Summary

Small building sites — domestic extensions, bathroom renovations, kitchen refits, loft conversions — often operate without any written health and safety documentation. Many tradespeople regard H&S paperwork as the domain of large contractors and not relevant to 1–3 person domestic jobs. This view is legally incorrect and practically dangerous.

The Management of Health and Safety at Work Regulations 1999, the Construction (Design and Management) Regulations 2015, and a range of specific regulations (noise, dust, manual handling, work at height) apply to all construction work regardless of size. The fact that the site is a domestic property and the client is a homeowner does not exempt the tradesperson from their duties as an employer or self-employed person.

That said, the H&S framework is proportionate. A sole trader fitting a bathroom in a domestic property is not expected to maintain the same documentation as a large housebuilder. The standard is "reasonably practicable" — controls appropriate to the actual risks. This article focuses on the practical minimum requirements for small sites and what proportionate documentation looks like.

Key Facts

  • CDM 2015 applies: To ALL construction work in Great Britain — including domestic repair, maintenance, and refurbishment
  • Domestic client: On a domestic project (client is a private individual having work done on their home), the client's duties under CDM pass to the contractor automatically (or to the principal contractor if there are multiple contractors)
  • Notifiable projects: Must notify HSE (F10 form) if project will last more than 30 working days with more than 20 workers simultaneously, OR exceed 500 person-days — these are the notification thresholds
  • Construction Phase Plan: Required for ALL projects, not just notifiable ones — but the level of detail should be proportionate to the risks; a small domestic job may need only a brief plan
  • Welfare facilities — toilet: Adequate toilets must be available; access to the householder's toilet is acceptable for small domestic jobs with their agreement, or a chemical toilet for larger sites
  • Welfare facilities — washing: Hot and cold (or warm) running water, soap, and hand-drying facilities; householder's bathroom acceptable for small domestic jobs with agreement
  • Welfare facilities — rest area: Somewhere to sit, eat, and shelter from the weather; a site cabin, van, or room in the property with agreement
  • Welfare facilities — drinking water: Clean, marked supply of drinking water
  • First aid — minimum provision: At least one appointed person (low-risk site, few workers) or a first aider (higher risk, larger workforce)
  • First aid kit: An adequately stocked first aid kit relevant to the activities on site
  • Method statements: Written description of how significant hazard operations will be carried out safely; required for tasks with significant risk (work at height, confined spaces, asbestos, deep excavation)
  • RAMS (Risk Assessments and Method Statements): Combined documents increasingly required by principal contractors and householders — include both risk assessment and method statement in one document
  • Toolbox talks: Brief verbal briefings on specific hazards before work starts — best practice for small teams; record that they happened

Quick Reference Table — Welfare Requirements by Site Size

Spending too long on quotes? squote turns a 2-minute voice recording into a professional quote.

Try squote free →
Site Size Toilet Washing Rest Drinking Water First Aid
1–2 workers, domestic (agreement with householder) Use householder's (agreement required) Use householder's (agreement required) Van or householder's kitchen (agreement) Van / bottles Appointed person with first aid kit
3–5 workers, domestic Portable chemical toilet if householder toilets not accessible Portable wash unit or householder's Cabin, van, or indoor room Water cooler or bottles Appointed person or first aider
5–10 workers, 4+ weeks Portable toilet (1 per 20 workers) Separate washing facility with warm water, soap Site cabin Mains or water cooler First Aider (trained); defibrillator recommended
10+ workers Multiple toilets; separate male/female recommended Dedicated washing facility Dedicated mess room/cabin Mains with clean supply First Aider; first aid room for large sites

Detailed Guidance

CDM 2015 on Small Domestic Sites

CDM 2015 is frequently misunderstood by small tradespeople. Key points:

The Regulations apply to ALL construction projects — "construction work" is broadly defined to include everything from building a wall to fitting a kitchen. There is no minimum size threshold.

For domestic projects (where the client is a private individual having work done on their own home), the client's CDM duties automatically pass to the contractor. If there is more than one contractor, they pass to the principal contractor.

