A Health and Safety File is a repository of health and safety information that serves as a legal record, benefiting both clients and end users – from initial construction through use, cleaning, maintenance, alterations and refurbishment, and demolition.
Why is a health and safety file required?
A health and safety file is required as part of the Construction, Design and Management (CDM) Regulations 2015. The CDM regulations are in place to ensure risks and hazards information are collected, that the project has a response in place to manage them correctly, and that the response has been communicated to everyone who needs to know.
A project’s health and safety file is part of the overall health and safety management system required by the Management of Health and Safety at Work Regulations 1999. It covers all relevant aspects of health and safety, ensuring that the welfare of people are at the core of the project and resulting asset.
In the UK, we are regulated by the Health and Safety Executive (HSE), who provides information, instruction and guidance. However, while HSE is vital to ensuring that we are meeting health and safety requirements, it is ultimately up to us to ensure that our projects and buildings comply. Having a robust health and safety file is part of that effort.
Who is responsible for the health and safety file, and what are their roles?
At the highest level, CDM Regulations place responsibility for producing a health and safety file with the principal designer. If the principal designer's tenure finishes before the end of the project, the responsibility passes to the principal contractor. Once the project is complete, the file is passed to the client. However, health and safety should always be treated as a wider team effort, with everyone feeding into it where appropriate. Health and safety should never be considered ‘someone else’s responsibility’.
Client
The client must ensure that the principal designer produces that file and, as a project progresses, ensure that the file is regularly updated, reviewed and revised. Once the project is complete, the client must ensure it remains readily available to all who need it. If the client sells the building, then the file goes to the new owner. In lease situations, the leaseholders must have access to the file and, if a leaseholder becomes the client on a future construction project, then the file must be made available to the newly-commissioned project’s principal designer.
The principal designer
The principal designer carries primary responsibility for preparing the health and safety file and is the one who is ultimately accountable to the client. As soon as possible, the principal designer should agree with the client on the file’s structure and format. From that point, the principal designer acts as coordinator, soliciting contributions to the file from the wider project team; in particular, the principal contractor. The principal designer is also responsible for reviewing and revising the information, ensuring that it is up-to-date at every stage of the project.
The principal contractor
The principal contractor provides the principal designer with information that should be included in the file. If the principal designer’s role finishes before the project ends, the principal contractor will take on their responsibility for the file, including passing it on to the client.
Designers and contractors
Designers should always seek to eliminate health and safety risks through design and, where this is not possible, control or reduce them. To this end, the designer is required to closely liaise with the principal designer (and/or the principal contractor), helping them produce the health and safety file. The same applies to contractors. While they do not hold any specific responsibility in regards to producing the file, they are in a position to feed into the process and provide knowledge and insight that will ultimately become a valued part of the file.
When should the Health and Safety File be produced?
Considering the importance of health and safety, the file should be produced as soon as possible; the earlier the information is compiled and shared, the better the decisions made and the fewer risks of duplication or the need for rework. Drawings and other documents are a crucial source of data, providing information on proposed construction methods, product choices and even the thought processes around how an asset will be used. This is also where you learn about hazards – lead, contaminated land, asbestos and any services or nearby activities that could affect the work.
On a BIM project, the Employers Information Requirements (EIR) forms part of the appointment and tender document and should clearly outline client requirements – what's required, when, and in how much detail. A section of the EIR focuses on the management of health and safety/ CDM, and it is here that a client can set out any requirements for BIM-supported health and safety management that it wishes bidders to address. Preferences as to the format of the file can also be set out in the EIR.
When working with a digital information model, considering health and safety requirements the from the beginning is time well spent. Appropriately tagged information can be input once and then used throughout a project. If designed correctly, the health and safety file can be an output of the model, generated by a user requesting a particular 'view' of the information contained within.
What should be included?
CDM Regulation 12 (5) states that the file should be 'appropriate to the characteristics of the project'. In other words, it should contain a sufficient depth and breadth of health and safety information to allow maintenance, cleaning, alterations, refurbishment or demolition to be carried out safely. Typically the file will contain:
- Information on the work being carried out.
- Hazards that have not been eliminated through the design and construction phases and how they have been addressed.
- Background information on the asset’s structure and form and any limitations – e.g., safe working loads for floors and roofs, the location of utility services, etc.
- Any hazardous materials used (e.g., paints, special coatings, etc.) that will prove useful when maintaining or removing these substances or working in affected areas.
- Information, including as-built drawings, including safe means of access to service areas.
What should not be included?
All information contained within the file should be of use when planning future construction work. Extraneous information – like that relating to pre-construction or operation and maintenance – is not required and will serve only to create an additional maintenance burden.
Do I still need an operation and maintenance (O&M) manual?
Traditionally, the health and safety file and operation and maintenance manual have been distinct and often produced by different people. However, doing it this way loses the potential for collaboration and appropriate cross linking. By creating a digital information model it is possible to beneficially combine, link and integrate both.
What format should the health and safety file take?
The CDM Regulations don't dictate a particular file format; however, the client is expected to provide easy access to the file and esure it can be easily retrieved by whoever needs it for as long as the building exists. So, there are a number of ways a file could be produced in a reasonably durable format – on paper, film or electronically.
Regardless of format, it is important that any reference to a plan, rule, document, report or copy should include reference to a 'physical' or an electronic copy somewhere. The purpose being that you can retrieve or reproduce information when required and have mitigated against the effects of loss or unauthorised interference.
Should I consider a digital health and safety file?
Historically, a health and safety file was produced and stored as a series of paper-based lever-arch files. This format didn't lend itself to easy interrogation or sharing and proved difficult to manage –becoming lost or damaged. These days, we tend to create the file digitally; however, we still print it out for sharing and access. The problem doing it this way is that, once printed, the information immediately dates, making it easy to fall out of step with the electronic copy. This not only creates an additional maintenance burden for both paper and electronic versions, but creates a risk that users are relying on an out-of-date version. A digital-only version that is stored and shared in a Common Data Environment (CDE) can serve as a single source of truth or, at least, be more clearly version controlled.
No matter how hard you try and avoid it, there’s a good chance that at least some of the information provided for inclusion in the health and safety file is printed. Early engagement with the supply chain helps manage expectations; however, in those times when paper cannot be avoided, the information should be scanned and stored alongside the project’s digital information. It’s also worth considering whether information scans that effectively create images regardless of content (text being unsearchable and editable) are appropriate or whether to use optical character recognition (OCR) software to translate paper documents into machine-readable data – ensuring that documents are searchable and editable, thus making retrieval much easier.
This article is based on one of the same name (2017) by former NBS Editor Richard McPartland and revised by Technical Content Specialist Jess Sharman.
Additional reading and postscrips
The article Health and Safety and the RIBA Plan of Work provides more information addressing health and safety through specifying and how its addressed in the RIBA Plan of Work 2020. The article is part of a wider NBS webinar series addressing the various elements of the new POW 2020, including fire safety, sustainability, conservation and intelligent design. To view the webinar series, please visit the RIBA Plan of Work 2020 hub page.
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