Alex is Sprintlaw’s co-founder and principal lawyer. Alex previously worked at a top-tier firm as a lawyer specialising in technology and media contracts, and founded a digital agency which he sold in 2015.
Running a construction business means you're already juggling people, subcontractors, suppliers, deadlines and site conditions that can change by the hour.
Health and safety paperwork can feel like one more thing on the pile, but a good policy is more than a box-ticking exercise. It gives your team clear rules, helps you manage site risks, and shows clients, principal contractors and the HSE that you take safety seriously.
The good news is that your health and safety policy doesn't need to be complicated. It just needs to be practical, specific to your work, and kept up to date as your business grows.
Do Construction Firms Need A Written Health And Safety Policy?
Yes, if you employ five or more people, you need a written health and safety policy.
Under the Health and Safety at Work etc. Act 1974, you have a duty to protect the health, safety and welfare of your employees and others affected by your work. If you have five or more employees, that policy must be written down.
If you have fewer than five employees, you may not legally need a written policy, but it can still be a smart move. Construction work carries higher risks than many other industries, and clients, insurers and principal contractors may ask to see your safety documents before letting you onto a site.
Your policy should explain:
- your commitment to health and safety
- who is responsible for what in a safety responsibility schedule
- how you identify and manage risks
- how workers report hazards, near misses and incidents
- how you train, supervise and communicate with your team
- how you review and update your safety arrangements
Say you run a small roofing company with four employees and you regularly bring in self-employed labourers. You might not hit the five employee threshold every week, but a written policy can still help you set expectations, brief subcontractors, and show larger contractors that your business is safe to work with.
What Should Your Health And Safety Policy Include?
Your policy should include a clear statement of intent, named responsibilities, and the practical arrangements you use to control risks.
A simple health and safety policy usually has three main parts.
1. Statement Of Intent
This is a short statement from you, as the business owner or director, confirming that your business is committed to providing a safe working environment.
It should be signed and dated by the person with overall responsibility for the business. For a limited company, this will often be a director.
You don't need grand wording. A practical statement might say that your business will:
- comply with relevant health and safety laws
- carry out risk assessments before work starts
- provide suitable training, supervision and equipment
- consult workers about health and safety matters
- review safety arrangements regularly
2. Responsibilities
This section should spell out who does what. In a small construction firm, people often wear several hats, so clarity matters.
You might identify responsibilities for:
- directors or owners
- site managers or supervisors
- employees
- subcontractors
- plant operators
- first aiders
- fire marshals
For example, your site supervisor might be responsible for daily site checks, making sure workers have the right personal protective equipment, and stopping work if conditions become unsafe.
3. Arrangements For Managing Risks
This is where your policy becomes practical. It should explain how you deal with the real risks your workers face, not just generic office-style hazards.
For construction firms, this may include arrangements for:
- working at height
- excavations and groundworks
- asbestos awareness and management
- manual handling
- plant, machinery and tools
- electrical safety
- dust, noise and vibration
- hazardous substances under COSHH
- traffic management and reversing vehicles
- temporary works
- welfare facilities
- lone working
- young or inexperienced workers
- emergency procedures
Templates can be a useful starting point, but they often miss the practical detail that matters on your sites. Your policy works best when it's tailored to how your business actually works.
How Do You Cover Site-Specific Construction Risks?
You cover site-specific risks by using your health and safety policy as the overall framework, then preparing project documents that deal with the risks on each site.
A general policy can't predict every job. A bathroom renovation in an occupied home is very different from commercial cladding works, a demolition job or a new build with several contractors on site.
For each project, think about what is specific to that site, including:
- the layout of the site
- access and delivery routes
- nearby roads, pedestrians or members of the public
- underground or overhead services
- weather exposure
- working near occupied premises
- asbestos or other hazardous materials
- other contractors working nearby
- site security
- fire risks
- noise, dust and disruption to neighbours
Construction Phase Plans
Under the Construction (Design and Management) Regulations 2015, a construction phase plan is required for construction projects. It should be proportionate to the size and nature of the work.
For a small job, it may be a short, practical document. For a larger project, it will usually be more detailed and may sit alongside RAMS, drawings, permits and site rules.
Your construction phase plan should set out how health and safety will be managed during the project, including:
- site rules
- key contacts and duty holders
- arrangements for welfare facilities
- main risks and control measures
- emergency arrangements
- how subcontractors will be managed
- how changes on site will be communicated
Risk Assessments And Method Statements
Risk assessments identify what could cause harm and what controls you'll put in place. Method statements explain how the work will be carried out safely.
Together, they're often referred to as RAMS.
For example, if your team is installing steel beams on a renovation project, your RAMS might cover:
- delivery and unloading arrangements
- lifting operations
- temporary support
- exclusion zones
- manual handling limits
- communication between workers
- what happens if weather conditions change
The key is to make RAMS usable. If workers can't understand them or they don't match the job, they won't protect your team or your business.
Who Is Responsible For Health And Safety On Site?
You're responsible for the health and safety of your own workers, and you may also share responsibilities with clients, designers, principal contractors and subcontractors depending on the project.
Construction projects often involve several duty holders. Under the CDM Regulations 2015, the main roles can include:
- Client: the person or organisation having the work done
- Principal designer: appointed where there's more than one contractor and responsible for planning, managing and monitoring health and safety during the pre-construction phase
- Principal contractor: appointed where there's more than one contractor and responsible for planning, managing and monitoring the construction phase
- Contractors: businesses carrying out construction work
- Workers: people carrying out the work on site
If you're the main contractor on a job with subcontractors, you may have principal contractor duties. That means you need to coordinate work, manage site safety, consult workers, and make sure site rules are followed.
