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#1 Posted : 30 November 2020 19:03:48(UTC)
Rank: Forum user


We are a private school with an in-house maintenance team and carry out our own construction work. As the 'Client', should we be producing a Construction Phase Plan?

Reg 4.5 (CDM 2015) appears to be rather ambiguous. Do we become a contractor by way of carrying out our own work?  Or should we not concern ourselves with a CPP until a contractor/ principal contractor is appointed?

Thank you for reading.

#2 Posted : 01 December 2020 11:15:32(UTC)
Rank: Super forum user

I think the intention of the regulations is that all construction work has a CPP, so that being the case, yes I think you should have one, even if the Contractor is also teh Client. 

The definition of Contractor in reg 2 is "any person (including a non-domestic client) who, in the course or furtherance of a business, carries out, manages or controls construction work" and if you're doing the construction work in-house, you're carrying it out, managing and controlling it, which makes you the Contractor.  Then under reg 15 (5) you need to prepare the CPP.

peter gotch  
#3 Posted : 01 December 2020 11:48:44(UTC)
Rank: Super forum user
peter gotch


As achrn indicates what you describe means that your in house team make you fall within the CDM definition of "Contractor".

However, unless there is more than one "Contractor" you don't need a Principal Contractor - this assumes that all the work can be done by the in house team and that none of them are self-employed. As soon as you bring in a specialist trade to help them then you have more than one Contractor and need to appoint a PC - and if you don't all the PC duties fall on you as Client anyway.

Either way Regulation 4(5) requires you as client to ensure that a CPP is in place - this does NOT have to be a complex document and Appendix 3 of the HSE guidance, L153 indicates what would and would not be appropriate to include.

For much of your work it is likely that a generic CPP would be appropriate and that you just need task specific information to produce when appropriate.

It is far from unlikely that you already have that CPP, just that you haven't called it such and CDM does not prescribe that the CPP shall be entitled the Construction Phase Plan, nor that it should be a singular document.

So this is probably not as difficult as it might first seem.

thanks 1 user thanked peter gotch for this useful post.
aud on 06/12/2020(UTC)
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