The health and safety file holds the information somebody will need to work on a building safely in future: to maintain it, clean it, alter it or demolish it. Under Regulation 12 of CDM 2015, the principal designer prepares it and keeps it up to date, the principal contractor feeds information into it, and at the end of the project it passes to the client, who must keep it available. It is only required on projects with more than one contractor.
Most clients receive the file at handover, store it, and never think about it again. That is where it fails.
What the regulations say
12(5): during the pre-construction phase, the principal designer must prepare a health and safety file appropriate to the characteristics of the project, containing the information likely to be needed during any subsequent project to ensure the health and safety of any person.
12(6): the principal designer must review, update and revise it to take account of the work and any changes.
12(7): during the project, the principal contractor must give the principal designer any information it holds that is relevant to the file.
12(8) and (9): if the principal designer's appointment ends early, the file passes to the principal contractor, who must keep it up to date.
12(10): at the end of the project the principal designer, or the principal contractor if there is no principal designer, passes the file to the client.
The client's side is in Regulation 4. The client must make sure the file is prepared, revised as new information arrives, and kept available for inspection by anybody who needs it to comply with the law (4(5)(b)). If the client sells their interest in the building, they must give the file to the buyer and make sure the buyer understands what it is for (4(7)).
What goes in it
HSE's guidance (L153) lists what should be considered:
a brief description of the work carried out;
hazards that were not eliminated through design and construction, and how they were addressed, such as asbestos or contaminated land;
key structural principles, such as bracing and sources of stored energy, and safe working loads for floors and roofs;
hazardous materials used, such as lead paints and special coatings;
how to remove or dismantle installed plant and equipment;
health and safety information about equipment provided for cleaning or maintaining the structure;
the nature, location and markings of significant services, including underground cables, gas supply equipment and fire-fighting services;
information and as-built drawings of the building, its plant and equipment, such as safe access to service voids and the location of fire doors.
What stays out
The file is not an archive of the project. L153 says it should not include things that will not help plan future work, such as the pre-construction information, the construction phase plan, contract documents or method statements. The detail should be proportionate to the risks, and the file should be clear, concise and easy to understand.
Where files go wrong
The commonest failure is the gap between the drawings and the building that was actually handed over. Changes made on site, and especially the changes made to close snags, are exactly what the next maintenance team needs to know: a swapped fixing, a different product, a rerouted cable, a ceiling opened and closed again. If they stay in a snag spreadsheet, the client receives a file that describes the building as drawn.
The second failure is after handover. Files get archived, lost in a system change, or never updated when the building changes. L153 says the client should keep the file for as long as it is relevant, normally the lifetime of the building, in any durable form, electronic or paper.
Who does what
Client: makes sure the file is prepared and updated, keeps it available after handover, and passes it on if the building is sold. Where part of a building is leased, the file should be made available to the leaseholders.
Principal designer: prepares it, agrees its structure with the client and the principal contractor, keeps it updated, and hands it over at the end.
Designers: provide information about the risks they could not design out.
Principal contractor: passes on relevant information throughout, and takes the file over if the principal designer leaves early.
Other contractors: no specific duties for the file, though what they know usually reaches it through the principal contractor.
Common questions
Is a health and safety file needed on a single contractor project?
No. HSE's guidance says the file is only required for projects involving more than one contractor.
Should the construction phase plan or the RAMS go in it?
No. They describe how this project was run. The file is for whoever works on the building next.
Who holds it after handover?
The client, for as long as it is relevant, and it goes with the building if the building is sold.
Our free snagging and handover checklist includes four checks before the file goes to the client. Related: pre-construction information under CDM 2015 and the golden thread is a client duty.
This article is general information, not legal advice.