Almost every other document produced on a construction project is for the people building it. The health and safety file is the exception: it is written for whoever comes next, possibly decades later, to clean the windows, replace the plant, alter the layout or take the building down.
That single fact settles most questions about what belongs in it.
When one is required
CDM 2015 regulation 12 requires a health and safety file for any project involving more than one contractor. The principal designer prepares it, reviews and updates it as the project progresses, and passes it to the client at the end of the project. Where the principal designer's appointment finishes before the end of the project, the principal contractor takes over completion and hand-over.
Where there is only one contractor, no file is required — though where the work leaves behind information a future worker would need, providing it anyway is sensible. On projects where a file already exists for the structure, the duty is to update it rather than create a second one.
What goes in it
Appendix 4 of HSE's L153 guidance sets out what the file should contain, and the theme throughout is information about residual risk that would not be obvious to a competent person arriving later.
- A brief description of the work carried out.
- Residual hazards and how they have been dealt with — contaminated land, buried services, asbestos left in place and managed, structures containing hazardous materials.
- Key structural principles: bracing, sources of substantial stored energy such as pre- or post-tensioned elements, and safe working loads for floors and roofs, particularly where they might preclude a future alteration.
- Hazardous materials used, including lead paint, specific pesticides and any special coatings.
- Information on the removal or dismantling of installed plant and equipment.
- Health and safety information about equipment provided for cleaning or maintaining the structure — anchor points, mansafe systems, access provisions.
- The nature, location and markings of significant services, including fire-fighting services and underground cables and pipework.
- As-built drawings and plans used and produced throughout the construction process, with the specifications of the building and its plant.
What stays out
The file is not the project archive. Explicitly, it should not contain the construction phase plan, the pre-construction information, RAMS, contractual documents, safety method statements, general risk assessments, or details of standard construction practice that any competent contractor would already know.
The reason is usability. A file that runs to forty lever-arch files of everything the project produced will not be read by a maintenance contractor with a job to do on a Tuesday morning — which means the one page that mattered, the location of the asbestos left in place, might as well not be there. Concise and navigable beats comprehensive.
This is the clearest practical distinction between the file and the working documents of a project: RAMS record how the work was carried out and belong to the project record, while the file records what the work left behind. Construction phase plan versus RAMS covers the other end of the same hierarchy.
Compiling it as you go
The most common failure is leaving the file until completion week, when the specialist subcontractors have demobilised, the designers have moved on, and nobody can produce the as-built information for a system installed nine months ago. By then the file gets assembled from whatever can be found, which is how files end up full of generic product literature and short on the specific information they exist to carry.
- Establish the file structure at the start and tell every designer and contractor what they will be asked for and when.
- Make file information a contractual deliverable in each package, tied to payment where possible.
- Collect at the end of each package rather than the end of the project.
- Review at each design and progress review: has anything changed that a future maintainer would need to know?
- Hand over at project completion, with the client confirming receipt in writing.
The client's ongoing duty
Once handed over, the client must keep the file available for inspection by anyone who needs it to comply with health and safety law, and must revise it if further information becomes available. If the structure is sold, the file passes to the new owner, who then carries the same duty. If it is sold in parts, the relevant information goes with each part.
The practical consequence for a contractor is that the file you contribute to may be read by somebody in twenty years' time who has no other source of information about what is behind that wall. Vague entries are not neutral; they are a hazard passed forward.
Format and retention
Electronic files are normal and are easier to search, update and pass on than paper, provided the formats will still open in a decade — searchable PDF rather than a proprietary model format, or both. Index it so a specific item can be found in under a minute, and make sure drawings are legible at the size they will actually be printed.
There is no fixed statutory retention period for the file; the duty is to keep it available for as long as the structure exists. That is a longer horizon than most document retention policies contemplate, which is worth checking against your own — our own approach to keeping and deleting documents is set out in what happens to documents after 90 days, and the file is precisely the kind of record that belongs with the client's permanent records rather than a contractor's working system.
Practically, the file also has commercial value: a good one shortens the pre-construction information pack for the next project on that structure, as described in pre-construction information. A bad one means the next team starts by surveying what somebody already knew.
This article is general guidance on UK construction documentation practice. It is not legal advice, a compliance certification or a substitute for review by your own qualified health and safety personnel, who remain responsible for deciding whether any particular document is adequate. See our disclaimer.