Does your Bristol demolition job need an F10?
Most demolitions in Bristol are small enough that no notification to the Health and Safety Executive is needed, but some are not. The notification is called an F10, and it is required for construction projects that reach one of two thresholds set in the Construction (Design and Management) Regulations 2015. Whether a job needs one depends on how long the work lasts, how many people work on it at the same time and how many person-days of work it involves. Getting that answer wrong is not a paperwork problem. A notifiable project that goes ahead without notice is a breach of the regulations. The duty to notify sits with a business client, while for a homeowner it passes, with the other client duties, to the contractor.
This guide explains the thresholds, who is responsible for giving the notice, when it has to be given and why a domestic project usually falls outside the duty. It is a guide to the rules as they apply to demolition, not a substitute for advice from a principal designer on a particular job.
The two thresholds
The rule is set out in regulation 6 of the Construction (Design and Management) Regulations 2015. A project is notifiable if the construction work on a construction site is scheduled to last longer than 30 working days and to have more than 20 workers working simultaneously at any point in the project. Alternatively, a project is notifiable if it is scheduled to exceed 500 person-days. The two limbs are separate. A job that lasts a long time with a small crew may be notifiable under the first, and a short job with a large crew may be notifiable under the second.
The thresholds apply to the scheduled work, not to the work as it actually turns out. That matters for demolition, because a programme that is planned to fall below both thresholds but that later stretches for weeks may need to be notified once the schedule changes. The contractor and the owner should check the programme again whenever it changes, and they should record the scheduled figures in writing when the job is agreed.
Who gives the notice
The duty falls on the client. Where the project is notifiable, the regulation requires the client to give written notice to HSE as soon as practicable before the construction phase begins. The HSE guide to CDM 2015 for clients (INDG411) says that, in practice, the client may ask someone else to do this on their behalf. A principal designer or a demolition contractor who has been engaged for the job often prepares the notice, but for a commercial client the legal responsibility remains with the client, and the owner should confirm in writing who is submitting it. For a domestic client, regulation 7 moves the notification duty itself to the contractor or principal contractor.
The HSE page on how to notify a project describes the online F10 form and the user guidance that goes with it. The notice contains the details of the project, the client and the people appointed to it, and it is submitted through HSE's online system. Once submitted, it gives HSE a record that a notifiable project is under way, and the owner should keep a copy with the rest of the project file.
The INDG411 guidance adds that a principal designer or a principal contractor will be able to advise on the client's duties. An owner who is not sure whether a job is notifiable should put the question to the people who would be appointed to it, and should ask for the answer in writing before the programme is fixed. That answer is more useful than a verbal assurance, particularly if the job is later re-scheduled and the calculation has to be repeated.
A Bristol owner who is weighing up several quotes should also make sure the calculation is done on the same basis for each of them. A contractor who assumes a short programme with a small crew may quote a lower price than one who plans a longer job with more people, and the notification answer will differ between them. Comparing the figures side by side is the simplest way to see which assumptions are behind each price.
When the notice has to be given
The timing rule is short but important. The notice must be given as soon as practicable before the construction phase begins. The construction phase is the period when the physical demolition work starts, not the period when the owner is first considering the job or obtaining quotes. An owner who waits until the day before the first machine arrives may find that the notice has not been given in time, and an owner who gives it months early may find that the programme has changed by the time the work starts.
The sensible course is to decide whether the job is notifiable at the quotation stage, when the programme is first drawn up. If it is, the notice can be prepared in parallel with the appointment of the contractor and the other notices the job needs. The timeline in the timeline guide shows where the notice fits in the sequence.
Why a domestic job is rarely notifiable
The CDM 2015 regulations treat domestic clients differently. The INDG411 guidance explains that a domestic client is a person having work done on their own home, or the home of a family member, that is not connected with a business. The only responsibility of a domestic client under CDM 2015 is to appoint a principal designer and a principal contractor when there is more than one contractor. If the domestic client does not make those appointments, the duties are transferred automatically to the contractor or the principal contractor. That transfer includes the duty in regulation 6: a domestic project that crosses a threshold must still be notified, but by the contractor rather than by the homeowner.
A typical house demolition is unlikely to meet either notification threshold. It seldom needs more than twenty people on site at the same time for more than thirty working days, and it is unlikely to reach the 500 person-days limb either. An owner who is clearing a single house should check the programme against the thresholds rather than assume the answer, and should record the check on the file. Where the house is part of a larger redevelopment, or where the demolition is combined with a substantial rebuild, the position can change.
What the notice does not do
A notification is not a permission. It does not give consent to demolish, it does not satisfy planning requirements and it does not replace the asbestos notices, the party wall procedure or the waste paperwork. Those are separate duties with separate timings. An owner who thinks that the F10 has dealt with the other issues will find that the other issues are still open.
It also does not reduce the duty to manage the project safely. The client's duties under CDM 2015 continue throughout the job, and the principal designer and principal contractor have their own duties. The INDG411 guidance warns that if a client does not comply with the regulations, the work may be stopped and additional work may be needed to put things right. In the most serious cases, the client can be prosecuted.
Who this matters for
The threshold matters most for commercial and industrial demolitions in Bristol, where the crew is larger and the programme is longer. A warehouse, an office block or a multi-storey building is more likely to be notifiable than a house, and the owner of a commercial site should check the position at the outset. The commercial demolition service page describes the scope that such a job would normally include, and the residential demolition service page covers the usual scope for a house.
Checking the answer before the job starts
The owner should ask every contractor to state whether the job is notifiable and to show the calculation. The answer should include the scheduled duration in working days, the maximum number of workers on site at one time and the estimated person-days. Where the answer is that the job is not notifiable, the owner should keep that calculation on file in case the programme changes. Where the answer is that it is notifiable, the owner should ask who is preparing the notice and when it will be submitted.
A quote request should include the expected size of the job and the programme you have in mind, so that each contractor can answer the notification question on the same basis. The basement demolition service page explains how below-ground work can extend the programme, which can affect the threshold calculation for a job that looks small on the surface.