Understanding CDM Duties for Small Groundworks Firms

CDM Applies to You, Even When the Job Is Small

There is a stubborn myth in groundworks that health and safety paperwork is for the big boys — the main contractors with a full-time HSE manager and a portacabin full of files. Dig a few trenches for a house extension or a drainage connection, the thinking goes, and nobody expects much beyond a bit of common sense.

That is not how the Construction (Design and Management) Regulations 2015 work. CDM applies to every construction project in Great Britain, from a two-day soakaway to a multi-storey frame. What changes with size is the scale of what you must do, not whether you must do it. A small firm laying a new driveway has duties. A small firm digging a 2.5-metre trench for a sewer connection has duties that could genuinely save a life.

The good news is that most of it is proportionate, practical and already close to what a careful groundworker does by instinct. This is about making that instinct documented and defensible.

Work Out Which Hat You Are Wearing

CDM assigns roles, and on small jobs one person or firm often wears several at once. Get this clear before work starts, because your duties flow from it.

• Client — the person or organisation the project is for. Even a homeowner having an extension built is a client, though domestic clients pass most of their duties to the contractor.
• Principal designer and principal contractor — only required on projects with more than one contractor. On many small groundworks jobs, you are the only contractor, so these roles do not apply.
• Contractor — anyone who manages or carries out construction work. If you are digging, you are a contractor, and you must plan, manage and monitor the work.
• Designer — if you decide how something is built, or specify a trench support method, you are making design decisions and have designer duties too.

If there is more than one contractor on site — say a bricklayer and an electrician alongside you — the client must appoint a principal contractor in writing, and that could well be you. Do not assume it will be somebody else.

Is the Project Notifiable?

A project must be notified to the Health and Safety Executive using form F10 if construction work is expected to last more than 30 working days with more than 20 workers on site at the same time, or exceed 500 person-days of work. For most domestic groundworks, that threshold will not be crossed, and no F10 is needed.

Do not let that lull you. Notifiable or not, you still need a construction phase plan proportionate to the job. On a small domestic dig, that might be a couple of sides of A4 covering the sequence of work, the main risks, the control measures and who is responsible for what. The HSE is far more interested in whether your plan matches the reality on the ground than in how thick it is.

Risk Assessments That Actually Get Used

A downloaded template with a tick in every box is worse than useless — it gives you false comfort and gives an inspector nothing to trust. Write assessments that describe your site, your plant and your people.

For excavation work, the recurring hazards are well known and all of them are killers:

• Buried services — always obtain up-to-date service plans, use a cable avoidance tool and a safe digging technique, and hand-dig around any marked service.
• Collapse — any trench deeper than 1.2 metres needs support, battering back or another engineered solution. Never let anyone work in an unsupported trench, and never let spoil sit right at the edge.
• Falls and falling objects — barrier off every excavation, provide secure access, and keep plant well back from the edge.
• Plant and pedestrian movements — 360-degree excavators have significant blind spots. Keep a banksman in place and separate people from machines.
• Confined spaces and water — deep manholes, wet ground and pumped excavations can create atmospheric and drowning risks.

Review the assessment when conditions change. Rain overnight can turn a stable trench into a lethal one by morning, and a moment spent reassessing is cheaper than a rescue.

Site Induction and Briefings

Everyone who sets foot on your site should receive a short induction before they start. It does not need to be a formal presentation in a meeting room. Ten minutes at the site gate covering the following is enough:

• Where the hazards are, particularly open excavations and overhead or underground services.
• Site rules on PPE, plant movements and exclusion zones.
• Welfare arrangements and the location of the first aid kit and trained first aider.
• Who the site supervisor is and how to raise a concern without fear of being brushed aside.

Record it — a signed sheet with names, dates and a brief note of what was covered. Hold a short briefing at the start of each day, especially before any deep dig. A worker who has been told what to look for is far more likely to stop and speak up.

Welfare Provision: Non-Negotiable Basics

Welfare is a duty from the first day, no matter how short the job. Workers must have access to:

• Toilets — including on domestic jobs, where you need an arrangement agreed with the householder or a hired unit.
• Washing facilities — with soap and warm water, or hot water on tap. Groundworkers handle fuel, concrete and contaminated soil, and skin conditions are a real occupational hazard.
• Drinking water — readily accessible.
• Somewhere to change and dry wet clothing, plus a rest area with protection from the weather and a means of heating food.

On a single-day job these can sometimes be modest, but they cannot be absent. Cold, wet, hungry groundworkers make mistakes, and mistakes in an excavation are the ones that hurt.

None of this is bureaucracy for its own sake. It is a handful of sensible habits, written down, that protect your crew, keep you on the right side of the law, and mark you out as a firm that larger contractors will happily put on their supply chain.