CDM Regulations and Demolition: Principal Contractor Duties, F10 Notification and Construction Phase Plan

Summary

CDM 2015 replaced the earlier CDM 2007 Regulations and introduced significant changes to how duty holder roles are structured. For demolition projects, the regulations impose duties at every level: on the client who commissions the work, on the Principal Designer who coordinates design-phase hazard management, and on the Principal Contractor who takes primary responsibility for health and safety during the construction (demolition) phase.

Demolition is explicitly defined as construction work under CDM 2015. This means there is no exemption for demolition projects — the regulations apply from the first stage of planning. Even where a project falls below the threshold for F10 notification, CDM duties still apply. A client who commissions demolition work retains legal duties whether or not they appoint duty holders, and those duties default to them if no appointment is made.

The Health and Safety Executive (HSE) takes a particular interest in demolition given its historically elevated fatality and serious injury rate compared with other construction activities. HSE enforcement activity on demolition sites is disproportionately high relative to the sector's size, and inspectors will check for F10 registration, Construction Phase Plans, and evidence that competent contractors have been appointed. Getting CDM documentation right is not just about compliance — it is the primary mechanism by which demolition contractors demonstrate that hazards have been identified and controlled.

Key Facts

• CDM 2015 notification threshold — projects lasting more than 30 working days with more than 20 workers simultaneously, OR projects exceeding 500 person-days of construction work, must be notified to HSE via the F10 form
• Demolition is always construction work — there is no minimum size or complexity threshold below which CDM 2015 does not apply; even a single-contractor demolition job carries CDM duties
• Principal Contractor appointment — where more than one contractor is involved in a project, the client must appoint a Principal Contractor in writing before the construction phase begins
• Principal Designer appointment — must be made in writing; the Principal Designer must be an organisation or individual with design skills and influence over design decisions, not simply a health and safety consultant
• Construction Phase Plan (CPP) — must be prepared by the Principal Contractor before the construction phase starts; must be project-specific and cover demolition-specific risks
• Pre-construction information — the client must provide all pre-construction information they hold to designers and contractors; for demolition this includes structural surveys, asbestos reports, services information and any previous building records
• F10 notification — submitted online via the HSE's F10 portal; must be submitted before the construction phase begins; the Principal Contractor must display a copy of the acknowledgement notice on site
• Health and Safety File — the Principal Designer must compile and hand over a Health and Safety File at project completion; for demolition this covers residual risks from any retained structures or infrastructure
• Domestic clients — can transfer their CDM duties to the Principal Contractor or contractor by written agreement; this does not remove the duties but shifts responsibility
• HSE enforcement powers — inspectors can issue Improvement Notices, Prohibition Notices and pursue prosecution; fatalities or serious injuries on demolition sites routinely trigger formal investigations
• Welfare facilities — CDM 2015 Schedule 2 specifies minimum welfare requirements; the Principal Contractor is responsible for ensuring these are provided from the first day of work
• Competence requirement — CDM 2015 requires that anyone appointed to a duty holder role must have the skills, knowledge, experience and (for organisations) the organisational capability to carry out their duties
• Method Statement requirement — not explicitly named in CDM 2015 but required in practice; the Construction Phase Plan should reference or incorporate method statements for high-risk demolition activities
• Coordination with designers — if any elements of the structure are being retained or altered, the Principal Designer must coordinate with structural engineers to manage residual design risks

Quick Reference Table

Detailed Guidance

Who Needs to Be Notified: Understanding the F10 Threshold

The F10 notification threshold catches more demolition projects than contractors sometimes expect. The 500 person-days figure is the key metric for most demolition work. A project involving 10 operatives working full time for 10 weeks (50 working days) reaches 500 person-days. At that scale, F10 notification is mandatory.

The "30 working days with 20+ workers simultaneously" limb is less commonly the trigger for demolition, but can apply to large-scale projects with site establishment periods. Working days includes days when any construction activity takes place, not just days when demolition specifically occurs.

Submit the F10 notification online via the HSE portal before the construction phase begins. There is no fee. You must notify before you start, not on the first day. If the project is already notifiable when you receive the contract, factor F10 submission into your mobilisation programme. The acknowledgement notice must be displayed at the site office or site entrance, visible to anyone entering the site.

For projects below the F10 threshold, you do not notify HSE, but CDM duties still apply in full. A Construction Phase Plan is still required where there is more than one contractor on site. Even on single-contractor demolition jobs, the contractor must have arrangements for managing health and safety that are proportionate to the risks.

What the Construction Phase Plan Must Cover

The Construction Phase Plan (CPP) is not a generic H&S policy document — it must be specific to the project. For demolition work, the CPP should cover:

Project description and programme — a description of the demolition works, the programme of activities, and the sequence in which demolition will proceed. For complex demolition, this should reference or incorporate the Method Statement and, where relevant, a Structural Engineer's scheme of works.

Site management and organisation — who is the site manager, how will day-to-day supervision be organised, what are the lines of communication between the Principal Contractor and sub-contractors.

Key hazards and controls — for demolition, this must address structural instability risks, asbestos (cross-referencing the asbestos management survey and Refurbishment and Demolition Survey), services disconnection, dust and noise, fire risk, falling objects, and any specific hazards arising from the nature of the structure (contamination, stored materials, live services in adjacent structures).

Emergency procedures — how to raise the alarm, evacuation routes, first aid provision, nearest A&E, and procedures for structural collapse or partial collapse emergencies.

Traffic management — routes for demolition plant, skip lorries and general site vehicles; pedestrian segregation; interface with public roads and any temporary road closures.

Welfare facilities — location and specification of welfare facilities; arrangements for maintenance.

