What a CDM principal contractor actually has to record

The Construction (Design and Management) Regulations 2015 give the principal contractor three verbs for the construction phase: plan, manage and monitor. They do not prescribe a template for any of them. That is deliberate — a fit-out of one floor and a twelve-storey residential block need different paperwork — but it leaves a gap that site managers usually fill with whatever was on the last job.

The duties, in the order they bite

Four of the principal contractor’s duties leave a record behind, and those are the four worth building a system around.

1. The construction phase plan

It has to exist before the work starts, and it has to be reviewed and revised as the job changes. A plan that was written once and never touched again is evidence of the opposite of management. The revisions matter as much as the document.

2. Managing the work

This is where inspection and test plans earn their place. An ITP is the written answer to “how do you know this was built to the specification?” — the activity, the requirement, the verifying document, the acceptance criteria, and the type of check. Written down that way it is answerable; carried in somebody's head it is not.

3. Monitoring

Monitoring is the part that is usually done and almost never recorded. A walk round with a camera is monitoring; a camera roll is not a record of it. What makes it a record is that each observation is tied to a place, a trade, a date and an outcome — and that somebody can see, later, whether it was closed.

4. Information for the health and safety file

Whatever the file will need has to be collected while it is collectable. Fire stopping is the clearest example: once the ceiling is in, the evidence either exists or it does not.

What to keep, in practice

• An inspection record per work package, with the acceptance criteria written out rather than referenced from memory, and the result of each line.
• What was checked before it was covered up. A check with no recorded result is worse than no check, because it looks like a control that was ignored.
• A defect record tied to a location, with the photograph attached to the item rather than living in a gallery.
• A non-conformance route for anything that needed more than a fix — what happened, why, what was decided, and what verified the close-out.
• Evidence of anything that gets covered up, taken before it is covered up.
• A handover record that shows what was outstanding at the point of signing, rather than implying nothing was.

The common failures

Records that only exist in one person’s head or phone. A site manager leaves and takes six months of evidence with them.

A defect list with no close-out trail. Somebody marked it fixed; nobody recorded that it was checked. On a dispute, “fixed” without verification is worth very little.

Photographs in a folder by date. Nobody can find the one that matters, and a photograph that cannot be located is not evidence.

Signing a unit over on the basis of a feeling. If the registers say two inspections are unsigned, they are unsigned, whatever the programme says.

Where the software fits

None of this needs software. All of it needs consistency, which is the thing software is genuinely good at: the same fields every time, the date stamped automatically, the photograph attached to the item rather than the day, and the register able to tell you what is open without anybody counting.

Project Audit Pro was written by a CDM principal contractor to answer these questions on his own jobs. The ITPs, the non-conformance route and the handover gates all exist because a real job needed them.