CDM 2015 Compliance Checklist for Small Contractors

What are the CDM 2015 Regulations?

The Construction (Design and Management) Regulations 2015 are the main set of regulations for managing health, safety, and welfare on construction projects in Great Britain. They apply to every construction project, regardless of size, and place duties on everyone involved, from clients to designers to contractors.

If you are a small contractor, you might think CDM only applies to large commercial sites. That is not the case. CDM 2015 removed the old notification threshold. Whether you are fitting a kitchen extension or building a housing estate, the regulations apply to you.

Who are the CDM duty holders?

CDM 2015 defines five duty holder roles:

• Client: the person or organisation paying for the work. On domestic projects, the contractor typically takes on client duties unless a principal designer is appointed.
• Principal Designer: responsible for planning, managing, and coordinating the pre-construction phase on projects with more than one contractor.
• Designer: anyone who prepares or modifies a design (including drawings, specifications, or material schedules) that relates to construction work.
• Principal Contractor: manages the construction phase on projects with more than one contractor. Responsible for site induction, coordination, and the construction phase plan.
• Contractor: any business or individual carrying out construction work. Even sole traders are contractors under CDM.

On many smaller domestic projects, there is only one contractor, so you take on both contractor and (in effect) principal contractor duties.

The CDM 2015 compliance checklist

Before work starts

• Understand your duties: know which duty holder roles apply to you on each project. If you are the only contractor, you carry both contractor and principal contractor duties.
• Check client awareness: make sure the client understands their duties. For domestic clients, provide a brief written summary of what CDM means for them.
• Review design information: if a designer is involved, check that you have received any pre-construction information, including known hazards, site surveys, or service locations.
• Prepare a construction phase plan: this is mandatory before work begins on site. It does not need to be a 50-page document. For small projects, a proportionate plan covering key risks, site rules, and emergency procedures is sufficient.
• Check competence: ensure everyone working on the project has the right skills, training, and qualifications. This includes CSCS cards, trade qualifications, and any specialist training needed for the job.
• Notify the HSE if required: projects lasting more than 30 working days with more than 20 workers on site at any point, or exceeding 500 person-days, must be notified to the HSE via an F10 form.

Risk assessments and method statements (RAMS)

• Complete risk assessments: identify the hazards for each significant task and document how you will control them. Focus on the most common construction killers: falls from height, being struck by vehicles or plant, collapse of structures, contact with services (gas, electric, water), and asbestos.
• Write method statements: for higher-risk activities, document the step-by-step process, who will do what, and what equipment and PPE are needed.
• Share RAMS with your team: there is no point having RAMS if your workers have not seen them. Brief your team before work starts and keep copies on site.
• Review and update: RAMS are living documents. If conditions change, the scope changes, or an incident occurs, update them.

On site

• Site induction: every person visiting or working on site must receive a site induction covering key hazards, site rules, welfare arrangements, and emergency procedures.
• Welfare facilities: you must provide (or arrange access to) toilets, washing facilities, drinking water, a place to rest and eat, and somewhere to change and store clothing. On domestic projects, you may agree to use the client's facilities, but this should be discussed up front.
• PPE: provide appropriate personal protective equipment and ensure it is worn. Hard hats, hi-vis, steel toe-cap boots, eye protection, and gloves are the minimum on most sites.
• Working at height: follow the Work at Height Regulations 2005. Use the hierarchy: avoid work at height where possible, use a safe working platform (scaffold, tower, MEWP) where it cannot be avoided, and only use ladders for short-duration, low-risk tasks.
• Electrical safety: ensure temporary electrics are protected by RCDs. Check cables and equipment regularly. Keep 110V for portable tools on site.
• Fire prevention: maintain clear escape routes, provide fire extinguishers where needed, and control hot works with a permit system.

Documentation and records

• Construction phase plan: keep it on site and accessible to everyone.
• RAMS: filed on site, signed by workers who have read them.
• Induction records: keep a log of who has been inducted and when.
• Inspection records: scaffold inspections, excavation inspections, plant checks.
• Accident book: record all injuries and near misses, no matter how minor.
• Health and safety file: if you are the principal contractor, you must hand over a health and safety file to the client at the end of the project. This includes as-built drawings, certificates, maintenance schedules, and any information needed for future work on the building.

5 common CDM failures for small contractors

1. No construction phase plan

This is the most common failing. Many small contractors do not realise they need one, or they think it only applies to commercial projects. Every project needs a plan before work starts, proportionate to the risk.

2. Inadequate welfare provision

Portaloos and a kettle are the bare minimum, not the standard. On longer projects, you need proper washing facilities, hot water, and a sheltered rest area. Cutting corners on welfare is an easy target for HSE inspectors.

3. Poor work at height controls

Falls from height remain the number one killer in UK construction. Using a ladder to work at height for extended periods, working on fragile roofs without protection, or failing to use edge protection on scaffolds are all common failings.

4. Missing or generic RAMS

Downloading a template from the internet and changing the company name is not a risk assessment. Your RAMS must be specific to the site, the work, and the conditions you face. Generic documents will not protect you in court.

5. No site induction

Even on a two-person domestic job, each worker should know the site hazards, emergency plan, and welfare arrangements. A five-minute conversation at the start of each day can count as an induction on smaller sites, but you should record it.

What happens if the HSE visits?

HSE inspectors can visit any construction site without notice. Here is what to expect:

Identification: the inspector will show their warrant card and explain why they are visiting (routine inspection, complaint, or accident investigation).

Site walk: they will walk the site looking at working conditions, welfare, access, plant, and documentation.

Document check: they will ask to see your construction phase plan, RAMS, induction records, and any relevant certificates or inspection reports.

Interviews: they may speak to workers individually to check they understand the risks and controls.

Outcome: the inspector may be satisfied, issue an improvement notice (giving you a deadline to fix a problem), issue a prohibition notice (stopping work immediately until a serious risk is resolved), or in the worst case, begin prosecution proceedings.

Fines for CDM breaches can be significant. Courts consider turnover when setting fines, and for serious failings, individual directors and sole traders can face personal prosecution.

How to stay on top of CDM compliance

Staying compliant does not need to be burdensome. The key is having a system that prompts you to complete the right documents at the right time.

ScopeKit's compliance tracking is built specifically for UK contractors. It helps you:

• Generate construction phase plans from project details
• Create site-specific RAMS using pre-built templates
• Track induction records and training certifications
• Set reminders for scaffold inspections and equipment checks
• Store all documentation in one place, accessible from site on your phone

Whether you are a sole trader groundworker or a small building firm, ScopeKit keeps your CDM paperwork organised without the admin overhead.

Book a 15-min demo and take the stress out of compliance.