This means: if you are the sole tradesperson on a domestic job, you are both the contractor and the effective CDM client. Your duties include:

  • Producing a Construction Phase Plan (proportionate to risk)
  • Notifying HSE if the project is notifiable
  • Ensuring welfare facilities are in place
  • Co-ordinating with other trades on site
  • Ensuring a health and safety file is handed over on completion of notifiable projects

The Construction Phase Plan for a small domestic job can be brief — it might be a single A4 sheet covering: work being done; hazards identified; controls in place; emergency contacts. For a small bathroom fit, this is disproportionate to the risk and a brief RAMS document for the key hazards is usually sufficient. For a larger renovation with multiple trades, a more detailed plan is appropriate.

Welfare Facilities — Practical Provision

Domestic jobs with householder agreement: For small domestic jobs (1–3 workers, short duration), it is common and acceptable to use the householder's toilet and washing facilities by agreement. Get this agreement before starting. Inform the householder what the arrangement is — many householders assume the tradespeople will use their facilities and are happy for this; some are not. Confirm it.

Portable sanitation: For longer jobs or where the householder's facilities are not available, a portable chemical toilet should be provided. These can be hired from plant hire companies. One toilet per 20 workers is the standard ratio. Site toilets must be maintained and emptied regularly (typically weekly or as required).

Washing facilities: The standard requires warm water, soap, and means of drying. For larger sites, a dedicated welfare unit (trailer or cabin with sink, electric water heater, toilet) is the practical solution.

Rest facilities: Workers must be able to rest, eat, and shelter from the weather. A site cabin, the van, or a designated room in the property (with householder agreement, and with adequate protection from work dust and noise during breaks) all meet this requirement. The rest area must be separate from areas where work is in progress — workers should not be eating lunch in a room where dust or chemical exposure is present.

First Aid Provision

The Health and Safety (First Aid) Regulations 1981 require employers to make adequate first aid provision. "Adequate" depends on the number of workers and the risk level of the work.

Appointed person (minimum): Can be the tradesperson themselves; must take charge in an emergency, call emergency services, administer basic first aid if trained. Appointed persons do not need to hold a full First Aid at Work certificate but should be trained.

First Aider: Required on larger or higher-risk sites; must hold a current first aid at work certificate (3-day course, renewed every 3 years).

First aid kit contents (minimum for construction): HSE guidance suggests a minimum kit for 1–5 workers should contain: disposable gloves (at least 6 pairs), eye wash, wound dressings (3 each of small/medium/large), 1 large sterile wound dressing, triangular bandages (2), safety pins, adhesive plasters (assorted), guidance card. Many pre-packaged first aid kits from Boots, RS Components or BSi-compliant suppliers meet or exceed this.

Kit should be: in a clearly marked container, accessible at all times, inspected regularly, and replenished when items are used.

Burns and chemical injuries: If the work involves chemicals, hot materials, or processes that create burn risk (soldering, welding, grinder sparks), ensure you have appropriate burn treatment (cool running water — the primary treatment for burns — plus burn gel, non-stick dressings).

Method Statements

A method statement is a written description of how a specific task will be carried out safely. It is different from a risk assessment — a risk assessment identifies hazards and assesses risk; a method statement describes the control measures and the step-by-step safe procedure.

In practice, for complex or high-risk tasks, a RAMS (Risk Assessment and Method Statement) combines both into a single document.

When a method statement is required:

  • Working at height (using ladders, scaffolding, MEWP)
  • Confined space entry
  • Work on or near asbestos (where work is planned at all; notifiable work requires a full plan of work)
  • Demolition or structural alterations
  • Deep excavations (over 1.2m)
  • Hot works (welding, cutting, use of blowtorches in fire risk areas)
  • Any work with significant interface between trades (e.g. structural engineer-specified temporary works)

Content of a method statement:

  1. Description of the work
  2. Hazards involved
  3. Controls and precautions
  4. Sequence of operations (step by step)
  5. PPE required
  6. Emergency procedures
  7. Supervisor/responsible person

Toolbox talks: Brief verbal briefings to site operatives before work on a specific task begins. Cover the key hazards and controls. Record that the talk happened (date, attendees, topic). Toolbox talks demonstrate active H&S management and are good evidence if an incident later occurs.

