Construction phase plan for a re-roof: who writes it and what goes in

Who writes the construction phase plan on a re-roof?

It depends on how many contractors the project involves. Regulation 12 puts the duty on the principal contractor, who must draw up the plan, or make arrangements for it to be drawn up, during the pre-construction phase and before setting up the site. Where there is only one contractor, regulation 15 gives the same job to that contractor, again as soon as is practicable before the site is set up. The principal designer helps by giving the principal contractor the information it holds, including the pre-construction information obtained from the client.

Situation on the roof project	Who prepares the plan	Regulation
One contractor only	That contractor, or someone it arranges	15(5)
More than one contractor, sub-contractors included	The principal contractor, appointed in writing by the client	5 and 12(1)
More than one contractor, but the client has appointed no principal contractor	The client, who must then fulfil the principal contractor’s duties	5
Other contractors on a multi-contractor job	They comply with the parts of the plan relevant to their work	15(3)

Because HSE treats sub-contractors as contractors, adding a scaffolder or an electrician to the roofer’s team takes the project into the second row. The CDM 2015 guide explains when the principal roles apply.

What must the client do about the plan?

The client must ensure that, before the construction phase begins, a construction phase plan is drawn up by the contractor on a single-contractor job, or by the principal contractor. HSE’s guidance for commercial clients puts it the same way. A contractor, for its part, must not carry out construction work unless satisfied that the client is aware of the client’s duties.

Timing matters. Regulation 12 asks for the plan to be drawn up in the pre-construction phase, before the site is set up, and HSE says the principal contractor must then implement it and regularly review and revise it to make sure it remains fit for purpose. A plan first produced after the site is set up is late by the Regulations’ own timing.

In practice the plan is the first document to ask for, before anyone goes on the roof. Five questions make a useful read-through. These are suggestions, not tests in the Regulations.

1. Does it describe this roof, its phases and how the building stays in use?
2. Does it use the pre-construction information on asbestos, structure and fragile areas?
3. Does it cover every trade in the contract, not only the roofer?
4. Are the site rules written down, including access, security and hot work?
5. Who reviews and updates it when the job changes?

Client duties and the F10 threshold sit in the CDM 2015 guide. The wider repair-or-replace decision, which comes before any of this, is in the repair or replace guide.

What must a construction phase plan cover?

Regulation 12(2) is short. The plan must set out the health and safety arrangements and site rules, taking account of the industrial activities on the site and, where applicable, including specific measures for work in the categories listed in Schedule 3. The Regulations define site rules as rules drawn up for a particular site and necessary for health or safety purposes. The principal contractor must keep the plan reviewed, updated and revised so that it stays sufficient throughout the project.

HSE says the effort devoted to planning should be proportionate to the complexity of the project and the risks involved, and that for a small job a simple plan before the work starts is usually enough. Two Schedule 3 categories are worth checking against a roof: work putting workers at risk of falling from a height where the risk is aggravated by the nature of the work or the environment; and work involving the assembly or dismantling of heavy prefabricated components, which may matter where precast elements or plant are lifted.

What belongs in a roof-specific checklist?

The Regulations do not list roofing topics, so this table is a checklist built from the regulation and HSE’s roof work guidance. Treat each row as a question for whoever writes the plan.

Topic	What to look for in the plan
Access	Routes for people and materials, how they are protected and who controls them. HSE says safe access needs careful planning, particularly where work progresses along the roof.
Edges and openings	Protection at every phase. HSE says falls from flat roof edges can be prevented by simple edge protection: a secure double guardrail and toeboard around the edge.
Fragile surfaces and rooflights	Where they are and how they are covered or guarded. HSE says all roofs should be treated as fragile until a competent person has confirmed they are not. See the fragile roofs guide.
Asbestos	The survey findings and who controls any asbestos-containing material. HSE says a refurbishment or demolition survey must locate it, including hidden material, before structural work begins. See asbestos in old roofing felt.
Hot works	Permits, fire watch and gas storage. See the hot works guide.
Lifting and loading	How materials reach the roof, where they are stored and what the structure can carry. See the RAAC guide for decks that need an engineer first.
Other trades and services	Scaffold, electrical isolation of rooftop plant, and the order of work.
Weather	What stops work, and how the open roof is left watertight each night. See the temporary roofs guide.
Occupants and public	Exclusion zones below, deliveries and access control. HSE says the principal contractor must consider everyone affected by the work, including members of the public.
Welfare, induction, emergencies	Facilities meeting Schedule 2, a site induction, unauthorised access prevented, and an emergency plan including rescue from height.

Work at height rules sit behind several rows; the work at height guide covers them.

How is the plan different from a method statement?

HSE describes a method statement as the common way to help manage work on roofs and communicate the precautions to those involved. The construction phase plan works at project level: regulations 12 and 15 require it, and it covers the arrangements and site rules for the whole job. In practice a contractor’s task-level risk assessments and method statements feed into the plan rather than replace it, and on a multi-contractor project each contractor must comply with the parts of the plan relevant to its work.

For example, a 5,000 square metre warehouse roof is recovered in two phases while the building stays in use, with a roofing contractor, a scaffolder and an electrician isolating rooftop extract fans. That is three contractors, so the client appoints a principal contractor in writing and the principal contractor owns the plan. A plan that says only “roofing method statement attached” would not describe the phasing, the routes below the roof or the isolations. This example is hypothetical.

If you want to talk a roof project through, you can send an enquiry through the form on this site.

Sources

• The Construction (Design and Management) Regulations 2015, regulations 2, 4, 5, 12, 13 and 15 and Schedule 3, legislation.gov.uk, checked 22 October 2026
• HSE: Principal contractors (updated 7 November 2024), Are you a contractor?, Contractors, Commercial clients, CDM 2015 FAQ, checked 22 October 2026
• Roof work (updated 5 June 2026) and The duty to manage asbestos in buildings: arrange an asbestos survey, Health and Safety Executive, checked 22 October 2026

Common questions

Does a small roof repair need a construction phase plan?

HSE’s FAQ says yes: a contractor who is the only contractor, or the principal contractor, must draw one up. It also says the plan should be proportionate to the size and scale of the job, and that a simple plan before the work starts is usually enough.

Can the building owner write the plan?

The Regulations put the drawing up with the contractor or principal contractor, who may arrange for it to be drawn up. The exception is a multi-contractor job where the client appoints no principal contractor: the client must then fulfil that role’s duties, which include the plan.

Is there a template?

HSE’s FAQ points small projects to a template construction phase plan. A template is only a starting point, because the roof’s own hazards, phasing and site rules still have to be written in.

Who gets to see the plan once it exists?

On a project with more than one contractor, HSE says the principal contractor must give each contractor the information in the plan that is relevant to their work, and each contractor must comply with the parts relevant to it. The client can ask for the plan before work starts.

Related guides

• Building control for a commercial re-roof: which route?
• What building control costs for a commercial re-roof
• Building regulations completion certificates for a commercial re-roof
• The Building Safety Act and commercial roof work