by admin | Oct 5, 2026 | CDM 2015, Construction Site Management, Consultancy Services, Health and Safety
The Government’s September response to the Grenfell Tower Inquiry does not suddenly create a new set of duties for contractors. It does, however, make the direction of travel much clearer: stronger senior accountability, more visible evidence of competence, tighter control of principal contractors and designers, and better traceability of the information used to demonstrate compliance.
The direction of travel is towards clearer accountability
On 10 September 2026, the Government published its sixth progress update on the Grenfell Tower Inquiry Phase 2 recommendations. Of the 28 recommendations grouped under the construction industry, nine were recorded as complete and 19 remained in progress. The construction-industry update confirms that major reforms are still being developed rather than presenting them all as current legal requirements.
That distinction matters for contractors. Headlines about principal contractor licensing, senior sign-off and a single construction regulator can easily be read as though each measure has already taken effect. It has not. Businesses need to separate duties that already apply from proposals, consultations and legislation that may change the system later.
The Building Safety Regulator became a standalone arm’s-length body in January 2026, with the staff transfer out of HSE completed in June. Government describes this as an important step towards the proposed Single Construction Regulator, but primary legislation will still be required to establish that wider regulator.
What is already a legal duty?
The Building Regulations dutyholder regime for building work in England is already in force. Government’s current dutyholder guidance requires clients, designers and contractors to take appropriate steps around competence and compliance, with principal designer and principal contractor appointments required where the statutory circumstances apply.
Competence is not simply a qualification or card. For individuals, the regime considers skills, knowledge, experience and behaviours. For organisations, the issue is organisational capability: whether the business has suitable policies, procedures, systems and resources to fulfil the work it undertakes.
Principal contractors must plan, manage, monitor and coordinate building work so it complies with the Building Regulations. Principal designers have corresponding responsibilities for design work. These duties sit alongside, rather than replace, duties under CDM 2015, even where the same organisation is appointed to a similarly named role under both regimes.
Senior sign-off and contractor licensing remain proposals
Recommendation 20 concerns a proposed senior-manager statement from the principal designer at Gateway 2 for higher-risk building work. The September update says Government intends to strengthen senior accountability and is considering how the recommendation should be implemented. It is not currently a general statutory sign-off requirement across building control applications.
Recommendation 21 concerns a licensing scheme for principal contractors working on higher-risk buildings, together with a personal undertaking from a director or senior manager. Government says the dutyholder-regime review and its evidence-gathering work will inform implementation. There is not currently a statutory principal-contractor licensing scheme of the type recommended by the Inquiry.
Directors should nevertheless pay attention to the direction of travel. A stronger accountability regime will place even greater value on being able to show who reviewed significant decisions, what information they considered, what competence was relied upon and how unresolved compliance issues were escalated.
Competence evidence needs to reflect the real work
The wider reform programme reinforces a point that already matters in practice: competence evidence needs to be connected to the work being undertaken. A training certificate, NVQ, card or professional membership can be important evidence, but none automatically demonstrates competence for every project, complexity or dutyholder function.
Businesses should be able to show how qualifications, relevant experience, supervision, organisational systems and project-specific capability fit together. Structured development through routes such as supervisory and management NVQs is most useful when it evidences real occupational responsibility rather than becoming a certificate-collection exercise.
Better records support better decisions
The September report also confirms that construction-product reforms remain in development. Government intends to bring forward legislation for a General Safety Requirement when Parliamentary time allows and is continuing work on access to reliable product testing and performance information.
For contractors, the practical lesson extends beyond product regulation. Design decisions, substitutions, approvals, changes, installation evidence and handover information should form a traceable chain. We explored the same issue in Digital Product Records in Construction: Should Contractors Be Preparing Now?.
Technology can make that chain easier to manage, but the objective is not digitisation for its own sake. It is being able to retrieve the information behind a safety-critical decision and understand why that decision was made, even after the people originally involved have moved on.
What should you do now?
- Confirm who holds your Building Regulations and CDM dutyholder roles and that appointments are correctly documented.
- Review competence records so they show relevant experience, project complexity, limitations and supervision as well as qualifications.
- Define how significant compliance decisions are reviewed and escalated.
- Test the information trail for one important design change, product substitution or installation on a live project.
- Monitor Government reforms without treating proposals as current law before they take effect.
Our professional view
The important theme running through these reforms is not simply more paperwork. It is the ability to demonstrate that competent people made properly informed decisions within organisations capable of controlling the work.
