Episode 155 - Health & Safety File

This week we will be talking about the Health & Safety File. This episode content meets PC5 - Building Procurement of the Part 3 Criteria.

Resources from today's episode:

Websites:

• https://www.thenbs.com/knowledge/what-is-the-health-and-safety-file
• https://www.hse.gov.uk/pubns/priced/l153.pdf

Thank you for listening! Please follow me on Instagram @part3withme for weekly content and updates or contact me via email me at part3withme@outlook.com or on LinkedIn. 

Join me next week for more Part3 With Me time.

If you liked this episode please give it a rating to help reach more fellow Part3er's!

Transcript

Episode 155:

Hello and Welcome to the Part3 with me podcast. 

The show that helps part 3 students jump-start into their careers as qualified architects and also provides refresher episodes for practising architects. I am your host Maria Skoutari and this week we will be covering the Health & Safety File. Todays episode meets PC5 of the Part 3 Criteria.

Make sure to stay until the end for todays scenario

I very briefly outline the key contents of the Health and Safety File back in episode 4, but given the importance of such a document, I thought I would create a dedicated episode for it to help you better understand its contents, why its required, when it is required and who compiles it and when. 

Let’s start by outlining What the Health and Safety File actually is:

According to the Health & Safety Executive, the health and safety file is defined as a file appropriate to the characteristics of the project, containing relevant health and safety information to be taken into account during any subsequent project. It serves as a legal record, befitting both the client and end user. The file is required as part of the Construction, Design, and Management Regulations 2015 and it forms part of a projects overall health and safety management system required by the Management of Health and Safety at Work Regulations 1999. It covers all relevant aspects of health and safety, ensuring that the welfare of people are at the core of the project and resulting asset.

The file is only required for projects involving more than one contractor. Although, in my experience I have seen projects with one contractor also provide a Health & Safety file, more as a good practice due diligence items more than a mandatory requirement.

The file must contain information about the current project likely to be needed to ensure health and safety during any subsequent work, such as maintenance, cleaning, refurbishment or demolition. 

What information is required to be included within a Health & Safety File:

• a brief description of the work carried out; 
• any hazards that have not been eliminated through the design and construction processes, and how they have been addressed; 
• key structural principles and safe working loads for floors and roofs; 
• hazardous materials used (eg lead paints and special coatings); 
• information regarding the removal or dismantling of installed plant and equipment (eg any special arrangements for lifting such 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, fire-fighting services etc; 
• information and as-built drawings of the building, its plant and equipment (eg the means of safe access to and from service voids and fire doors). 

The file should provide enough detail to allow the likely risks to be identified and addressed by those carrying out the work and the level of detail should be proportionate to the risks. 

The file should not include things that will be of no help when planning future construction work such as: 

• Pre-construction information or the construction phase plan
• Construction phase risk assessments, written systems of work and COSHH assessments which were adopted during the project
• Details about the normal operation of the completed structure
• Construction phase accident statistics 
• Contractual documents
• Safety method statements and so on.

Information must be in a convenient form, clear, concise and easily understandable. It can be in paper form or electronic form. Where the file is kept electronically, suitable back-up arrangements must be in place. The level of detail of the file must be in proportion with the risks involved, and the degree of effort and resources expended to compile the health and safety file must also be proportionate to the risks in the project.

The key benefits of a well prepared Health and Safety File is that it can significantly benefit clients by:

• Providing crucial information for future works
• Reducing costs associated with future projects
• Ensuring compliance with the CDM Regulations 2015
• Enhancing safety for future workers on the site or structure 

So who is responsible for the Health and Safety file and what are the various parties roles:

At the highest level, CDM Regulations place responsibility for producing a health and safety file with the principal designer. If the principal designer's appointment ends before the end of the project, the responsibility passes to the principal contractor. Once the project is complete, the file is passed to the client. However, health and safety should always be treated as a wider team effort, with everyone feeding into it where appropriate. Health and safety should never be considered ‘someone else’s responsibility’.

As such, the client:

Must ensure that the principal designer prepares the health and safety file for a project. As the project progresses, the client must ensure that the principal designer regularly updates, reviews and revises the health and safety file to take account of the work and any changes that have occurred. The client should also be aware that if the principal designer’s appointment finishes before the end of the project, the principal designer must pass the health and safety file to the principal contractor, who then must take on the responsibility for the file as previously mentioned. 

Once the project is finished, the client should expect the principal designer to pass them the health and safety file. In cases where the principal designer has left the project before it finishes, it will be for the principal contractor to pass the file to the client. 

