Is my construction project notifiable under CDM 2015?

Not every construction project needs to be notified to the HSE. CDM 2015 Regulation 6 sets two thresholds. If your project exceeds either one, you must submit an F10 notification before the construction phase begins.

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The two notification thresholds

Under CDM 2015 Regulation 6, a construction project is notifiable if it meets either of these conditions:

Threshold A

The construction work will last longer than 30 working days and have more than 20 workers on site at any one time.

Threshold B

The construction work will exceed 500 person-days in total.

If either threshold is met, the project is notifiable. You do not need to exceed both. A small project with three workers running for 170 working days hits 510 person-days and is therefore notifiable under Threshold B, even though it never has more than 20 workers on site.

What counts as construction work?

CDM 2015 defines construction work broadly. It includes building, alteration, fitting out, commissioning, renovation, repair, upkeep, redecoration, external cleaning with water or abrasive, demolition, dismantling, and the installation, maintenance, or removal of mechanical, electrical, gas, compressed air, hydraulic, telecommunications, and computer services that are normally fixed within or to a structure.

Site preparation, exploration, investigation (but not mineral extraction), and the clearance or preparation of a site for use or for building work also count. If in doubt, assume it counts.

Who is responsible for notifying?

The duty to notify sits with the client. Under CDM 2015, the client is the person or organisation for whom the construction work is carried out. The client may delegate the practical task of completing and submitting the F10 form to the principal designer, a project manager, or another competent person, but the legal duty remains with the client.

For domestic projects where the client does not appoint a principal designer, the duty to notify transfers to the contractor (or principal contractor, if more than one contractor is involved).

When to submit the F10

The notification must be submitted as soon as practicable before the construction phase begins. There is no fixed deadline (such as 14 days before), but in practice the earlier you notify, the less likely you are to receive an enforcement notice for late notification.

The F10 should be updated if the particulars change materially during the project, for example if the principal contractor changes or the expected duration increases significantly.

Consequences of not notifying

Failure to notify a notifiable project is a criminal offence under CDM 2015. The HSE can issue improvement notices or prosecute. In practice, the HSE inspector will usually ask for the F10 during a site visit. If the project is notifiable and no F10 has been submitted, the inspector will issue an enforcement notice and may consider further action depending on the circumstances. The fine for non-notification is unlimited in the magistrates' court.

Common edge cases

Phased projects cause the most confusion. If a developer splits a large scheme into phases with different contractors, the entire scheme counts as one project for notification purposes if it falls under a single client. Each phase does not reset the person-day count.

Maintenance contracts with rolling call-offs can be notifiable if the total person-days across the contract period exceed 500. A facilities management company running a team of four for a year-long maintenance programme will exceed 500 person-days and should notify.

Temporary structures, scaffolding, and site welfare facilities all count towards the workforce and duration totals.

Frequently asked questions

What counts as a "working day" for CDM notification purposes?
A working day is any day on which construction work takes place, regardless of how many hours are worked that day. Weekends and bank holidays count if work happens on those days. Periods where no work is carried out (such as breaks between phases) do not count towards the 30-day threshold.
Does demolition work count as construction work under CDM 2015?
Yes. CDM 2015 defines "construction work" broadly to include demolition, dismantling, alteration, conversion, renovation, repair, maintenance, and commissioning. A standalone demolition project that exceeds the notification thresholds must be notified to the HSE.
Can I notify a project that might not reach the thresholds?
Yes. There is no penalty for notifying a project that turns out to be non-notifiable. The HSE explicitly advises that if you are in doubt, you should notify. Over-notification is always safer than under-notification.
What happens if phases of work are separated by gaps?
If the work is part of the same project, each phase contributes to the overall total. A project that involves 15 working days of groundwork, a two-week gap, then 20 working days of superstructure work exceeds the 30-day threshold because the total construction duration is 35 working days. The gap does not reset the count.
Are domestic projects exempt from CDM notification?
Domestic projects are not exempt from CDM 2015 entirely, but they have reduced duties. If a domestic project exceeds the notification thresholds, it must still be notified to the HSE. The main exemption for domestic clients is that they do not need to appoint a principal designer or principal contractor if the project is not notifiable and has only one contractor.
How do I submit the F10 notification?
The F10 is submitted online through the HSE website. The form asks for project details including location, client name, principal designer, principal contractor, planned start date, planned duration, and maximum number of workers. It should be submitted as soon as practicable before the construction phase begins.

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