CDM Health and Safety File: what should it contain?

A CDM Health and Safety File is required for a project involving more than one contractor. The Principal Designer prepares it during the pre-construction phase, reviews and updates it as the project changes, and passes the completed file to the client at the end. If the Principal Designer's appointment ends before completion, the file passes to the Principal Contractor, who takes over those duties.

The file should contain relevant information from the current project that is likely to be needed to protect people during later construction work, including maintenance, cleaning, refurbishment or demolition. Its contents must be appropriate to the project and proportionate to the risks.

Who prepares, updates and owns the file?

The file depends on information moving between several duty holders. Appointing one person to assemble documents is not enough if the project team has not agreed what information is needed, who will provide it and when.

The client remains responsible for ensuring the arrangements work. A document request issued two days before practical completion does not create an effective information process.

When should the Health and Safety File be started?

Regulation 12 requires the Principal Designer to prepare the file during the pre-construction phase. HSE guidance says the Principal Designer and client should agree its structure and content as soon as practicable after appointment.

Starting early allows the team to:

• review any existing file and asset information supplied by the client;
• identify the significant design and construction information future workers will need;
• allocate information requirements to designers, the Principal Contractor and specialist contributors;
• set submission dates before packages finish or people leave the project; and
• review whether design changes, substitutions and as-built conditions alter the file.

A useful approach is to establish a file index and responsibility schedule early, then treat both as live controls. The finished file should reflect what was actually designed and built, not just the tender information.

What information should the file contain?

HSE's L153 guidance gives examples to consider rather than a universal contents list. Include an item when it is relevant to the structure and likely to help someone identify and control risks during future construction work.

1. A clear description of the completed work

Summarise the project scope, important alterations and the parts of the structure affected. This helps a future reader understand which information applies and where to look next.

2. Significant residual hazards

Record hazards that could not be eliminated through design or construction and explain how they were addressed. This may include relevant asbestos or contaminated-land information, unusual access constraints, concealed hazards or specific precautions needed for later work. Focus on information that is significant, project-specific and not obvious to a competent person.

3. Structural principles and safe working limits

Include key structural principles, stability information and safe working loads where these will affect later work. Examples may include bracing requirements, load limits, post-tensioned elements or stored energy. The aim is to prevent a future alteration, opening, lifting operation or temporary condition from undermining the structure.

4. Hazardous materials incorporated into the work

Identify relevant hazardous materials that could expose people during maintenance, refurbishment or removal. The file should make the material, location and required precautions understandable rather than simply store an unfiltered product-data folder.

5. Removal and maintenance information

Provide information needed to remove or dismantle installed plant and equipment safely, including any special lifting or access arrangements. Include health and safety information for equipment provided to clean or maintain the structure.

6. Significant services and as-built information

Record the nature, location and markings of significant services, such as underground cables or gas-supply equipment. Include relevant as-built drawings for the building, plant and equipment, especially where they show safe access to service voids, isolation points, maintenance zones or other risk-critical features.

What should not be put in the file?

HSE says the file should not include material that will be no help when planning future construction work. That normally means excluding wholesale copies of:

• the pre-construction information pack;
• the Construction Phase Plan;
• generic risk assessments and method statements;
• contracts, tender returns, valuations and routine commercial correspondence;
• superseded drawings with no continuing safety relevance; and
• generic product literature that does not help a future worker locate or control a project-specific risk.

Do not remove a relevant item merely because it also appears elsewhere. Instead, include or clearly cross-reference the controlled information a future duty holder will actually need. The file should be convenient to use, clear, concise and understandable.

How should the file be handed over and retained?

At the end of the project, the Principal Designer normally passes the updated file to the client. If the Principal Designer's appointment ended earlier, the Principal Contractor completes that handover. A controlled handover should identify the file version, date, format, contents and any genuinely outstanding item, and should confirm that the client understands the file's purpose.

The client must retain the file and make it available to people who may need it for as long as it remains relevant—normally for the life of the building. It may be kept electronically, on paper or in another durable form, but it needs an owner, a reliable location and a process for keeping it accessible.

If the client disposes of its interest in the building, the file must pass to whoever takes on the client duties. For a partial sale, relevant information must be passed or copied to the new owner. Where premises are leased, arrangements should allow leaseholders and future Principal Designers to obtain the information they need.

How does it differ from PCI, the CPP and O&M information?

These information sets can share source documents and be managed within one handover system, but they have different purposes. Labelling an entire O&M manual as the Health and Safety File without selecting and organising the relevant future-construction information can leave the CDM purpose unmet.

A practical review before handover

Before the file is accepted, check whether:

• the contents match the completed work and current as-built condition;
• significant residual hazards are described clearly and can be located;
• structural principles, load limits, hazardous materials and significant services are covered where relevant;
• drawings, surveys and records show their status, date and revision;
• important information from designers, specialists and the Principal Contractor has been received;
• irrelevant project administration and duplicate material have been removed;
• the file is searchable or logically indexed and understandable to a future project team; and
• the client knows where it will be retained, who controls it and how it will be made available.

IMERI H&S Partners provides CDM Principal Designer support, including proportionate Health and Safety File arrangements, for clients, developers, architects and project teams in Watford, Hertfordshire, London and across the South East. The correct scope depends on the project, appointment and information already available.