Site Rules and Householder Communication

On domestic jobs, the householder is typically present or nearby. Clear communication before work begins prevents conflict and protects the tradesperson:

  • Which areas of the property are work zones
  • Which facilities workers may use (toilet, kitchen for rest)
  • Working hours
  • Smoking and no-smoking areas (no smoking in enclosed workplaces under Health Act 2006)
  • Householder access to work areas (ideally restrict access during hazardous operations)
  • Dust management (dust sheets, ventilation, where dust will accumulate)
  • Parking arrangements for vans and deliveries

A brief verbal briefing on the first day, confirmed with a short written summary, sets professional expectations and protects all parties.

Site Inspection and Record-Keeping

Weekly site inspections (self-performed for small sites) identify hazards before they cause incidents. Check:

  • Access and egress clear
  • Welfare facilities adequate and maintained
  • Materials stacked safely
  • Cables, hoses, and trip hazards managed
  • PPE available and being used

Record the inspection briefly — date, checked by, any issues and actions. This takes 5 minutes per week and provides evidence of active H&S management.

Frequently Asked Questions

Do I need a Construction Phase Plan for a bathroom renovation?

Yes, in principle — CDM 2015 requires a Construction Phase Plan for all construction work. However, the level of detail should be proportionate to the risk. A bathroom renovation for a single tradesperson can be covered by a brief document (one page) identifying the main hazards (electrical isolation, manual handling, slip on wet surfaces, dust from cutting) and the controls. For a simple job, a RAMS covering these areas meets the CDM requirement.

Who is responsible for H&S when there are multiple trades on site?

Where there is more than one contractor (including self-employed subcontractors) on a domestic site, CDM 2015 requires a principal contractor to be appointed. The principal contractor takes on the client duties (in a domestic project) and co-ordinates H&S across all trades. On small domestic jobs with two or three trades, typically the main contractor (builder, extension contractor) is the principal contractor and is responsible for the Construction Phase Plan and site H&S co-ordination.

I'm self-employed — do I need to provide my own first aid kit?

Yes. Self-employed people have duties under health and safety law in respect of their own safety and the safety of any persons who could be affected by their work. A first aid kit is basic and inexpensive — keep one in the van at minimum.

Can I work without a dedicated site toilet if the house is occupied?

Yes, if the householder agrees. For short jobs (one or two days) with a small team, use of the householder's toilet with their agreement is standard and acceptable. For longer jobs, it is better to arrange a portable toilet rather than relying on householder facilities — it is more professional and avoids disputes about access.

Regulations & Standards

  • Construction (Design and Management) Regulations 2015 (CDM 2015) — applies to all construction work; duties of domestic client, contractor, principal contractor

  • Management of Health and Safety at Work Regulations 1999 — risk assessment requirements

  • Health and Safety (First Aid) Regulations 1981 — first aid provision requirements

  • Workplace (Health, Safety and Welfare) Regulations 1992 — welfare facilities (applied to construction sites with CDM supplement)

  • Health Act 2006 — smoking ban in enclosed workplaces

  • Construction Health, Safety and Welfare Regulations [verify current instruments] — specific welfare provisions for construction sites

  • HSE CDM 2015 Guidance — official HSE guidance on CDM for small contractors and domestic clients

  • CITB Site Safety Plus — health and safety training for construction including first aid

  • HSE First Aid at Work — first aid requirements and kit contents

  • LABC CDM Guidance for Domestic Projects — Local Authority perspective on CDM compliance

  • HSE Construction Phase Plan Guide — guidance on proportionate Construction Phase Plans

  • working at height — working at height requirements within site setup

  • dust control — dust control as part of small site H&S

  • noise at work — noise controls within site H&S planning

  • confined spaces — confined space requirements on site

  • cdm regulations — full CDM 2015 guidance for tradespeople