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 isn’t 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 plenty of people are still working from that memory. It doesn’t say that any more. The 2015 regulations added the twenty-worker condition, and that 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. Someone else can submit it on the client’s behalf, whether that’s the principal designer, the principal contractor or a consultant, 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’s more than one, unless a written agreement makes the principal designer responsible instead. In practice, a domestic project big enough to be notifiable gets notified by the principal contractor.

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

NoteThere’s no minimum notice period. The requirement is "as soon as is practicable" and before the construction phase begins. Don’t treat it as a form you submit on day one of the works.

This is the part that matters. Notification is an administrative step, nothing more. The duties below apply to every construction project in Great Britain, and that includes a two-day domestic bathroom.

A construction phase plan is required on every project. Not being notifiable doesn’t remove it.

The plan should be proportionate. For a small job it’s a short document: 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 doesn’t have to be long. The RAMS each contractor supplies 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 makes sure 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 working out how a staircase gets fixed to the wall is designing, and so is a builder who substitutes a detail on site because the specified one won’t fit. Both carry the duty.

Most work carried out by small firms isn’t 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’re the only contractor, you carry the client duties on domestic work. Say so in writing to the homeowner so both of you know where you stand.
3. 03If other trades are on site, someone is principal contractor. On domestic work, that’s normally you.
4. 04Count person days when a job runs long with a small crew. That’s where the 500 person day threshold catches people.
5. 05Keep the health and safety file for the client at the end. It’s 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 it can gate site clock-on on induction, CSCS card and RAMS acceptance. It is bundled from Solo upward rather than sold separately. It doesn’t submit F10 notifications to HSE, and it doesn’t write your construction phase plan.