Health and Safety Files: What to Keep and Why
Spring & Co, Stockport. Construction & property consultants since 1992
The health and safety file is the record you hand the client at handover so anyone who works on the building in future can do it safely. Under Regulation 12 of the CDM Regulations 2015, the principal designer prepares it, the client keeps it for the life of the structure, and it holds the residual risks, not every scrap of site paperwork.
The mistake we correct most often is a file that weighs more than it should. Someone hands over a lever-arch folder stuffed with the full construction phase plan, every delivery note and a pile of product manuals, and calls it thorough. It is the opposite. The file is written for one reader: the person standing in the plant room in 2045 with a drill, who needs to know what is behind that wall before they cut into it. Give them 20 pages they can trust, not 400 they will never open.
What is the health and safety file, actually?
It is the safety record for the finished building, not for the job of building it. CDM 2015 came into force on 6 April 2015 and splits the safety paperwork into three parts: the pre-construction information before the work, the construction phase plan during it, and the health and safety file for afterwards. Only the last one is meant to outlive the project.
People confuse it with the operation and maintenance manual, and the two often sit in the same binder, but they answer different questions. The O&M manual tells the facilities team how to run the boiler and service the lifts. The file tells the next contractor what will hurt them if they touch the structure. One keeps the building working. The other keeps people safe when someone changes it.
Who has to produce it, and who has to keep it?
The principal designer prepares the file, and the client keeps it. Regulation 12(5) puts the duty on the principal designer to prepare, review and update it as the design develops. If the principal designer leaves the project before the end, the principal contractor takes it on. When the work finishes, the file passes to the client, whose duty under Regulation 4 is to keep it available to anyone who needs it.
This only bites where more than one contractor is involved, which in practice is almost every commercial project. And the duty to keep it does not lapse when the scaffold comes down. If you sell the building, the file goes with it. We tell clients to hold a digital copy off site as well, because the one place a paper file is guaranteed to be missing is the morning a surveyor asks for it.
What actually goes in the file?
The residual risks a future worker could not reasonably be expected to spot for themselves. HSE guidance L153, Appendix 4 sets out what belongs, and the same theme runs through all of it: danger that survives the build and is not obvious once the paint is on.
| What to keep | Why it matters |
|---|---|
| A brief description of the work carried out | Orientation for anyone who never saw the project |
| Residual hazards and how they were dealt with (asbestos surveys, contaminated ground, buried services) | The hazards that stay in the building after everyone leaves |
| Key structural principles, bracing and any stored energy such as post-tensioned members | Cut the wrong element and the structure can fail |
| Safe working loads for floors and roofs | Stops a future fit-out overloading a slab or a plant deck |
| Hazardous materials left in place, such as lead paint or special coatings | Protects anyone who later drills, sands or strips them |
| How to remove or dismantle installed plant safely | End-of-life and replacement work carries its own risk |
| Nature, location and marking of significant services, including underground cables and gas | The buried 11kV run nobody remembers is the classic near miss |
| As-built drawings of the structure, its plant and safe access to service voids | The drawings have to match what was actually built, not the design intent |
If you are partway through a project and no one can tell you who owns the file, that is worth a call now rather than at practical completion. Our CDM advisor and health and safety team picks files up mid-build and gets them back on track before handover.
What does not belong in the file?
Almost everything people try to put in it. The construction phase plan is a live document for the build, and it has no place in the file once the job is done. Pre-construction information, risk assessments, method statements and delivery records belong in the project archive, not here. Padding the file with them buries the two or three entries that actually matter.
There is a genuine tension here, and I will not pretend otherwise. Leave something out and a future risk goes unrecorded. Put everything in and the one entry that saves someone gets lost on page 300. We come down hard on the side of a short, ruthless file with a clear index, and we would rather defend a lean file than a fat one. A 12 page file that names the asbestos, the buried 11kV cable and the post-tensioned slab does its job. A 300 page file that hides them behind delivery notes does not.
Why does the file matter more on a Greater Manchester refurbishment?
Because of what our building stock is actually made of. Stockport and the wider North West are full of Victorian and Edwardian mills, warehouses and terraces built for the cotton trade, and a large share of the commercial refurbishment work here happens inside them. That means cast iron columns of unknown capacity, timber that has carried a century of alterations, asbestos in the fabric of almost anything touched between the 1950s and the 1999 ban, and services that were added, abandoned and built over by one owner after another. A file for a new steel-frame unit on a business park is thin by comparison. A file for a mill conversion off Chestergate is where this discipline earns its fee, because the residual risks are genuinely hidden and genuinely serious.
How long do you keep the health and safety file?
For as long as the building stands.
There is no fixed retention period in CDM 2015, because the honest answer is the life of the structure. A file created today could be opened by someone in 60 or 80 years, which is why format matters as much as content. Store it where it will outlive the software it was written in, keep the as-built drawings legible, and update it every time the building changes. When you sell, the file transfers to the new owner, and the duty to keep it becomes theirs under Regulation 4.
A quick test for a file that works
Hand your file to someone who has never seen the building and ask four things:
- Can they find the residual hazards in under a minute?
- Do the as-built drawings match what was really built?
- Is there anything in here a future worker does not need?
- Would you be comfortable if this file were the only warning someone got?
If the answer to any of them is no, the file is not finished.
We prepare and review health and safety files as part of our CDM advisory and construction health and safety work, and we audit inherited files through our project monitoring and auditing service. If you are approaching handover in Stockport or anywhere across Greater Manchester and you are not sure your file would pass that test, talk to our team before the project closes out, not after.