Construction Phase Plan: What HSA and HSE Inspectors Check

A construction phase plan reads differently depending on which side of the Irish Sea the site sits. In the UK, the Principal Contractor writes it under Regulation 12 of CDM 2015 and the Health and Safety Executive is the body that audits it. In Ireland, the Project Supervisor Construction Stage develops it under Regulation 16 of the Construction Regulations 2013, and the Health and Safety Authority checks it instead. The two documents share a common ancestor and a similar shape, but the duty holder, the notification test and the schedule numbers an inspector will actually quote are not the same.

We write and review construction phase plans for tier-one contractors and engineering clients on both sides of the border, and the gaps we find during a site safety audit are rarely about writing quality. They are almost always about which jurisdiction’s rules the plan was written against, and whether anybody checked that match before the site opened.

What a Construction Phase Plan Actually Covers

In the UK, Regulation 12(2) of CDM 2015 requires the construction phase plan to set out the health and safety arrangements and site rules for the project, and to include specific measures for any work falling into one or more of the 10 categories in Schedule 3, ranging from aggravated falls from height and engulfment risk through to work with explosives and the assembly of heavy prefabricated components. The Principal Designer feeds in pre-construction information so the plan is grounded in what is already known about the site, not written from a blank page.

In Ireland, the equivalent document sits in Regulation 16 of the Construction Regulations 2013. The PSCS develops what the Regulation calls “the plan” from the preliminary safety and health plan the PSDP prepared at design stage, adjusts it as the job progresses, and includes specific measures for any work carrying a particular risk under Schedule 1, which lists the same 10 categories as the UK’s Schedule 3, just numbered differently. Practitioners commonly call this the Construction Safety Plan, though the Regulations themselves never use that exact phrase.

Who Writes It and When It Has to Be Ready

The duty holder is not interchangeable between jurisdictions, and getting this wrong is one of the most common mistakes we see on cross-border projects.

In the UK, the Principal Contractor draws up the construction phase plan, or arranges for someone to draw it up, during the pre-construction phase and before the construction site is set up. On a single-contractor project, that duty falls to the contractor directly. The plan then has to stay current: Regulation 12(4) requires it to be reviewed, updated and revised throughout the project so that it continues to reduce risk so far as is reasonably practicable.

In Ireland, the client appoints the PSCS in writing before construction work commences, under Regulation 6(3)(b). The PSCS then develops the safety and health plan from the PSDP’s preliminary version, and Regulation 16(b) requires adjustments to reflect the progress of the work and any changes that occur. Appointing the PSCS late, or only verbally, is not something that can be fixed after the fact, a point our PSCS guide covers in more depth, alongside the parallel duties the PSDP carries under the Regulations, which our PSDP guide sets out separately.

When a Project Becomes Notifiable

Both jurisdictions set a notification duty, but the test is not identical, and the difference catches contractors who assume the rules translate directly.

Regulation 6 of CDM 2015 makes a UK project notifiable where construction work is scheduled to last longer than 30 working days and have more than 20 workers working simultaneously at any point, or where the volume is scheduled to exceed 500 person days. Where either limb is met, the client gives written notice to the Health and Safety Executive, commonly called the F10 notification, as soon as is practicable before the construction phase begins. The notice contains the particulars listed in Schedule 1 and has to be displayed on site.

Ireland’s test, under Regulation 10 of the Construction Regulations 2013, drops the worker count entirely: a project is notifiable where work is planned to last longer than 30 working days or the volume is scheduled to exceed 500 person days. The client gives that notice to the Health and Safety Authority. A second, separate duty then falls on the PSCS under Regulation 22, which requires its own written notice before work begins, containing the particulars in Schedule 3, displayed on the construction site and kept current. Both jurisdictions require 2 separate notices, and the worker-count condition exists on only one side of the border.

What HSA and HSE Inspectors Actually Check

An inspector reading a construction phase plan is not grading the prose. They are checking whether the document still matches the site in front of them.

The questions that come up most often at audit are consistent across both jurisdictions. Has the plan been updated since the last significant change on site, or does it still read like the day the job mobilised? Does it include specific measures for every particular risk category that is actually present, rather than a boilerplate reference to Schedule 1 or Schedule 3 with nothing underneath it? Are the site rules written down and genuinely brought to the attention of every contractor, not just filed in an office drawer? And where a notice is required, is it the current version, displayed where a worker engaged in the work can actually read it?

We have found the same category of gap on a live Irish site before: a duplicate PSCS appointment that broke the statutory chain of accountability, resolved through a managed stakeholder process inside a week. The plan itself can be well written and still fail if the appointment underneath it was never valid.

The plan that never changed

The single most common finding on both sides of the border is a plan that has not moved since mobilisation. A construction programme changes constantly, new subcontractors arrive, sequencing shifts, a particular risk activity that was not scoped at tender turns up in month 4, and the plan has to track all of it. Regulation 12(4) in the UK and Regulation 16(b) in Ireland both put that obligation on the duty holder directly, and an inspector who finds a static plan against a visibly changed site treats it as a live finding, not a paperwork technicality.

The mismatched jurisdiction

The second recurring failure is a plan written against the wrong country’s Regulations, usually because a template or a previous project’s document was reused across the border without being rebuilt. The citations do not carry across: a UK plan that references Schedule 3 particular risks and the Principal Contractor will not satisfy an HSA inspector looking for Schedule 1 and a PSCS appointment, and the reverse is equally true. Our guide to writing a RAMS document covers the same cross-border citation trap in more detail, because it affects risk assessments and method statements just as much as the plan that sits above them.

Getting the Plan Right for the Site You Are Actually On

A construction phase plan only works if it was written for the jurisdiction, the duty holder and the actual conditions on the site it covers. That means confirming early who owns the duty, UK Principal Contractor or Irish PSCS, checking which notification test applies and whether either threshold has been crossed, naming every particular risk category genuinely present rather than copying a Schedule reference, and treating the plan as a live document that changes every time the site does. The same discipline applies whether the build is a conventional site, an engineering fit-out, or a hyperscale data centre build, where the schedule pressure and the MEP density make an out-of-date plan even easier to miss.

We produce and review construction phase plans as part of our CDM advisory work in the UK and our PSCS advisory work in Ireland, chartered-authored for the jurisdiction the site actually sits in. If you want a plan tested against the regulations an inspector will actually quote, book a construction safety audit and we will start with the duty-holder chain.