A business can employ very capable individuals and still fail if responsibilities are unclear, information is fragmented or commercial pressure prevents proper escalation. Equally, a sophisticated management system has limited value if nobody can show how it influences decisions on a live project.
Construction businesses do not need to wait for every future reform before improving that position. All Star Safety’s health and safety consultancy service can support contractors reviewing dutyholder arrangements, competence systems and practical compliance assurance.
by admin | Sep 30, 2026 | Consultancy Services, Health and Safety, Risk Assessment, Safety Update
A recent HSE prosecution has demonstrated why an established risk assessment cannot simply be stretched to cover a new task, altered method or different use of work equipment. Employers must review risk assessments when they may no longer be valid or when a significant change affects the work. That does not always mean starting again, but it does mean checking whether the existing controls still match reality.
A fatal incident followed a change in working practice
In July 2026, the Health and Safety Executive reported a prosecution after a worker died following a fall from a mobile loading ramp during a newly introduced activity. HSE found that the work had not been properly assessed, the manufacturer required handrails for pedestrian use, and alternatives that could have avoided work at height had not been adequately considered.
The important point for construction and industrial employers is broader than the equipment involved. When the planned method changes, the assumptions behind the original risk assessment can change with it.
When must a risk assessment be reviewed?
Under Regulation 3 of the Management of Health and Safety at Work Regulations 1999, employers must make a suitable and sufficient assessment of risk. That assessment must be reviewed where there is reason to suspect it is no longer valid or where there has been a significant change in the matters to which it relates.
A review may result in a small amendment, a revised method statement or a completely new assessment. The scale of the paperwork should be proportionate to the scale of the change and the risk created by it.
What counts as a significant change?
The test is not simply whether the change is expensive or permanent. A relatively small operational change can materially alter the hazard profile. Examples include:
- introducing new plant, attachments or work equipment;
- using existing equipment for a different purpose;
- changing the work sequence or access arrangements;
- moving an activity to another part of the site;
- introducing pedestrian access into a plant area;
- changing loads, materials or substances;
- starting lone, night or out-of-hours working;
- using less experienced workers or a different subcontractor;
- departing from manufacturer instructions; or
- responding to changed ground, weather or temporary works conditions.
HSE’s workplace transport guidance similarly advises employers to assess risks before significant changes and to keep assessments aligned with the way work is actually carried out.
Does every change require completely new RAMS?
No. A minor variation that does not materially change the hazards or controls may be dealt with through a proportionate review and briefing. However, foreseeable change should not be pushed into a vague instruction to “dynamic risk assess” the job.
A formal RAMS review is particularly important where the change affects work at height, lifting operations, temporary works, vehicle and pedestrian interaction, excavation support, hazardous substances, isolation, guarding, emergency arrangements or the competence and supervision required.
If a revised method creates a new technical question, the right response may be to obtain specialist input from a designer, engineer, appointed person or other competent professional before work resumes.
Manufacturer instructions matter
The Provision and Use of Work Equipment Regulations 1998 require work equipment to be suitable for its intended use. Manufacturer instructions are therefore important evidence of the conditions under which equipment has been designed and tested to operate safely.
Where a business deliberately departs from those instructions, it should have competent technical justification for the alternative arrangement. Convenience, programme pressure or “we have always done it this way” are not robust reasons.
What should you do now?
- Identify work activities that have changed since the RAMS were approved.
- Check whether the existing assessment still describes the real work.
- Review equipment suitability and manufacturer requirements.
- Apply the hierarchy of control to any new or increased risk.
- Confirm whether additional competence, supervision or specialist advice is needed.
- Update the method before implementing significant changes.
- Brief everyone affected and check understanding.
- Observe the revised method during its first use.
- Update permanent documents if the change becomes established practice.
Our professional view
Many serious incidents happen not because an organisation has no safety arrangements, but because an apparently small change bypasses them. A different attachment, temporary access route, revised sequence or unfamiliar item of equipment can invalidate assumptions that were perfectly reasonable when the RAMS were written.
A practical management-of-change process does not need to be bureaucratic. HSE’s Plan, Do, Check, Act approach provides a useful framework: identify the change, understand the risk, implement the right controls, communicate them and then verify that the revised system works.
