Who does CDM 2015 apply to — including sole traders
The Construction (Design and Management) Regulations 2015 apply to every construction project in the UK without exception based on the size of the contractor. If you're a tradesperson, a sole trader, a small contractor, or a one-person business carrying out construction work, CDM 2015 applies to you. This is a point of genuine confusion in the industry — many small contractors believe CDM 2015 only applies to large commercial projects with principal designers and formal construction phase plans. This is incorrect.
CDM 2015 applies to all construction work, from a one-day domestic job to a major infrastructure project. The threshold determines which specific duties apply, not whether the Regulations apply at all. Even the smallest contractor doing a single day's work on a domestic property has CDM 2015 duties.
The key duties for CDM 2015 small contractors fall into three areas: planning your work before you start, providing suitable project documentation where the job or client requires it, and co-operating with other contractors if you're working alongside them. These duties exist whether or not anyone asks you to label the documents as RAMS.
The three core CDM 2015 duties every small contractor must fulfil
CDM 2015 Regulation 15 requires that all contractors plan, manage, and monitor their own work. This means carrying out a risk assessment before starting any task, not after the work has begun, not during — before. It means producing a method statement for work that involves more than straightforward hazards. It means ensuring your workers are competent — trained, supervised, and aware of the hazards. It means providing adequate information, instruction, and training to your workers before they start. And it means not starting work until the planning is done — not until someone asks for RAMS — until the work is planned.
This duty exists whether or not anyone asks you for RAMS. The planning isn't done for the principal contractor — it's done for the safety of your workers and anyone else who might be affected by your work. If a HSE inspector visits and asks to see your risk assessments, you must have them. The fact that the principal contractor didn't ask for them isn't a defence.
When a principal contractor or client asks you to provide your RAMS before starting on their site, you must provide task-specific documents — not generic templates. The distinction between a compliant RAMS submission and a rejected one comes down to specificity. "Electrical installation work" isn't a task description. "First-fix electrical installation to new-build residential property, including cable routing via joist drilling and containment installation" is a task description. CDM 2015 small contractors who submit generic templates will have RAMS rejected.
If you're working alongside other contractors — even on a domestic job where the client has appointed multiple trades — you have a duty to co-operate under CDM 2015. This means sharing information about your hazards and how they might affect other contractors, co-ordinating your work with other trades to avoid creating new hazards, reporting any unsafe conditions or near misses to the principal contractor, and following the site rules set by the principal contractor.
When CDM 2015 small contractors must notify HSE via F10
The F10 notification is a legal requirement for projects that meet certain thresholds. A project must be notified to HSE via the F10 form if it will involve more than 30 working days of construction work and more than 20 workers on site at any one time, or if it will exceed 500 person-days of construction work in total.
For most CDM 2015 small contractors working on small domestic projects — a kitchen renovation, a small extension, a bathroom fit-out — the work is unlikely to exceed these thresholds. On notifiable projects, the client must ensure the F10 is submitted, although in practice the person managing the project administration may handle the filing. If you are acting as the principal contractor or leading the project, confirm early who is taking responsibility for the notification.
For commercial projects, the principal contractor is responsible for submitting the F10 before construction begins. If a client tells you work is starting and no F10 has been submitted for a project that clearly meets the thresholds, you should flag this to the client and not start work until it's resolved. Starting work on a notifiable project without an F10 is a breach of CDM 2015.
What a principal contractor actually wants from your RAMS
When a principal contractor reviews your RAMS, they're checking for four specific things. Understanding these four things is the fastest way to produce RAMS that pass review and avoid the experience of RAMS rejected feedback.
First — task-specific content. The risk assessment must identify the hazards of the specific work you're doing on this specific project. A generic risk assessment that could apply to any job in any location isn't acceptable. The hazard identification, the control measures, and the emergency procedures must all be specific to the task and the site.
Second — risk rating methodology. Principal contractors want to see your working — your Likelihood × Severity calculation for each hazard. This isn't bureaucratic box-ticking. It's their way of verifying that you've actually thought about the risk and that your controls are proportionate to the actual hazard. Without the working, they have no way to verify your ratings and no reason to trust your RAMS.