If you're a subcontractor, you still need to protect your workers and cooperate with the principal contractor. You can't simply assume someone else is handling every risk.
In practice, this means you should be clear about:
- who prepares the construction phase plan
- who gives site inductions
- who checks competence and training records
- who controls access to site
- who approves high-risk activities
- who reports incidents and near misses
- who communicates changes to the work plan
If your contracts are unclear, you may end up carrying more risk than you realised. Your building contracts, subcontractor agreements and site documents should line up with your health and safety responsibilities.
What Other Documents Should Sit Alongside Your Policy?
Your health and safety policy should sit alongside practical documents that help you manage people, projects and site risks day to day.
Depending on your work, you may need:
- risk assessments
- method statements
- construction phase plans
- COSHH assessments for hazardous substances
- asbestos management procedures where relevant
- plant and equipment inspection records
- lifting plans and LOLER records
- PUWER checks for work equipment
- working at height procedures
- permit-to-work systems for higher-risk tasks
- site induction records
- training records
- toolbox talk records
- accident and near-miss reports
- emergency and fire procedures
- first aid arrangements
- PPE issue records
You should also think about your employment and contractor documents as part of a wider legal health check. Health and safety duties often work best when they're built into your agreements from the start.
For employees, your employment contracts, probation policy and staff handbook can cover obligations to follow safety rules, report hazards, use PPE properly, and attend training.
For subcontractors, your subcontractor agreement can require them to:
- comply with site rules and applicable health and safety laws
- provide competent workers
- supply training records, licences and insurance details when asked
- follow your RAMS or provide their own for approval
- report incidents, hazards and near misses promptly
- indemnify your business for certain losses caused by their breach
Insurance is also part of the picture. If you have employees, you're usually required to have employers' liability insurance with cover of at least £5 million. Many contractors also carry public liability insurance and contractors' all risks cover, depending on the jobs they take on.
How Often Should You Review Your Policy?
You should review your health and safety policy regularly, and whenever there's a meaningful change in your business, projects or risks.
A sensible rhythm is to review it at least once a year. You should also review it when:
- you start taking on larger or higher-risk projects
- you hire more staff, introduce flexible work arrangements or change your management structure
- you use new equipment, materials or substances
- you move into a new type of construction work
- there's an accident, near miss or safety complaint
- HSE guidance or legal requirements change
- a client or principal contractor raises an issue
Construction risks can change quickly. For example, a general refurb contractor might start taking on basement works. That shift brings excavation risks, temporary works, structural support issues, water ingress and confined space concerns that may not be covered in the existing policy.
Reviewing your policy doesn't always mean rewriting it from scratch. Sometimes it means adding a new procedure, updating responsibilities, or tightening your subcontractor checks.
What Happens If You Do Not Have The Right Policy?
If you don't have the right health and safety policy, you may struggle to show that your business has properly assessed and managed site risks.
The Health and Safety Executive can investigate incidents and inspect sites. Where there are serious failings, consequences can include improvement notices, prohibition notices, fees for intervention, prosecution and fines.
There are also everyday commercial consequences. Without clear health and safety documents, you may:
- miss out on work with larger contractors or public sector clients
- have difficulty satisfying insurer requirements
- find it harder to defend your decisions after an incident
- lose time dealing with preventable disputes on site
- create confusion about who is responsible for key safety tasks
Some incidents also need to be reported under the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013, commonly called RIDDOR. For example, certain specified injuries, dangerous occurrences and work-related deaths are reportable. Injuries causing a worker to be away from work or unable to do their normal work for more than seven consecutive days must generally be reported within 15 days of the accident.
If you're unsure whether an incident is reportable, check the HSE requirements quickly and get advice if needed. Leaving it too late can create avoidable problems.
Common Mistakes To Avoid
Health and safety policies go wrong when they're too generic, out of date, or disconnected from what actually happens on site.
Common mistakes include:
- Using a generic policy that doesn't mention construction risks: A policy that talks about office fire exits but not working at height, plant, dust or subcontractors won't be much help.
- Forgetting subcontractors: If subcontractors are central to your work, your policy and contracts should explain how you'll check competence, share site information and manage their work.
- Not matching the policy to the site documents: Your policy, RAMS, construction phase plan and site rules should work together.
- Writing documents no one reads: Long, vague documents often get ignored. Clear, job-specific instructions are far more useful.
- Not keeping training records: If someone is asked to use equipment or carry out higher-risk work, you should be able to show they were competent and properly briefed.
- Failing to update after incidents: A near miss is a warning sign. Use it to improve your systems before something more serious happens.
Your goal isn't to create a perfect folder that sits on a shelf. It's to create a working system that helps your team make safer decisions on busy sites.
Key Takeaways
- If you have five or more employees, you need a written health and safety policy under UK health and safety law.
- Even smaller construction firms often benefit from a written policy because clients, insurers and contractors may ask for it.
- Your policy should cover responsibilities, risk management arrangements and construction-specific hazards.
- Site-specific documents such as construction phase plans, RAMS, COSHH assessments and induction records help turn your policy into practical site controls.
- Your contracts with employees and subcontractors should support your health and safety systems.
- Review your policy regularly, especially when your projects, team or risk profile changes.
If you'd like help with your health and safety policy, subcontractor terms, employment contracts or construction project documents, you can reach us at 08081347754 or team@sprintlaw.co.uk for a free, no-obligations chat.
Drafted by Taylor, Sprintlaw's AI, and overseen by Alex Solo. How we write
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