The Preliminary Health and Safety Plan: What It Must Contain and Who Prepares It
The Preliminary Health and Safety Plan is one of the most important documents on any notifiable construction project in Ireland.
# The Preliminary Health and Safety Plan: What It Must Contain and Who Prepares It The Preliminary Health and Safety Plan is one of the most important documents on any notifiable construction project in Ireland, yet it is also one of the most frequently misunderstood. Many clients and contractors confuse it with the Construction Stage Safety and Health Plan, or treat it as a box-ticking exercise rather than a genuine planning tool. This guide explains what the Preliminary Health and Safety Plan is, who prepares it, what it must contain, and how it should be used during the construction phase. ## What Is the Preliminary Health and Safety Plan? The Preliminary Health and Safety Plan (PHSP) is a document prepared during the design phase of a construction project. It is required under the Safety, Health and Welfare at Work (Construction) Regulations 2013 for all notifiable projects, that is, projects where construction work is expected to last longer than 30 working days with more than 20 workers simultaneously, or where the volume of work is expected to exceed 500 person-days. The PHSP is prepared by the Project Supervisor for the Design Process (PSDP). Its purpose is to communicate to the PSCS and all contractors the key health and safety information they need to plan and carry out the construction work safely. It is a planning document, not a compliance checklist. The PHSP must be prepared before the construction phase begins and must be provided to the PSCS before they take up their appointment. The PSCS then uses the PHSP as the basis for developing the Construction Stage Safety and Health Plan, which is the operational safety management document for the construction phase. ## Who Prepares the Preliminary Health and Safety Plan? The PHSP is prepared by the PSDP. This is a legal requirement under the Construction Regulations 2013. The PSDP must be competent to carry out this function, which requires a combination of design knowledge, construction experience, and health and safety expertise. In practice, the PSDP is often a safety consultant, an engineer, or an architect with appropriate health and safety qualifications and experience. On larger projects, the PSDP may be a specialist health and safety consultancy. On smaller projects, the PSDP may be the project architect or engineer who has taken on the PSDP role in addition to their design responsibilities. The PSDP must gather information from all members of the design team to prepare the PHSP. This includes information about hazards arising from the design, the site, and the construction methods envisaged. The PHSP is therefore a collaborative document, even though the PSDP has overall responsibility for preparing it. ## What the Preliminary Health and Safety Plan Must Contain The Construction Regulations 2013 set out the minimum content requirements for the PHSP. These are set out in Schedule 2 of the Regulations. The PHSP must include the following. **General description of the project.** This includes the nature of the project, the location of the site, the client's contact details, and the names and contact details of the PSDP and any designers involved. **Description of the existing environment.** This covers the physical characteristics of the site and its surroundings, including underground services, overhead lines, adjacent structures, ground conditions, and any contamination. The PSDP must carry out or commission surveys to establish this information before the PHSP is prepared. **Description of the existing structure.** Where the project involves work on an existing building or structure, the PHSP must describe the structure, including its construction, condition, and any known hazards such as asbestos, lead paint, or structural instability. **Information on hazardous substances.** Where hazardous substances are known or suspected to be present on the site, the PHSP must identify them and describe the risks they create. This is particularly important for sites with a history of industrial use, where soil or groundwater contamination may be present. **Specific risks arising from the nature of the work.** The PHSP must identify the specific risks that arise from the nature of the construction work, including working at height, excavation, demolition, use of explosives, and work near water. For each risk, the PHSP should describe the measures envisaged to control it. **Arrangements for coordination.** The PHSP must describe the arrangements for coordinating health and safety between the various contractors who will work on the project. This includes the arrangements for managing interfaces between different trades and for managing the movement of plant and vehicles on site. **Welfare arrangements.** The PHSP must describe the welfare facilities that will be provided on site, including toilets, washing facilities, rest areas, and facilities for storing and drying clothing. **Emergency arrangements.** The PHSP must describe the emergency arrangements for the project, including the location of the nearest hospital, the arrangements for summoning the emergency services, and the arrangements for evacuating the site in an emergency. ## The Relationship Between the PHSP and the Construction Stage Plan The PHSP and the Construction Stage Safety and Health Plan are related but distinct documents. The PHSP is prepared during the design phase and sets out the known hazards and the envisaged control measures. The Construction Stage Plan is prepared by the PSCS before construction begins and sets out in detail how safety will be managed during the construction phase. The PSCS must use the PHSP as the starting point for developing the Construction Stage Plan. They must review the PHSP, assess whether the information it contains is accurate and complete, and develop the Construction Stage Plan to address any gaps or changes in circumstances. In practice, the quality of the Construction Stage Plan is heavily dependent on the quality of the PHSP. A PHSP that is generic, incomplete, or out of date will result in a Construction Stage Plan that does not adequately address the actual risks on the project. This is why it is so important that the PSDP prepares the PHSP with care and that it is kept up to date as the design develops. ## Updating the Preliminary Health and Safety Plan The PHSP is not a static document. It must be updated as the design develops and as new information becomes available. If the design changes significantly after the PHSP has been prepared, the PSDP must update the PHSP to reflect the changes. Common triggers for updating the PHSP include changes to the scope of the project, changes to the construction programme, discovery of previously unknown hazards such as asbestos or underground services, and changes to the design that affect the construction method. The PSDP must communicate updates to the PHSP to the PSCS and to all contractors who may be affected. This communication must be timely. If a contractor starts work without being aware of a significant hazard that has been identified after the PHSP was first issued, the PSDP may be liable for any resulting injury. ## Common Deficiencies in Preliminary Health and Safety Plans In our experience working on construction projects across Leinster, the most common deficiencies in PHSPs are as follows. **Insufficient site investigation.** The PHSP is only as good as the information it is based on. If the PSDP has not carried out or commissioned adequate site investigations, the PHSP will not accurately reflect the hazards present on the site. Ground investigations, underground service surveys, and asbestos surveys should all be completed before the PHSP is finalised. **Generic content.** A PHSP that has been prepared by copying and pasting from a previous project, or from a template, without adapting it to the specific characteristics of the current project, is not adequate. The PHSP must be specific to the project. **Failure to address design-related hazards.** One of the primary purposes of the PHSP is to communicate to the PSCS and contractors the hazards that arise from design decisions. If the design team has not considered buildability and the health and safety implications of their design choices, the PHSP will not contain this information. **Late preparation.** The PHSP must be available to the PSCS before they take up their appointment, which should be before construction begins. A PHSP that is prepared after construction has started is of limited value. ## The Value of a Well-Prepared PHSP A well-prepared PHSP is a genuine planning tool that adds value to a construction project. It enables the PSCS and contractors to plan their work with full knowledge of the hazards on the site. It reduces the likelihood of unexpected hazards causing delays or accidents during construction. And it provides a clear record of the information that was available to the design team and how it was communicated to the construction team. Clients who invest in a thorough PHSP at the design stage typically see the benefit in a smoother construction phase with fewer safety incidents and fewer programme delays caused by unexpected hazards. If you need a PSDP appointment, a Preliminary Health and Safety Plan, or PSCS services for your construction project in Leinster, Safety Check has the expertise and experience to deliver. Contact us to discuss your project requirements.