Third — controls that match the hierarchy. The hierarchy of risk control — eliminate, reduce, isolate, control, PPE — must be visibly applied. If your only control for working at height is "wear a harness," a principal contractor will notice you've skipped three steps. For each hazard, they want to see that you've worked down the hierarchy correctly.
Fourth — evidence of competence. Your RAMS must include your name, your qualification, and the date. This is your evidence that a competent person has prepared the document. CDM 2015 small contractors are required to be competent — having competence evidence in the RAMS demonstrates you understand this obligation.
The five most common reasons small contractors' RAMS get rejected
In practice, principal contractors reject CDM 2015 small contractors' RAMS for five recurring reasons. Knowing these reasons in advance means you can write RAMS that avoid them.
The first is a task description that is too vague. "Electrical work" or "plumbing work" doesn't describe what you're actually doing. A vague task description is the most common reason for RAMS rejected feedback and the easiest to fix — just write more specifically about what you're actually doing.
The second is missing risk rating methodology. Initial and residual ratings not shown, no Likelihood × Severity working. The principal contractor cannot verify your ratings without the working.
The third is controls that don't match the hazards. "Wear PPE" appears without any mention of elimination or isolation. PPE is the last step of the hierarchy, not the first.
The fourth is no competent person evidence. No name, qualification, or date in the document. The principal contractor has no way to verify who wrote the RAMS.
The fifth is missing emergency procedures. What happens if something goes wrong isn't described. An emergency procedure that is specific to the task and the site — not a generic statement about following site procedures — is what is required.
Competence requirements for CDM 2015 small contractors
CDM 2015 requires that everyone involved in construction work is competent — or working under the supervision of someone who is competent. For a CDM 2015 small contractor, this means having the relevant qualifications for the work you're doing — NVQ, CSCS card, ECS card, or equivalent industry recognition. It means having the experience to carry out the work safely — not just the qualification, but the hands-on experience to apply it correctly.
It means keeping your knowledge current — regulations change, standards change, and your RAMS must reflect the current requirements. CDM 2015 small contractors who are still using RAMS written five years ago without updating them to reflect regulatory changes aren't meeting their obligations.
It means being able to demonstrate competence if asked. By showing your qualifications, your previous RAMS, or your track record. A CSCS card or ECS card is the most visible evidence of competence for construction trades. Principal contractors will check cards on site. If you're doing electrical work, your ECS card should show the appropriate grade for the work you're carrying out.
What to do when you receive a RAMS request
When a principal contractor asks you to submit your RAMS before starting on their site, the correct process is straightforward. First, confirm what work you're being asked to do — get the task description in writing, not just a verbal instruction. Second, visit the site if possible — or get as much information as you can about the specific location and conditions. Third, write your RAMS specific to this task, this site, and these conditions — not a template.
Fourth, check your RAMS against the principal contractor's requirements before submitting. Does it address all the items on their RAMS checklist? Fifth, submit with enough time for review — don't wait until the day before you're due to start. Sixth, be available to answer questions or provide additional information if requested. Principal contractors who ask follow-up questions are usually giving you an opportunity to improve the submission before formal rejection.
CDM 2015 and domestic projects for small contractors
On domestic projects — where the client is a householder — the CDM 2015 duties are allocated differently. The domestic client duties are generally transferred to the contractor or principal contractor arrangements set up for the job, but the contractor still retains the core duties described above. Where a domestic project involves more than one contractor, make sure it is clear who is acting as principal contractor and who is handling project-level CDM duties.
In practice, this means that if you're the only contractor on a domestic job, you may need to manage the planning documentation that would otherwise sit with a principal contractor on a larger project. For domestic work, make sure the construction-phase arrangements are proportionate to the job and that any required plan or project information is in place before work starts.
CDM 2015 small contractors who understand their duties and can demonstrate them through quality RAMS submissions are the contractors that principal contractors want on their sites. Competence demonstrated in documentation is the foundation of the professional relationship between contractor and principal contractor.
