Hello,

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.

Frank

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.