The Health & Safety File
The Construction (Design and Management) Regulations 2015 requires that certain documents be in place at particular stages in the design and construction process.
The Health and Safety File is a record of information for the Client or the end user which focuses on health and safety. The information it contains will alert those who are responsible for the structure of the key health and safety risks that will need to be dealt with during subsequent maintenance, repair and construction work.
The amount of detail needed in the Health and Safety File and the time and effort required to prepare it should be in proportion to the scale and complexity of the structure. Structures with minimal health and safety risks will call for a simple, straightforward file. Large structures or those involving significant risks will need more detail.
Preparing the Health & Safety File
The Principal Designer is responsible for ensuring that the Health and Safety File is prepared.
Early on in the construction project the Principal Designer will discuss the Health and Safety File with the client. This will help determine what information the client requires and how the client wishes the information to be stored and recorded. When the client’s requirements are known, procedures may need to be drawn up by the Principal Designer so that all those who will be contributing to the Health and Safety File (eg designers and contractors) are aware of:
- what information is to be collected;
- how the information is to be collected, presented and stored.
Throughout the project those who carry out design work (including contractors) need to ensure so far as is reasonably practicable that information about any feature of the structure which will involve significant risks to health and safety during the structure’s lifetime is passed to either the Principal Designer or to the Principal Contractor. Providing this information on drawings allows for amendments if any variations arise during construction. It also allows health and safety information to be stored on one document, therefore reducing the paperwork.
The Principal Contractor may need to obtain details of services, plant and equipment which are part of the structure from specialist suppliers and installers, eg mechanical and electrical contractors, and pass this information on. Contractors have a specific duty in the CDM Regulations to pass information for the Health and Safety File to the Principal Contractor, who in turn has to pass it to the Principal Designer. This information could include ‘as built’ and ‘as installed’ drawings as well as operation and maintenance manuals.
At the end of the project the Principal Designer has to hand over the Health and Safety File to the client. In some cases it might not be possible for a fully developed file to be handed over on completion of the project. This may happen because the construction work was finished rapidly to meet a tight deadline and completion of the Health and Safety File was impossible. Clearly a common sense approach is needed so that the Health and Safety File is handed over as soon as is practical after a completion certificate or similar document has been issued.
Contents of the Health & Safety File
The Health and Safety File should contain the following information:
- a brief description of the work carried out
- any residual hazards which remain and how they have been dealt with (e.g. information concerning asbestos, contaminated land, buried services etc.)
- key structural information (e.g. bracing, sources of substantial stored energy – including pre- or post-tensioned members etc.)
- safe working loads for floors and roofs, particularly where these may prohibit placing scaffolding or heavy machinery
- hazardous materials used (e.g. pesticides, special coatings which should not be burnt off etc.)
- information regarding the removal or dismantling of installed plant and equipment (e.g. any special arrangements for lifting, special instructions for dismantling etc.)
- health and safety information about equipment provided for cleaning or maintaining the structure
- the nature, location and markings of significant services, including underground cables; gas supply equipment; fire-fighting services etc.
- information and as-built drawings of the structure, its plant and equipment (e.g. the means of safe access to and from service voids, fire doors and compartmentalisation etc.)
The Health and Safety File does not need to contain information that is irrelevant to the future planning of works or the normal operation of the structure.
Future use of the Health & Safety File
When the project is finished and the Health and Safety File has been handed over by the Principal Designer, the client should keep it available for those who need to use it. Usually this will include maintenance contractors, the Principal Designer and contractors preparing or carrying out future construction work.
Ideally, the Health and Safety File should be kept available for inspection on the premises to which it relates. It may be useful to store the Health and Safety File in two parts. One part will be more relevant for day to day use, eg operational and maintenance manuals. The other part will be for longer term use, eg drawings which will only be required when major alteration work is carried out. In addition the Health and Safety File could be stored electronically or on microfiche. In whatever form it is stored, it should be easily accessible.
On a project which involves work on part of a structure for which there is no Health and Safety File, a file only has to be created in relation to the construction work carried out and not for the whole of the structure. Eventually, as further work is carried out on that structure, the Health and Safety File will be added to and amended.
If the client sells all or part of the structure, the Health and Safety File, or the relevant parts of the Health and Safety File, should be passed to the new owner.