F10 notification — who is responsible and when it is required
The F10 form is the notification document that must be submitted to the Health and Safety Executive for notifiable projects. A project is notifiable under CDM 2015 if it involves more than 30 working days of construction work with more than 20 workers on site at any one time, or more than 500 person-days of construction work in total.
The responsibility for ensuring the F10 is submitted sits with the client, although on many projects the principal contractor or project lead handles the practical filing. For most CDM 2015 small contractors working as sub-contractors on domestic or commercial projects, the F10 notification will usually be dealt with by the client-side or principal-contractor-side project team rather than the sub-contractor.
However, contractors who are about to start work on a project that clearly meets the notification thresholds should satisfy themselves that the F10 has been submitted. Starting work on an unnotified notifiable project is a breach of CDM 2015 Regulation 5, and enforcement action can be taken against whoever was responsible for the notification. The contractor who asks "has the F10 been submitted?" before starting work on a large project is asking a sensible question.
Working with principal designers — the small contractor's perspective
On projects where CDM 2015 applies in full — projects involving more than one contractor — a principal designer must be appointed by the client. The principal designer has specific duties under CDM 2015 Regulation 11: to plan, manage, and monitor the pre-construction phase, and to coordinate the health and safety aspects of the design work. For small contractors, the principal designer is a key point of contact for pre-construction information and design-related health and safety issues.
The pre-construction information that the principal designer provides to contractors includes information about the site, the existing structure, any hazardous materials, and the design approach. Small contractors should read this information carefully — it informs the RAMS they write and may contain hazards that aren't immediately obvious from a site visit alone.
Small contractors aren't required to report directly to the principal designer — they report to the principal contractor. But the principal designer has a duty to share health and safety information relevant to the contractor's work, and contractors have a duty to report any risks identified during the work that may affect the health and safety file. This two-way flow of information is essential for effective CDM 2015 management on any project.
Understanding your CDM 2015 duties as a small contractor or sole trader
Sole traders and one-person businesses often assume that CDM 2015 applies only to larger companies with formal health and safety departments. This is incorrect. As a sole trader carrying out construction work, you're a contractor under CDM 2015 and you have the same fundamental duties as any other contractor — to plan, manage, and monitor your own work. This duty exists whether or not a principal contractor has asked you for RAMS, and whether or not you have any employees.
In practice, the key obligations for sole traders under CDM 2015 are: to carry out a risk assessment before starting any construction work, to prepare a method statement for any work involving more than straightforward hazards, to ensure you're competent to carry out the work — or working under appropriate supervision, to provide RAMS to any principal contractor who requests them before you start work on their site, and to co-operate with other contractors and follow site rules set by the principal contractor.
Frequently Asked Questions About CDM 2015 for Small Contractors
Does CDM 2015 apply to a sole trader working alone on a domestic job?
Yes. CDM 2015 applies to all construction work regardless of the size of the contractor or the project. As a sole trader, you're a contractor under CDM 2015 and you have the same fundamental duty to plan, manage, and monitor your own work as any other contractor. This means carrying out a risk assessment before you start, preparing a method statement for work involving more than straightforward hazards, and ensuring you're competent to do the work. The duty exists whether or not anyone asks you for RAMS.
When does a small contractor need to submit an F10 to HSE?
Small contractors don't typically submit the F10 themselves. However, if you're about to start work on a project that clearly meets the notification thresholds — more than 30 working days with more than 20 workers on site at the same time, or more than 500 person-days — you should satisfy yourself that the F10 has been dealt with before you start. If it hasn't, flag it to the client or principal contractor so the position can be resolved.
What is the most common reason a small contractor's RAMS gets rejected?
A vague task description. "Electrical work" or "plumbing work" tells the principal contractor nothing about what you're actually doing. They need to see: exactly what task you're carrying out, the location and building type, the work stage, and how you'll access the work area. A task description like "first-fix electrical installation to a new-build three-bedroom house, including cable routing through joist drilling and PVC conduit installation on ground floor" gives the reviewer much more of what they need to know. The more specific your RAMS, the easier it is to review.