closely to agree the structure and content of the file as soon as practicable after appointment. In preparing the file, the principal designer should expect the client to provide any health and safety file that may exist from an earlier project.
11. The principal designer must also cooperate with the rest of the project team and should expect their cooperation in return. Cooperation with the principal contractor is particularly important in agreeing the structure and content of the information included in the file. Liaison with designers and other contractors is also important. They may hold information that is useful for the health and safety file, which may be difficult to obtain after they have left the project.
12. The principal designer, in cooperation with other members of the project team must also ensure that the file is appropriately updated, reviewed and revised as necessary to ensure it takes account of any changes that occur as the project progresses.
13. The principal designer must pass the updated file to the client at the end of the project. In doing this, they should ensure the client understands the structure and content of the file and its significance for any subsequent project. If the principal designer’s appointment finishes before the end of the project, they must pass the file to the principal contractor who must then take on responsibility for it. In doing this, the principal designer should ensure the principal contractor is aware of any outstanding issues that may need to be taken into account when reviewing, updating and revising the file.
The principal contractor
14. For the duration of the principal designer’s appointment, the principal contractor plays a secondary role in ensuring the health and safety file is fit for purpose. They must provide the principal designer with any relevant information that needs to be included in the health and safety file.
15. Where the principal designer’s appointment finishes before the end of the project, the principal contractor must take on responsibility for ensuring that the file is reviewed, updated and revised for the remainder of the project. At the end of the project the principal contractor must pass the file to the client. In doing this, they should ensure the client understands the structure and content of the file and its significance for any subsequent project.
16. The contractor has no specific duties placed on them in relation to the health and safety file.
If you find that the regulations around the Health and Safety File are too complex, or you would like peace of mind that you are fully compliant, please give the QSC Team a call on 01332 294800