Planned Preventative Maintenance and CDM 2015
- Paul Scanlon
- Jul 30
- 1 min read
The client called it "planned preventative maintenance." CDM 2015 called it construction work. HSE agreed.
This is an anonymised account of how scope creep created a significant compliance gap.
A facilities management team commissioned a programme of maintenance works across a four-storey occupied office building. The scope included mechanical and electrical servicing, fabric repairs, and common area redecoration. Multiple contractors were engaged over a rolling programme.
The FM team did not consider a formal CDM structure. The word "maintenance" made it feel routine.
Within three weeks of works starting, the programme was clearly meeting the definition of a notifiable project: more than 20 workers on site simultaneously across different contractors, and a programme exceeding 30 working days.
No F10 had been submitted. No Construction Phase Plan had been prepared. An HSE improvement notice was issued to the client organisation — not the FM contractor — for failure to put in place the required CDM structure before construction work began.
The lesson is straightforward: CDM 2015 applies to construction work, not just construction projects. Maintenance programmes that involve multiple contractors, physical intervention in the building fabric, or work in occupied buildings are construction work. Scale and framing do not change that.
If you manage a property portfolio with a rolling maintenance programme, your CDM position is worth a proper review.
Get your free Client Guide to CDM 2015 here: cdm2015.co.uk/resource-download
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