Construction has the highest rate of fatal injury of any major industrial sector in Great Britain. In the year ending March 2025, 51 workers were killed on construction sites, and tens of thousands suffered non-fatal injuries. The Health and Safety Executive (HSE) responds with an enforcement strategy that targets not just unsafe acts, but inadequate documentation. If you cannot prove you managed a risk, the HSE presumes you did not manage it at all.
This guide covers the six areas of HSE compliance that generate the most paperwork for construction companies: CDM 2015 duty-holder obligations, RIDDOR reporting, COSHH assessments, working at height controls, asbestos management, and scaffold inspections. Each section explains what the law requires, what records you must keep, and what triggers enforcement action.
The Construction (Design and Management) Regulations 2015 apply to all construction projects in Great Britain. There is no small project exemption: even a homeowner hiring a single contractor to extend a kitchen is within scope, though the notification and principal designer requirements only apply to projects lasting longer than 30 working days with more than 20 workers simultaneously, or exceeding 500 person-days of construction work.
CDM defines five duty-holder roles: client, principal designer, designer, principal contractor, and contractor. Each carries specific legal duties, and the documentation obligations flow from these duties.
The principal contractor must produce a construction phase plan before the construction phase begins. This is the single most important CDM document. It must set out the arrangements for managing health and safety risks on the project, including site rules, emergency procedures, welfare arrangements, coordination of work between contractors, and the specific control measures for high-risk activities (working at height, excavations, demolition, confined spaces, hot works). An HSE inspector arriving on site will ask for the construction phase plan first. If it does not exist, or if it is a generic template that bears no relationship to the actual project, the inspector will issue an improvement notice or, in serious cases, a prohibition notice that stops work.
The principal designer must prepare and maintain the health and safety file, which is handed to the client at the end of the project. This file contains information that anyone carrying out future construction, maintenance, or refurbishment work on the structure will need: as-built drawings, details of hidden services, materials used (particularly anything hazardous), and any residual risks that future workers need to manage. Many principal designers treat this as an afterthought. That is a mistake: the client has a legal duty to keep the file and make it available, and its absence makes future maintenance work more dangerous and potentially uninsurable.
The client must provide pre-construction information to every designer and contractor as soon as practicable. This includes any existing health and safety file, known site hazards (contaminated land, asbestos surveys, services information), and any client requirements or restrictions. Failing to provide this information does not only breach CDM: it leaves contractors operating blind and creates foreseeable risk that the HSE will attribute directly to the client.
The Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013 (RIDDOR) require employers and those in control of work premises to report certain workplace incidents to the HSE. Failure to report is a criminal offence.
You must report the following without delay:
Reports are submitted online through the HSE's RIDDOR reporting portal. Keep a copy of every report, and maintain an internal accident book (the BI 510 format or equivalent) recording all workplace injuries, including those that do not reach the RIDDOR threshold. The HSE uses RIDDOR data to target its inspection programme, and incomplete or late reporting is itself an enforcement trigger.
The Control of Substances Hazardous to Health Regulations 2002 (COSHH) require you to assess the risks from hazardous substances used on your sites and to implement appropriate control measures. In construction, the relevant substances include cement and concrete dust (a cause of occupite dermatitis and respiratory sensitisation), silica dust from cutting, drilling, or grinding concrete, brick, or stone, wood dust, solvents and adhesives, paints and coatings, fuel vapours, and welding fume.
A COSHH assessment must be written for every hazardous substance that workers may be exposed to. It must identify the substance, the hazard (using the safety data sheet), who is exposed and how, the existing control measures, and any additional measures needed. Controls follow the hierarchy: elimination, substitution, engineering controls (LEV, wet cutting), administrative controls (reduced exposure time, rotation), and finally PPE as a last resort.
Assessments must be reviewed whenever there is a change in the substance, the process, or the workforce, and at regular intervals regardless. Keep assessments on site and ensure that every operative who works with or near a hazardous substance has been briefed on the relevant COSHH assessment. An HSE inspector will ask operatives directly whether they know what substances they are working with and what the controls are. If they cannot answer, the assessment is not working.
The Work at Height Regulations 2005 apply to all work at height where there is a risk of a fall liable to cause personal injury. Given that falls from height account for roughly half of all construction fatalities, the HSE treats working at height failures as a priority enforcement area.