Induction and training — what project induction will cover; any additional training required for specific demolition activities.

The CPP is a live document. It should be updated as the project progresses, particularly if the demolition sequence changes or new hazards are identified.

Principal Contractor Duties in Detail

The Principal Contractor (PC) carries the heaviest CDM burden during the demolition phase. Key duties include:

Planning and managing the construction phase — the PC must plan work in sufficient detail to allow hazards to be identified and controlled before work begins. For demolition, this typically means commissioning a structural survey, reviewing pre-construction information from the client, and developing a detailed method statement in conjunction with a structural engineer where required.

Coordinating contractors — where multiple contractors (demolition sub-contractors, asbestos removal contractors, scaffold erectors, waste hauliers) work on the same site, the PC must coordinate their activities to prevent conflicts and ensure that one contractor's activities do not create risks for another.

Site rules — the PC must establish site rules and ensure all contractors and workers are aware of them. Site induction is the standard mechanism. Demolition site rules typically cover exclusion zones, hard hat and PPE requirements, ground conditions (particularly where demolition is affecting foundations), and emergency procedures.

Liaison with Principal Designer — during the construction phase, the PC must share any information that affects the Health and Safety File, including as-built surveys, residual hazard information, and changes to the structure relative to original drawings.

Consulting and involving workers — CDM 2015 requires the PC to consult workers on matters that affect their health and safety. This does not require a formal committee but must be a genuine consultation rather than one-way communication.

CDM for Domestic Demolition Projects

Domestic clients — people having work done on their own home — have lighter CDM duties than commercial clients, but the regulations still apply. A homeowner commissioning demolition of an outbuilding, extension or the house itself is a domestic client under CDM 2015.

Where a domestic client appoints more than one contractor, they can transfer their CDM duties to the contractor in writing. In practice, on domestic demolition projects with a single demolition contractor, the contractor takes on the client's duties by default if the client does not make a separate appointment. This means the demolition contractor effectively becomes both PC and client, which places a heavier obligation on them to ensure that pre-construction information is gathered (structural surveys, asbestos checks) even where the homeowner has not provided it.

Do not assume that domestic projects are informally regulated. HSE enforcement activity includes domestic demolition sites, particularly following complaints from neighbours or local authorities about unsafe practices.

Frequently Asked Questions

Do CDM Regulations apply to knocking down a garden wall?

CDM 2015 applies to all construction work, which includes demolition. However, for very minor domestic demolition (a single wall or small structure), CDM duties are minimal and proportionate to the risk. The key check is whether the work is notifiable (almost certainly not for a garden wall), and whether more than one contractor is involved. A single domestic contractor taking down a garden wall would be expected to have a basic method statement and risk assessment, but not a full Construction Phase Plan.

Who is responsible for checking the F10 has been submitted?

The client has a duty to ensure notification is made where required. The Principal Contractor is typically the party that submits the F10, but if they fail to do so and the client has not checked, both parties may have enforcement exposure. Confirm at pre-start meeting that the F10 has been submitted and the acknowledgement is on-site before any demolition commences.

Can the Principal Contractor and Principal Designer be the same company?

Yes — on demolition projects with an in-house design function, one company can hold both roles. However, the duties are distinct. If a demolition company holds both roles, it must demonstrate that it has genuine design competence as Principal Designer, not just operational competence. HSE inspectors will question this arrangement where it is clearly inappropriate (e.g., a demolition-only firm claiming the PD role for a complex structural project).

How detailed does the Construction Phase Plan need to be?

Proportionate to the risk. HSE guidance states that the CPP should be as simple and focused as possible while addressing all significant hazards. A simple domestic demolition project CPP might be a few pages. A large industrial demolition project CPP, incorporating multiple method statements, structural engineer's reports and sub-contractor activity plans, may run to dozens of pages. Avoid generic templates that don't address the specific project — these fail HSE inspection regularly.

What happens if demolition starts without an F10 on a notifiable project?

Starting a notifiable project without submitting the F10 is a criminal offence under CDM 2015. HSE can issue an Improvement Notice requiring notification before work continues, or a Prohibition Notice stopping work entirely. On projects with historic injuries or near-misses, failure to notify can be used as evidence of a management failure contributing to the incident.

Regulations & Standards

• Construction (Design and Management) Regulations 2015 (CDM 2015) — the primary regulatory framework; defines duty holder roles, notification requirements and pre-construction obligations

• Health and Safety at Work etc. Act 1974 (HSWA) — underpins CDM and creates general employer and employee duties

• Management of Health and Safety at Work Regulations 1999 — requires employers to undertake suitable and sufficient risk assessments; applies on demolition sites

• HSE L153: Managing Health and Safety in Construction — HSE's approved code of practice and guidance for CDM 2015 [verify current edition]

• Control of Asbestos Regulations 2012 — integrates with CDM pre-construction information obligations; R&D Survey required before demolition

• Work at Height Regulations 2005 — applies to elevated work on demolition sites, including working from machinery, MEWPS, and scaffold

• HSE — Construction (Design and Management) Regulations 2015 — official HSE CDM guidance and free downloads

• HSE F10 Notification Portal — online notification system

• HSE L153 Approved Code of Practice — statutory guidance on CDM 2015 [verify availability]

• HSE — Demolition — sector-specific demolition guidance from HSE

• NFDC — NFDC guidance on CDM compliance for demolition contractors

• nfdc membership and standards — NFDC competency requirements and DICS card scheme

• pre demolition audit — Pre-construction information gathering including structural surveys and hazardous material surveys

• structural demolition sequence — Structural demolition sequencing and method statement preparation

• demolition adjacent structures — Managing CDM obligations where demolition is adjacent to occupied structures