by Richard McPartland
What is the Health and Safety File?
Simply put, the Health and Safety File is a repository of health and safety information and serves as a legal record that will be of use to both clients and end users.
Why is a Health and Safety File required?
The Construction, Design and Management (CDM) Regulations exist to ensure that information about risks and hazards are collected, a response developed to manage these appropriately, and this response is then communicated to all who need to know.
Where are requirements for the Health and Safety File established?
On a BIM project the Employers Information Requirements (EIR) forms part of the appointment and tender document and the EIR should clearly outline client requirements - what's required, when, and in how much detail.
A section of the EIR focuses on the management of health and safety / CDM and it is here that a client can set out any requirements for BIM-supported health and safety management that it wishes bidders to address. Preferences as to the format of the file can also be set out in the EIR.
Who is responsible for the Health and Safety File?
Under the CDM Regulations responsibility for producing a Health and Safety File is placed on the Principal Designer.
If the Principal Designer's tenure finishes before the end of the project then the Principal Contractor should be in receipt of, and take responsibility for, the Health and Safety File. The file is, ultimately, passed to the client who must ensure it is readily available to all who need it.
If a building is sold then the client must ensure that the file is made available to the new owner.
When areas of the building are leased then leaseholders must have access to the file. If a leaseholder becomes client on a future construction project, then the file must be made available to the Principal Designer for the newly commissioned project.
What roles and responsibilities do specific members of the project team have?
The client must ensure that the Principal Designer produces that file and, as a project progresses, ensure that the file is regularly updated, reviewed and revised.
The client should retain the file and provide access to it for as long as required and ensure, if they sell the building, that the file passes to new owners.
The designer should seek to eliminate health and safety risks through design and, where this is not possible, control or reduce them. To this end, the designer will be required to closely liaise with the Principal Designer (and/or the Principal Contractor) in helping them produce the Health and Safety File.
The Principal Designer
The Principal Designer is responsible for preparing the Health and Safety File and is ultimately accountable to the client. To this end, the Principal Designer should agree, as soon as possible after appointment, the structure and format of the file.
The Principal Designer acts as a coordinator - soliciting contributions to the file from the wider project team, particularly the Principal Contractor.
The Principal Designer also has responsibilities to review and revise the information to ensure it is kept up-to-date as a project progresses.
The Principal Contractor
The Principal Contractor will supply appropriate information to the Principal Designer for inclusion in the file. If the Principal Designer's role finishes before the project does then the Principal Contractor will take on responsibility for the Health and Safety File and passing it over to the client. The Contractor has no duties, under CDM, in relation to the Health and Safety File.
If the Principal Designer's role finishes before the project does then the Principal Contractor will take on responsibility for the Health and Safety File and passing it over to the client.
The Contractor has no duties, under CDM, in relation to the Health and Safety File.
When should the Health and Safety File be produced?
Health and safety should be really considered throughout the project lifecycle - the earlier the information is compiled and shared, the better decisions that can be made by the disciplines that come together to work on the project, avoiding duplication and the need for reworking down the line.
Considering health and safety requirements in the context of your digital information model from the start is time well spent. Appropriately tagged information can be input once and then used throughout a project. Indeed, it's feasible that, if designed correctly from the start, the Health and Safety File can be just an output of the model, generated by a user requesting a particular 'view' of the information contained within.
What should be included?
CDM Regulation 12 (5) states that the file should be 'appropriate to the characteristics of the project'. In other words, it should contain a sufficient depth and breadth of health and safety information to allow maintenance, cleaning, alterations, refurbishment or demolition to be carried out safely.
Typically the file will contain information on the work being carried out, hazards that have not been eliminated through the design and construction phases and how these have been addressed.
Background information on the structure and form of the building and any limitations - safe working loads for floors and roofs, or the location of utility services, for example - will also be included.
The file can also usefully note any hazardous materials used (paints and coatings, for example) that will prove useful when maintaining or removing these substances or working in affected areas of the structure.
Information, including drawings, of the building as built, including safe means of access to service areas should also be included.
What should not be included?
All information contained within the file should be of use when planning future construction work. Extraneous information, such as that relating to pre-construction, or operation and maintenance, is not required and will serve only to create an additional maintenance burden.
Do I still need an Operation and Maintenance (O&M) Manual?
Traditionally the Health and Safety File and Operation and Maintenance Manual have been distinct, often produced by two different people, meaning that the potential for collaboration and appropriate cross linking has been lost. By creating a digital information model it is possible to beneficially combine, link and integrate both.
What format should the Health and Safety File take?
The CDM Regulations don't dictate a particular file format for the Health and Safety File.
Under the regulations the client is expected to provide easy access to the information, allowing it to be easily retrieved by whoever needs it, for so long as the building exists. There are a number of ways a file could be produced in a reasonably durable format - on paper, on film or electronically.
Regardless of which format you use it is important that any reference in the CDM 2015 regulations to a plan, rule, document, report or copy should include reference to a 'physical' or an electronic copy somewhere. The aim being that you can retrieve or reproduce information when required and have mitigated against the effects of loss or unauthorised interference.
Should I consider a digital health and safety file?
Traditionally the file was produced (and given to the client) as a series of paper-based lever-arch files. This format didn't lend itself to easy interrogation or sharing. They also proved difficult to manage - easily being lost or damaged, succumbing to general wear and tear or environmental damage.
In more recent years information has increasingly been created on computers but then printed out. The problem with this approach is that information then immediately dates and falls out of step with the electronic copy creating a maintenance burden for both paper and electronic versions. Users can often find it hard to tell whether they are reading the most up-to-date versions of documents. A digital-only version, stored and shared in a Common Data Environment (CDE) can serve as a single source of truth, or at least be more clearly version controlled.
However hard you try and avoid it you're likely to encounter many instances where printed information on paper is supplied to the Principal Designer for inclusion in the Health and Safety File. Early engagement with the supply chain should manage expectations in this regard. If paper cannot be avoided then it should ideally be scanned to allow it to be stored alongside the other digital information on your project. You should consider whether scans of information which effectively create images regardless of content (text being unsearchable and editable) are appropriate or whether to use Optical Character Recognition (OCR) software to translate paper documents into machine-readable data - the benefits being such documents are searchable and editable making retrieval much easier.
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