Businesses that need an independent review of changed working methods can use our health and safety consultancy service for RAMS reviews, risk assessments and site-based support.
by admin | Sep 28, 2026 | Construction Site Management, Consultancy Services, Health and Safety, Safety Update
Appointing a subcontractor does not transfer away the principal contractor’s duty to plan, manage, monitor and coordinate the construction phase. Subcontractors retain responsibility for work under their control, but the principal contractor still needs to check competence, coordinate activities, maintain suitable site arrangements and intervene where unsafe work is foreseeable or observed.
A serious fall shows where contractor control can fail
In July 2026, the Health and Safety Executive reported the prosecution of a principal contractor after a labour-only subcontractor suffered life-changing injuries while dismantling pipework.
A scissor lift had been ordered but could not access the work area. Instead of stopping and selecting suitable access equipment, a forklift truck and tipping bucket were used. HSE found there were no suitable arrangements for managing contractors, no adequate supervision and no effective system preventing untrained people from accessing the equipment.
The lesson goes beyond the particular equipment involved. When the planned method becomes impracticable, the work should be reassessed. An improvised alternative should not become the new method simply because the job is already under way.
What must a principal contractor legally do?
Under the Construction (Design and Management) Regulations 2015, a principal contractor on a project involving more than one contractor must plan, manage, monitor and coordinate health and safety during the construction phase.
That includes organising cooperation between contractors, coordinating work where activities interact, maintaining the construction phase plan, providing suitable site inductions and ensuring workers receive the information, instruction, training and supervision they require.
Contractors retain duties of their own. They must plan, manage and monitor the work under their control and cooperate with the principal contractor. The duties deliberately overlap: the principal contractor coordinates the project while each contractor controls its own operation.
Does approving RAMS transfer responsibility?
No. A principal contractor’s review of subcontractor RAMS does not make the principal contractor the author of every specialist method. Equally, accepting a document does not remove the responsibility to consider whether the method is suitable for the actual project.
A meaningful review should ask whether the RAMS describe the real scope and location, whether the proposed equipment will physically fit, whether interactions with other trades have been considered, what competence and supervision are required, and what should happen if site conditions or the planned method change.
Where work materially departs from the agreed method, our professional recommendation is to stop, reassess and obtain fresh authorisation before continuing.
Who controls labour-only subcontractors?
The expression “labour-only subcontractor” can cover different contractual arrangements. From a site-safety perspective, the important questions are practical: who controls the work, who provides the equipment, who gives instructions, who appoints the supervisor and who has authority to stop the activity?
Before work begins, the parties should agree who provides task-specific supervision, who verifies training and authorisation, who controls access to plant and equipment, who approves changes to the method and who coordinates with other contractors.
A labour-only arrangement should never create a gap where the principal contractor assumes the subcontractor is supervising the workers while the subcontractor assumes the principal contractor is directing them.
Improvised access equipment should be a warning sign
A tipping bucket is not a purpose-designed working platform. HSE’s guidance on working platforms used with forklift trucks explains that forklift trucks are primarily intended to lift materials rather than people. Even a properly designed non-integrated working platform should only be used in exceptional circumstances and under controlled conditions.
If a MEWP, scaffold or planned access system cannot be used, that does not justify using the nearest available substitute. It should trigger a review of the work sequence, access constraints, equipment selection, obstructions and programme.
What should you do now?
- Define who controls each contractor and labour-only team.
- Check competence and organisational capability before appointment.
- Review RAMS against the actual site conditions.
- Confirm access equipment is suitable and will physically fit.
- Restrict equipment use to trained and authorised people.
- Identify high-risk stages requiring additional supervision.
- Monitor whether the agreed method is being followed.
- Stop work when equipment, conditions or sequencing change.
- Record significant interventions and corrective actions.
- Review contractor performance before future appointments.
Our professional view
A principal contractor does not need to stand over every subcontractor throughout every task. It does need a defensible system showing that contractors were selected carefully, given suitable information, coordinated, monitored and challenged where necessary.
The most revealing moment is often when the original plan stops working. A competent team pauses and finds a safe alternative. A weak system allows an improvised method to become the new plan without anyone formally deciding whether it is acceptable.
All Star Safety’s health and safety consultancy service includes RAMS reviews, site inspections and support with contractor-management arrangements. Managers and supervisors can also develop their risk-management skills through our IOSH courses and workplace-based Supervisory and Management NVQs.
by admin | Sep 18, 2026 | Construction Site Management, Consultancy Services, Safety Update
Construction handover is often treated as a final-week document chase: as-built drawings arrive late, certificates sit in unrelated folders and O&M manuals contain information nobody has checked against the finished building. The practical question is whether the information handed over can actually support safe operation, maintenance and future construction work.
