CDM 2015: when do I need to notify HSE on an F10?

A project is notifiable if it meets either of these. Only one has to be true.

1. 01The construction work is likely to last longer than 30 working days and have more than 20 workers working simultaneously at any point in the project.
2. 02The construction work is likely to exceed 500 person days.

The first threshold needs both conditions. Thirty-five working days with six operatives on site is not notifiable on that limb.

This is the point most commonly got wrong. Under the old CDM 2007 regulations, duration alone triggered notification at 30 days, and a lot of people are still working from that memory. The 2015 regulations added the twenty-worker condition, which took a large number of medium-sized jobs out of notification.

Person days is the total: number of workers multiplied by the days each of them works. Four operatives for 130 days is 520 person days and is notifiable on the second limb, even though the first limb was never met.

The client. Regulation 6 places the duty on the client to give notice in writing to HSE as soon as is practicable before the construction phase begins. The client can arrange for someone else — the principal designer, principal contractor or a consultant — to submit it on their behalf, but the duty stays with the client.

For domestic clients, regulation 7 passes the client duties to the contractor on a single-contractor project, or to the principal contractor where there is more than one — unless there is a written agreement making the principal designer responsible. In practice, a domestic project large enough to be notifiable will be notified by the principal contractor.

The F10 is submitted online through HSE’s website. It must be updated if the particulars change, and a copy of the notice has to be displayed in the site office where workers can read it. Notification is free, and there is no penalty for notifying a project that turns out not to have needed it.

NoteThere is no minimum notice period. The requirement is "as soon as is practicable" and before the construction phase begins. Do not treat it as a form to submit on day one of the works.

This is the part that matters. Notification is an administrative step; the duties below apply to every construction project in Great Britain, including a two-day domestic bathroom.

A construction phase plan is required on every project. Not being notifiable does not remove it.

The plan should be proportionate. For a small job it is a short document setting out the description of the work, the management arrangements, the site rules and the specific health and safety risks with their controls — HSE’s own guidance is clear that it does not have to be long. The RAMS supplied by each contractor feed into it.

• Client — anyone having construction work carried out for their business or undertaking. Makes suitable arrangements for managing the project, provides pre-construction information, and ensures the construction phase plan and health and safety file exist.
• Principal designer — appointed where there is more than one contractor. Plans, manages and monitors the pre-construction phase, and coordinates health and safety in design.
• Principal contractor — appointed where there is more than one contractor. Plans, manages and monitors the construction phase, draws up the construction phase plan, and secures the site.
• Designer — anyone who prepares or modifies a design, including a contractor working out how something will be built. Eliminates foreseeable risks so far as reasonably practicable.
• Contractor — manages the work under their control and cooperates with the principal contractor.
• Worker — reports anything likely to endanger themselves or others, and cooperates with the arrangements.

NoteA design duty applies to more people than expect it. A joiner who decides how a staircase will be fixed is designing. So is a builder who substitutes a detail on site.

Most work carried out by small firms is not notifiable, and almost all of it is still covered by CDM. A practical position for a firm doing domestic extensions and small commercial fit-outs:

1. 01Write a short construction phase plan for every job. One or two pages, specific to the site.
2. 02If you are the only contractor, you carry the client duties on domestic work. Say so in writing to the homeowner so both of you know.
3. 03If other trades are on site, someone is principal contractor. On domestic work, that is normally you.
4. 04Count person days when a job runs long with a small crew. That is where the 500 person day threshold catches people.
5. 05Keep the health and safety file for the client at the end. It is what the next contractor will rely on.

Estimark’s Health & Safety module holds versioned RAMS with operative sign-off, site inductions, toolbox talks and near-miss reporting, and can gate site clock-on on induction, CSCS card and RAMS acceptance. It is £19 a month, included from the Pro plan at £249 a month. It does not submit F10 notifications to HSE and does not generate a construction phase plan for you.