You must avoid work at height where it is reasonably practicable to do so. Where it cannot be avoided, you must use the right equipment for the task: fixed platforms and guardrails take precedence over personal fall protection, which takes precedence over nothing. Every piece of work at height must be planned by a competent person, supervised appropriately, and carried out in conditions where weather does not create unacceptable risk.
Risk assessments for working at height must be specific to the task, not generic. A method statement describing the sequence of operations, the equipment to be used, the competencies required, and the emergency rescue plan must accompany the risk assessment. Together, these form the RAMS (risk assessment and method statement) that every site supervisor should have to hand.
Ladders may only be used for work at height where a risk assessment shows that use of more suitable equipment is not justified because of the low risk, short duration, or existing features of the site that cannot be altered. Even then, the ladder must be inspected before use, secured against slipping, and the user must maintain three points of contact.
The Control of Asbestos Regulations 2012 impose a duty to manage asbestos in all non-domestic premises. For construction firms, this means that before any refurbishment or demolition work begins on a building constructed before 2000, you must establish whether asbestos-containing materials (ACMs) are present and where they are.
The duty to manage rests with the building owner or occupier, who should hold an asbestos management survey (Type 2) for the building. Before refurbishment or demolition, a refurbishment and demolition survey (Type 3) is required, carried out by a UKAS-accredited surveyor. The survey report must be provided to all contractors working on the building.
If ACMs are found, they must be managed in situ (encapsulation, labelling, and monitoring) or removed by a licensed asbestos removal contractor (for licensable work: work with asbestos insulation, asbestos coating, or asbestos insulating board). Notifiable non-licensed work requires notification to the HSE but not a licence. Work with textured coatings (Artex) falls into this category.
Records must include the survey report, the asbestos management plan, the asbestos register (a living document updated whenever ACMs are found, removed, or re-encapsulated), air monitoring results, and waste consignment notes for any asbestos removed from site. The HSE treats asbestos non-compliance as one of the most serious categories of health and safety failure, and enforcement action for unlicensed removal or failure to survey carries the heaviest penalties.
Under the Work at Height Regulations, scaffolding must be inspected by a competent person before first use, after any event likely to have affected its stability (high winds, structural alteration, impact damage), and at intervals not exceeding seven days. Each inspection must produce a written report within 24 hours, recording the date, the location, the inspector's name and competence, whether the scaffold is safe to use, and any defects found and actions required.
The inspection report must be kept on site for the duration of the scaffold's use and retained for three months after dismantling. The competent person must hold a recognised scaffold inspection qualification (CISRS Scaffolder or equivalent) and must be independent of the erection team.
Common failures include: no inspection record for the current seven-day period, inspection records signed by someone who is not competent, scaffolds altered after inspection without re-inspection, and scaffolds lacking toe boards, guardrails, or adequate ties. Any of these is grounds for a prohibition notice that stops work immediately.
Hot works (welding, cutting, grinding, brazing, soldering, and any process that generates sparks, flame, or heat sufficient to ignite combustible materials) require a formal permit-to-work system. The permit must be issued before work begins and must specify the location, the nature of the hot works, the fire precautions in place (fire extinguisher within reach, fire watch during and for at least 60 minutes after work, combustible materials cleared or covered), the competence of the operative, and the signature of the person authorising the work.
Hot works permits should be time-limited (typically one shift) and must be closed out when the work is complete and the fire watch period has ended. The completed permit must be retained as a record. Insurers take hot works failures extremely seriously: a large proportion of construction site fires originate from uncontrolled hot works, and a claim arising from hot works conducted without a valid permit may be declined.
The documentation burden for a compliant construction company is substantial. Across a single project, you need a construction phase plan, pre-construction information, RAMS for every activity, COSHH assessments for every hazardous substance, scaffold inspection reports every seven days, hot works permits for every welding or cutting operation, an asbestos register and survey report, toolbox talk records, induction records for every operative, CSCS card checks, plant inspection records (LOLER, PUWER), and RIDDOR reports for any reportable incident.
For a company running multiple sites simultaneously, the volume of documentation is considerable. The firms that manage it well tend to be the ones that survive HSE inspections without enforcement action. The ones that do not are the ones that find themselves in the HSE's public register of prosecutions, explaining to a magistrate why their scaffold inspection records stopped three weeks before a worker fell.
SitePad by Slatewick tracks RAMS, COSHH, scaffold inspections, permits, and RIDDOR in one place. Built for site managers, not consultants.
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