Contents
CDM 2015 background: what triggers PCI requirements
CDM 2015 applies to all construction projects in the UK. For domestic clients (homeowners commissioning residential work), the specific requirements depend on whether the project is 'notifiable':
- **Notifiable project criteria** (either or both triggers the notification duty):
- •More than 30 working days with more than 20 workers simultaneously present at any one time during a phase of the project
- •More than 500 person-days of work
In practice, most standard domestic extensions, loft conversions, and refurbishments in London do not cross the notifiable threshold — a single-contractor loft conversion taking 10–14 weeks with a crew of 5–6 rarely reaches 500 person-days.
- However, CDM 2015 **still applies** to all construction projects, notifiable or not:
- •A Principal Contractor must be appointed
- •A Principal Designer must be appointed if there are two or more contractors
- •Pre-construction information must be gathered and passed to contractors — the duty is just less formally administered for non-notifiable projects
**For domestic clients specifically**: Where a domestic client has not appointed a Principal Designer, CDM 2015 assigns the duty to the designer in control of the pre-construction phase (typically the architect). Where there is no designer, the duty falls to the Principal Contractor. This means even for a simple domestic project, someone is legally responsible for gathering and passing pre-construction information — even if no formal F10 notification to the Health and Safety Executive (HSE) is required.
What a Pre-Construction Information pack contains
The PCI pack collects all information known about the site, the existing structure, and the proposed works that is relevant to the health and safety of those working on the project. CDM 2015 Schedule 4 sets out the required content.
- **Project description and programme**:
- •Description of the project and its intended scope
- •Key dates — planned start, expected duration, any phasing constraints
- •Procurement route and information about other contractors likely to be involved
- **Client information**:
- •Contact details of the client
- •Any specific site security, access, or operational constraints (e.g., occupied property — hours of work, dust, noise constraints; neighbouring business operating hours)
- •Whether the property will be occupied during the works
- **Environmental constraints**:
- •Details of any hazardous materials known or suspected to be present:
- – Asbestos: the location and condition of any identified asbestos-containing materials (ACMs), together with any Asbestos Survey reports already commissioned. This is typically the most critical item in a PCI for pre-2000 properties — see below.
- – Lead paint: in pre-1970s properties, lead paint is common on window frames, pipework, and external surfaces. Disturbing lead paint without proper controls creates health risk to workers.
- – Contaminated ground: any known ground contamination — made ground, former industrial use, buried tanks — relevant to excavation or foundation work.
- **Existing services**:
- •Location and condition of existing services within and around the property:
- – Gas supply pipework
- – Electricity supply and distribution (fuse board location, incoming supply route)
- – Water mains, stop cock location
- – Drainage layout (surface water and foul drainage — essential before any groundwork or extension foundation dig)
- – Overhead or underground electricity cables — particularly relevant for extensions near the boundary
- – Any previously buried infrastructure (old cesspits, oil tanks, filled wells)
- **Structural information**:
- •Any structural surveys, structural engineer reports, or building surveys already commissioned
- •Information on party walls — whether party wall agreements are in place or notices served
- •Foundation type of existing structure (if known)
- •Any known structural defects or previous alterations (underpinning, previous structural repairs)
- **Design assumptions and constraints**:
- •Architect's drawings and specifications as developed at the point of PCI issue
- •Any outstanding design elements
- •Planning conditions that affect the construction method
- •Building Control requirements confirmed to date
- **Site constraints**:
- •Access constraints — street width, parking, lorry access, skip placement
- •Proximity to underground railways or tunnels (particularly relevant in central and inner London — TfL guidelines may constrain excavation depth or vibration)
- •Boundary constraints — proximity to neighbouring structures, party walls, trees with TPOs
- •Hours of work restrictions (particularly in conservation areas, residential streets, or where planning conditions limit working hours)
Asbestos and the PCI: why this is the most critical item for pre-2000 properties
For any property built before 2000, asbestos is a potential concern that must be addressed in the PCI. Asbestos was used extensively in UK construction between the 1950s and its final ban in 1999:
- **Where asbestos may be found in a domestic property**:
- •Artex textured ceiling coatings (chrysotile asbestos — widely used up to 1985, still used in some formulations to late 1990s)
- •Sprayed coatings on ceilings, beams, or structural steel
- •Pipe lagging and boiler insulation (older properties with original heating)
- •Floor tiles and vinyl flooring adhesive (particularly 9-inch floor tiles from 1950s–1960s)
- •Asbestos cement roof sheets, soffits, and rainwater goods
- •Partition boards — AIB (Asbestos Insulating Board, sometimes sold as Supalux or Asbestolux)
- •Textured coatings on external walls (less common but present)
- **The duty to manage asbestos**:
- •For commercial premises, the duty to manage asbestos is well-established. For domestic premises, the position is different — there is no general legal duty on a homeowner to manage asbestos in their own home. However, where contractors are brought in to work on the property, the duty to protect the health of workers applies — and a contractor who disturbs asbestos unknowingly is at risk.
- **Management Survey vs. Refurbishment and Demolition Survey**:
- •A **Management Survey** (formerly Type 2) locates and identifies ACMs that could be disturbed during normal occupancy — suitable for an occupied property where no intrusive work is planned.
- •A **Refurbishment and Demolition Survey** (formerly Type 3) is required before any significant refurbishment or demolition work — it is more intrusive (opens up elements of the structure) and produces a comprehensive record of all ACMs likely to be disturbed. This is the appropriate survey type before a loft conversion, extension, or significant internal refurbishment.
- •**Artex testing**: If Artex ceilings are present and are likely to be disturbed (e.g., removed, drilled through, or textured over), an Artex sample test (£30–£60 per sample via an accredited laboratory) should be carried out before work begins.
**Practical obligation on the design team and principal contractor**: A well-prepared PCI for a pre-2000 London property should always include either a Refurbishment Survey report (if commissioned) or an explicit statement of the known asbestos position and any remaining uncertainties — with the Principal Contractor advised to implement a 'watch and act' protocol for any disturbance of suspected ACMs during the works.
Frequently Asked Questions
Who produces the Pre-Construction Information pack for a domestic extension?▼
Do I need an asbestos survey before a loft conversion?▼
Can the contractor proceed without a PCI?▼
Important Note
This guide is for general information only. Building regulations, planning rules, and legal requirements change regularly and vary by local authority. Always seek professional advice specific to your project and location. RCB Design & Build offers free initial consultations — book your free survey.