Site Safety on London Residential Projects: What the Contractor Is Responsible For

Health and safety on a construction site is a legal requirement, not a preference. The Construction (Design and Management) Regulations 2015 (CDM 2015) set out a framework of duties for everyone involved in a construction project -- including the client, the principal designer, the principal contractor, and all contractors and workers. For London homeowners commissioning construction work on their homes, understanding what is required of them and what to expect from a competent contractor is an important part of choosing the right team and managing the project appropriately.

A domestic client is a person who commissions construction work on their home for purposes unrelated to any trade, business, or profession. Under CDM 2015, domestic clients have simplified duties compared with commercial clients -- but they are not duties-free.

In practice, under CDM 2015, most of the domestic client's duties transfer to the contractor or principal contractor by default:

• Where only one contractor is working, that contractor takes on the client's CDM duties by default
• Where more than one contractor is working, the domestic client must appoint a principal contractor and a principal designer, or the roles default to the main contractor and the principal designer role defaults to the architect or, in their absence, the contractor

This means that for most London residential projects, the appointed contractor is responsible for managing health and safety on the site under CDM 2015. This does not mean the client has no interest in safety -- it means the formal legal duty has transferred, and the client should check that the contractor is discharging it competently.

As principal contractor on a London residential project, the contractor is responsible for:

Preparing and maintaining a Construction Phase Plan -- the Construction Phase Plan (CPP) sets out how the contractor will manage health and safety during the construction phase. It should be prepared before the construction phase begins and updated as the project progresses. It typically includes: site organisation, site rules, emergency procedures, risk assessments, method statements for significant hazards, and welfare facilities.

Coordinating all contractors and workers on site -- ensuring that all subcontractors and workers on site understand and comply with the site rules and the CPP.

Controlling access to the site -- preventing unauthorised access, particularly by children and members of the public. In London's dense residential streets, controlling site access is a significant practical challenge that requires physical barriers, signage, and disciplined gate management.

Providing welfare facilities -- including toilet facilities, handwashing facilities, a place to rest and eat, and a supply of drinking water. On a London residential project, welfare facilities are often provided within the property being refurbished or via portable facilities.

Managing significant hazards -- including: asbestos (engaging licensed contractors for licensed ACM removal), working at height (correct scaffolding and edge protection), excavation (shoring and monitoring as required), manual handling, and noise and vibration.

Asbestos -- the most significant hazard in London residential refurbishment. Properties built before 2000 may contain asbestos-containing materials (ACMs) in artex ceilings, floor tiles, pipe lagging, insulating board, and roofing materials. A management survey (and refurbishment/demolition survey where invasive works are proposed) must be carried out before work begins. Licensed ACM removal requires a licensed contractor and HSE notification.

Working at height -- scaffold erection and loft conversion work involve significant working at height risks. Correct scaffold specification, competent erection (NASC members for larger scaffolds), edge protection at eaves and dormers, and controlled access to roof-level working areas are all required.

Structural instability -- during demolition and structural alteration, temporary propping must be in place before load-bearing elements are removed. Working in or adjacent to structurally weakened areas without engineer-approved temporary support is a serious risk.

Excavation -- basement excavation and foundation work involve risk of collapse of unsupported excavations. Ground conditions in London are variable, and excavations adjacent to existing structures require careful management, monitoring, and temporary support where required.

Electrical services -- existing electrical services in London homes are frequently outdated or non-compliant. Strip-out work should not proceed until electrical isolation is confirmed.

Dust and noise -- London councils enforce noise limits, and dust from demolition, cutting, and plastering poses health risks to workers and neighbours. Water suppression, respiratory protection, and dust screens at site boundaries are standard requirements.

A competent London contractor running a well-managed site will:

• Have a signed, site-specific Construction Phase Plan before works begin
• Provide clearly signed and controlled site access
• Have scaffolding erected to a specification by a NASC-registered contractor where appropriate
• Maintain daily induction records for all operatives entering the site
• Conduct toolbox talks with the site team before significant operations
• Maintain a site diary and accident/near-miss recording system
• Display the F10 notification (where required for notifiable projects) and the contractor's insurance certificates on site

rcbGroup prepares a Construction Phase Plan for every project before work begins. Our site managers maintain site access control, toolbox talk records, and daily diaries throughout the project. We work with licensed asbestos contractors where required and coordinate our scaffold specification with our structural engineer and party wall surveyor requirements.

If you are assessing contractors for a London residential project, asking to see a sample Construction Phase Plan and the contractor's health and safety policy is a reasonable and appropriate part of the selection process.

Contact rcbGroup to discuss the health and safety arrangements for your London project.