New industry guidance starts with the people inheriting the building
The Construction Leadership Council and BIM in Asset Management have opened consultation on new guidance covering As Built & Handover Information. The work focuses on a simple question: what information does somebody actually need when a construction project finishes?
The consultation is intended to apply across different project scales, from major developments to refurbishment, retrofit and smaller replacement work. That is useful because poor handover is not exclusively a BIM problem on large projects.
The consultation itself is industry guidance in development rather than new legislation. Existing statutory duties still need to be considered separately.
See the As Built & Handover Information consultation.
A handover pack can contain several different legal and contractual records
The phrase “handover pack” is convenient but can conceal several separate information requirements.
Under CDM 2015, a health and safety file is required for projects involving more than one contractor. Its purpose is specific: to contain information likely to be needed to protect health and safety during subsequent construction work on the building.
Separate requirements can arise under the Building Regulations, including relevant fire-safety information. Higher-risk buildings in England also have more extensive golden-thread information requirements. O&M manuals, warranties, commissioning records and asset registers may then be required by the project specification or contract.
These information streams can overlap, but they are not automatically the same document. Producing an O&M manual does not, by itself, prove that every CDM, Building Regulations or golden-thread obligation has been satisfied.
“As built” should mean what was actually installed
A drawing can be professionally produced and still be a poor as-built record if it reflects the design team’s last intention rather than the completed asset.
If a service route changes during construction but the drawing remains unchanged, someone carrying out future intrusive work may rely on inaccurate information. The same issue can arise with fire dampers, structural fixings, underground services, roof-access systems, electrical isolators and other safety-critical assets.
The useful question is: what evidence gives the recipient confidence that the record reflects what was actually installed?
That evidence might include inspection records, commissioning results, approved changes, test certificates, marked-up drawings or other proportionate verification.
Our earlier article on digital product records in construction makes a related distinction: product data can identify what a product is, but does not by itself prove where it was installed or whether the installation matches the approved design.
The information gap often appears after subcontractors demobilise
Project teams frequently discover missing records after the specialist contractor has left site. The supervisor has moved to another project, the commissioning engineer is no longer available and somebody is left reconstructing drawings, certificates or product information from old emails.
The better approach is to define information requirements before the work begins. Specialist contractors should know what records they are expected to provide, in what format, who will review them and when they are due.
Where information is generated progressively, it should be collected progressively. Fire-stopping records, commissioning results, plant information and as-built changes should not all be deferred until the final week because they are traditionally considered “handover documents”.
Good handover starts at procurement, not practical completion
A simple project information schedule can identify each required record, who produces it, who reviews it, the required format, the date it becomes available and where the approved version will be stored.
On a larger project this may sit within BIM and a common data environment. On a smaller project, a controlled spreadsheet and logical folder structure may be perfectly adequate. What matters is the management process.
Changes during construction should trigger information changes. If a product, route or system changes, the team should ask what drawings, asset data, fire information, maintenance instructions and future access information are affected.
Review should also happen during the project. Sampling completed handover information each month can reveal missing approvals, contradictory references and poor naming while the people who generated the information are still available to correct it.
What should you do now?
- Review a recently completed project from the perspective of an unfamiliar facilities manager.
- Separate the CDM health and safety file, fire-safety information, O&M records and higher-risk-building information where applicable.
- Create a project-specific information schedule with owners and due dates.
- Make construction changes trigger a review of affected as-built information.
- Collect specialist-contractor information before demobilisation.
- Link test and commissioning evidence to the relevant asset or location where practical.
- Sample handover information during construction rather than waiting for completion.
- Verify critical information before project close-out.
Our professional view
The measure of a good handover pack should not be its file size. It should be whether somebody who did not work on the project can find, understand and reasonably rely on the information when they need it.
Good information management also needs to be proportionate. A small plant-replacement project does not need a complex digital twin, but it may need accurate plant references, commissioning results, isolation information, maintenance instructions and revised drawings.
The question remains the same at every scale: what will the person inheriting this asset need to know, and can we demonstrate that what we are giving them reflects what was actually built?
