Construction Phase Plan — What It Must Contain and How to Manage It

TL;DR

The Construction Phase Plan (CPP) is the principal contractor's master document for managing health and safety during the construction phase. It must be prepared before construction starts, kept up to date throughout the project, and made available to all contractors and the client.

What is the Construction Phase Plan?

The Construction Phase Plan is a statutory document required under Regulation 12 of CDM 2015. It is prepared by the principal contractor and sets out the arrangements for managing health and safety during the construction phase.

The CPP is a live document — it should grow and develop as the project progresses, reflecting actual site conditions, new risks, and changes to the programme or workforce.

On projects with only one contractor, that contractor prepares the CPP. On multi-contractor projects, the principal contractor prepares it.

What Must the CPP Contain?

The CDM 2015 regulations do not specify a fixed format, but Schedule 3 of the regulations sets out the minimum required contents:

Project Description and Management

• A description of the project
• The management structure (who is responsible for what)
• Details of how health and safety will be monitored and reviewed
• Contact details for all key duty holders

Site-Specific Arrangements

• Site layout and access arrangements
• Site rules (including speed limits, PPE requirements, prohibited areas)
• Welfare facilities (toilets, washing, rest areas, drinking water, changing)
• Security and access control arrangements
• Emergency procedures and first aid arrangements

Risk Management

• Summary of significant risks identified in the pre-construction information
• How those risks will be managed during construction
• Arrangements for RAMS approval and communication
• Procedures for managing high-risk activities (working at height, confined spaces, hot works, excavation, etc.)

Coordination and Communication

• How contractors will cooperate and coordinate with each other
• How information will be shared between the site team
• Toolbox talk and briefing arrangements
• Arrangements for worker consultation

Specific Hazard Plans

Where the project involves particularly high-risk activities, the CPP should include specific sections covering:

• Working at height
• Excavations and groundwork
• Demolition
• Asbestos (if relevant)
• Confined spaces
• COSHH substances
• Traffic management and plant operations

Who Reads the CPP?

The CPP must be:

• Available to all contractors working on site
• Made available to the client on request
• Shared with the principal designer to support the health and safety file
• Made available to HSE inspectors on request

The CPP is not a secret internal document — it is a site-wide resource.

How Should the CPP Be Updated?

The CPP should be reviewed and updated:

• At the start of each new work phase
• When significant new contractors join the project
• When significant new risks are identified
• After any incident or near-miss that reveals a gap in existing arrangements
• When the programme changes significantly

Each significant update should be version-controlled and dated. Key contractors should be notified when substantive changes are made.

What Does a Good CPP Look Like?

What HSE Inspectors Look For

When the HSE visits site, they commonly ask to see the CPP. They look for:

• Whether it exists and has been prepared before construction started
• Whether it addresses the significant risks on the site
• Whether it reflects current site conditions (not an out-of-date document)
• Whether contractors have been made aware of its contents
• Whether it is being actively used to manage the site

A CPP that is clearly a template filled in with minimal detail, or one that predates significant risk areas, will be treated as inadequate.

How Workforce Guardian Supports CPP Management

• Digital CPP creation — structured templates with all required sections built in
• Version control — full history of CPP updates with timestamps
• Contractor sharing — send the CPP to all contractors via the platform with read confirmation
• Integration with RAMS — link approved RAMS to the relevant CPP sections
• Inspection readiness — CPP always available in the project dashboard for instant access

FAQs

Does the CPP need to be a long document?

No. The HSE guidance makes clear that the CPP should be proportionate to the project risk. A small, low-risk project might have a CPP of two or three pages. A complex high-risk project should have a comprehensive, detailed CPP. Length is less important than relevance and accuracy.

Can I use a template CPP for every project?

A template is a useful starting point but every CPP must be tailored to the specific project, site and risks. A generic CPP that has not been adapted to the project will not satisfy CDM 2015 requirements and may give the HSE grounds for enforcement action.

Must the CPP be written before any workers arrive on site?

Yes. CDM 2015 Regulation 12 states clearly that the construction phase must not begin unless the principal contractor has prepared a CPP that is suitable and sufficient. This is a hard pre-start requirement.

Can sub-contractors contribute to the CPP?

Yes — and this is good practice. Sub-contractors carrying out significant or high-risk activities should contribute to the relevant sections of the CPP. Their RAMS should be aligned with and referenced in the CPP.

Is the CPP the same as the health and safety file?

No. The CPP is a live management document used during construction. The health and safety file is prepared by the principal designer and handed to the client at practical completion. It contains information needed for future maintenance. They are separate documents with different purposes.