As an H&S file is not required for a project that has only 1 contractor, what is the purpose of a Health and Safety File? Why is a file only required where 2 or more contractors are on a project? This question was asked during a seminar with a wide range of opinions and answers being given. I would be interested in the thoughts of board members with regard to this subject taking into account Appendix 4 (3) of CDM 2015 that states; "The file must contain information about the current project likely to be needed to ensure health and safety during any subsequent work, such as maintenance, cleaning, refurbishment or demolition. When preparing the health and safety file, information on the following should be considered for inclusion: (a) a brief description of the work carried out; (b) any hazards that have not been eliminated through the design and construction processes, and how they have been addressed (eg surveys or other information concerning asbestos or contaminated land); (c) key structural principles (eg bracing, sources of substantial stored energy – including pre- or post-tensioned members) and safe working loads for floors and roofs; (d) hazardous materials used (eg lead paints and special coatings); (e) information regarding the removal or dismantling of installed plant and equipment (eg any special arrangements for lifting such equipment); (f) health and safety information about equipment provided for cleaning or maintaining the structure; (g) the nature, location and markings of significant services, including underground cables; gas supply equipment; fire-fighting services etc; (h) information and as-built drawings of the building, its plant and equipment (eg the means of safe access to and from service voids and fire doors)."

What non-construction people struggled with is that the file is put together for future use. With 1 contractor, potentially doing lots of different work a file is not needed, hence persons doing future work have no file to view! The hazards/risks for future work are the same whether there is 1 contractor or 2.

First, I must point out the CDM 2015 Regulations do not prescribe a H&S File must be provided where there is more than one contractor. However L153 Guidance states - 'The health and safety file is only required for projects involving more than one contractor.' I suspect this was an after-thought by the HSE. Another anomaly with the regulations! Where there is only one contractor there may still be a need for a H&S File. What exactly is provided depends largely on the requirements of the client. I have been invloved in large projects where the client insisted all and sundry was included in the H&S File, including RAMS. For many projects such as basic building, repairs and mainteance work a H&S File will not be needed, regardless of whether there is more than one contractor involved. The regulations do not explicitly provide for this scenario, however common sense prevails...a lot of common sense is needed with regards to CDM 2015 in my opinion.

Health and Safety Files should be maintained for the lifetime of the structure. CDM requirement has been around since 1994. Any Client who doesn't have at least the rudiments of a H&S File after 20+ years of statutory requirement should be asking questions. Why does CDM only require the File to be considered where there is more than one contractor? (and that is a prescriptive requirement) Because that's exactly what the Parent Directive states, and the regulator was constrained by perceived "gold plating" issues. Do note that Regulation 9 requires every Designer to consider matters required for the File. Otherwise, I suggest the pragmatic approach would be for the Client to ask via contract (or preconstruction information pack) for what he wants. New Builds: Can you really build something from the ground up with only one contractor? I doubt it.

If there is no safety file, regulation 5(1) or 12(5) has not been complied with. The regulations require a health and safety file for projects with more than one contractor. This isn't an implicit requirement, this is explicit - those regulations can only be satisfied if a file is created.