For clients and contractors reviewing CDM arrangements, project information or construction close-out processes, All Star Safety’s health and safety consultancy service provides project-based and ongoing support. Our CDM 2015 Awareness course also covers key project documents and dutyholder responsibilities.
by admin | Sep 16, 2026 | Consultancy Services, Health and Safety, Safety Update
An HSE Improvement Notice is not an advisory letter to deal with when workload allows. It is formal legal enforcement requiring a specified contravention to be put right within a defined period. Failing to respond properly can turn an inspection issue into criminal convictions, significant costs and personal consequences for company directors.
A recent prosecution shows how far enforcement can escalate
In August 2026, the Health and Safety Executive reported the prosecution of a sawmill business and its managing director after Improvement Notices were not complied with.
Inspectors had identified deficiencies involving wood-dust exposure, respiratory protection, health surveillance and lift-truck safety. The company was given formal opportunities to put matters right but subsequently failed to comply with the notices.
The business was fined and ordered to pay costs. The managing director was also prosecuted and disqualified from acting as a company director for five years. The case is a clear reminder that formal enforcement should be visible and actively managed at senior level.
An Improvement Notice is a legal requirement
Section 21 of the Health and Safety at Work etc. Act 1974 provides the basis for Improvement Notices. An inspector may serve one where they believe there is, or has been, a contravention of relevant health and safety law and the contravention is likely to continue or be repeated.
The notice should identify the legal requirement involved, the matters giving rise to the contravention and the period allowed for compliance. The notice normally provides time to remedy the breach rather than automatically stopping the activity.
That differs from a Prohibition Notice, which can be used where an activity involves, or is likely to involve, a risk of serious personal injury and may take effect immediately.
The deadline matters, but so does the standard achieved
Compliance is not simply a matter of completing an action before the date printed on the notice. The business needs to bring the relevant activity or management arrangement into compliance with the law.
If the notice concerns inadequate dust control, for example, purchasing an extraction unit is not enough unless the resulting system actually controls exposure adequately. If it concerns plant competence, booking a training course may not solve a wider problem involving authorisation, familiarisation, supervision or unsafe traffic arrangements.
A useful internal test is: can the business demonstrate that the contravention identified by the inspector has genuinely been corrected and that the new arrangement will continue to work?
Evidence might include revised procedures, risk assessments, training records, competent-person reports, photographs, inspection records, purchase or installation evidence and confirmation that the new controls have been briefed and implemented.
Appeal rights exist, but the timescale is short
Section 24 of the Health and Safety at Work etc. Act 1974 provides a formal appeal route. Appeals against Improvement and Prohibition Notices are dealt with through the Employment Tribunal system.
An appeal must normally be lodged within 21 days from the date the notice was served. For an Improvement Notice, an appeal suspends the operation of the notice until the appeal is determined. The position for a Prohibition Notice is different.
A business that believes a notice is technically wrong or disproportionate should therefore obtain competent advice quickly. Informal discussion with the inspector should not be allowed to cause the appeal deadline to pass unnoticed.
Directors can face consequences alongside the company
Section 37 of the Health and Safety at Work etc. Act allows directors, managers and other senior individuals to be prosecuted in certain circumstances where a company offence was committed with their consent or connivance, or was attributable to their neglect.
That does not mean a director is automatically prosecuted whenever the company commits an offence. But where formal enforcement has been served, directors should know what the notice requires, who owns each action, what resources are needed and how completion will be verified.
Ignoring a notice, assuming somebody else is dealing with it or failing to check whether the required action actually happened creates an unnecessary personal and corporate risk.
What should you do now?
- Read the complete notice and identify the exact legal provision involved.
- Record the compliance deadline and appeal deadline immediately.
- Escalate the notice to the appropriate director or senior manager.
- Appoint one competent person to coordinate the response.
- Decide whether interim controls are needed before the permanent remedy is complete.
- Define what compliant performance will look like.
- Allocate the necessary budget, labour and specialist support.
- Keep clear evidence of each corrective action.
- Verify completion independently rather than relying on verbal confirmation.
- Check whether the same weakness exists on other projects or sites.
Our professional view
Receiving an Improvement Notice is serious, but it is also a point at which a business still has a clear opportunity to regain control. The most damaging management failure is to receive a formal, legally enforceable warning and then fail to make sure the required improvement actually happens.
Good directors should be able to answer four questions quickly: what has HSE identified, who owns the corrective action, when must it be completed, and how will we verify that it has worked?
All Star Safety’s health and safety consultancy service includes site audits, management-system support and competent-person assistance. Our IOSH courses also support managers and supervisors in understanding practical risk management and their legal responsibilities.