The client must then retain the file and ensure it is available to anyone who may need it for as long as it is relevant, which is normally the lifetime of the building, to enable them to comply with health and safety requirements during any subsequent projects. It can be kept electronically, on paper, on film, or any other durable form. 

If a client disposes of their interest in the building, they must give the file to the individual or organisation who takes on the client duties and ensure that the new client is aware of the nature and purpose of the file. If they sell part of a building, any relevant information in the file must be passed or copied to the new owner. If the client leases out all or part of the building, arrangements should be made for the file to be made available to leaseholders. If the leaseholder acts as a client for a future construction project, the leaseholder and the original client must arrange for the file to be made available to the new principal designer. 

Now in terms of the Principal Designers responsibilities:

As mentioned, the principal designer must prepare the health and safety file and they are accountable to the client and should liaise closely to agree the structure and content of the file as soon as practicable after appointment. In preparing the file, the principal designer should expect the client to provide any health and safety file that may exist from an earlier project. 

The principal designer is also expected cooperate with the rest of the project team and should expect their cooperation in return. Cooperation with the principal contractor is particularly important in agreeing the structure and content of the information included in the file. Liaison with designers and other contractors is also important. They may hold information that is useful for the health and safety file, which may be difficult to obtain after they have left the project. Additionally, the principal designer, in cooperation with other members of the project team, must also ensure that the file is appropriately updated, reviewed and revised to ensure it takes account of any changes that occur as the project progresses. 

Then, the principal designer must pass the updated file to the client at the end of the project. In doing this, they should ensure the client understands the structure and content of the file and its significance for any subsequent project. If the principal designer’s appointment finishes before the end of the project, they must pass the file to the principal contractor who must then take on responsibility for it as again previously mentioned. In doing this, the principal designer should ensure the principal contractor is aware of any outstanding issues that may need to be taken into account when reviewing, updating and revising the file. 

Now in terms of the Principal Contractors responsibilities:

For the duration of the principal designer’s appointment, the principal contractor plays a secondary role in ensuring the health and safety file is fit for purpose. They must provide the principal designer with any relevant information that needs to be included in the health and safety file. 

Where the principal designer’s appointment finishes before the end of the project, the principal contractor must take on responsibility for ensuring that the file is reviewed, updated and revised for the remainder of the project. At the end of the project the principal contractor must then pass the file to the client. In doing this, they should ensure the client understands the structure and content of the file and its significance for any subsequent project. 

In addition to the client, Principal Designer and Principal Contractor, Designers and also have responsibilities when it comes to compiling the information for the Health & Safety File:

Designers, where it is not possible to eliminate health and safety risks when preparing or modifying designs, they must ensure appropriate information is included in the health and safety file about the reasonably practicable steps they have taken to reduce or control those risks. This will involve liaising with: 

• the principal designer, in helping them carry out their duty to prepare, update, review and revise the health and safety file. This should continue for as long as the principal designer’s appointment on the project lasts; or 
• the principal contractor, where design work is carried out after the principal designer’s appointment has finished and where changes need to be made to the health and safety file. In these circumstances, it will be the principal contractor’s duty to make those changes, but the designer must ensure that the principal contractor has the appropriate information to update the file.

This information should be provided to the principal designer and principal contractor as early as possible before the designer’s work ends on the project. 

Now in terms of Contractors, they have no specific duties placed on them in relation to the health and safety file. 

So when should the Health and Safety File be produced:

It is recommended that the file should be produced as soon as possible, the earlier the information is compiled and shared, the better the decisions made and the fewer risks of duplication or the need for rework. Drawings and other documents are a crucial source of data, providing information on proposed construction methods, product choices and even the thought processes around how an asset will be used. This is also where hazards are discovered, such as lead, contaminated land, asbestos and any services or nearby activities that could affect the work.

The Health & Safety file as mentioned, is handed to the client at the end of a project as part of the Practical Completion process.  

To sum up what I discussed today:

• The Health and Safety File is a legal document required under the CDM Regulations 2015 and Management of Health and Safety at Work Regulations 1999.  It covers all relevant aspects of health and safety, ensuring that the welfare of people are at the core of the project and resulting asset.
• The file should be concise, clear, and proportionate to project risks, avoiding unnecessary documents like contractual agreements or accident statistics. It can be paper-based or electronic (with backup systems) and must be reviewed and updated regularly throughout the project to reflect changes.
• The Principal Designer is responsible for compiling and maintaining the file. If the Principal Designer leaves before project completion, the Principal Contractor takes over and the Client must ensure the file is updated, retained, and transferred if ownership of the building changes.