Welfare on day one: what CDM 2015 actually requires before the first operative arrives
It has to be there before the first operative starts work, not once the compound is finished. That single distinction is the most common mobilisation gap we find.
Welfare is not something you install once the site is running. It has to be there before the first operative starts work, it is set out in law as a minimum list rather than a standard to aim at, and it is the first thing an inspector looks at because it is the only part of a construction site that can be assessed in four minutes without a drawing.
Here is the list, what it actually means on a real compound, and the five places mobilisations get caught.
The legal minimum, in one place
Schedule 2 of the Construction (Design and Management) Regulations 2015 sets out the minimum welfare facilities for a construction site. It is short. It is also unforgiving, because "so far as is reasonably practicable" appears in some of it and not in other parts.
- Sanitary conveniences. Suitable and sufficient, adequately ventilated and lit, kept clean and orderly, with separate rooms for men and women where required. Rooms containing them must be adequately ventilated and lit.
- Washing facilities. At every sanitary convenience and every changing room, with clean hot and cold or warm running water, soap and towels or another suitable means of drying. Showers where the work is dirty or involves health risks.
- Drinking water. An adequate supply of wholesome drinking water, conspicuously marked where necessary, with cups unless it is a jet from which people can drink.
- Changing rooms and lockers. Where a person has to wear special clothing, and where they cannot be expected to change elsewhere, with facilities to dry clothing and to secure it.
- Facilities for rest. Suitable and sufficient, including the means to prepare and eat a meal, to boil water, and — where necessary — arrangements for pregnant women and nursing mothers to rest.
The HSE's guidance on welfare on construction sites is the practical companion to that list, and the approved code of practice on workplace health, safety and welfare is where the underlying standards for a fixed workplace sit.
"From day one" is the part people get wrong
The regulations do not describe a facility that arrives when the compound is finished. Work includes the work of building the compound. That means the groundworkers laying your hardstanding are entitled to the same list as the people who will use the offices six weeks later.
In practice that produces the single most common mobilisation gap we see: a permanent welfare arrangement that is correct, procured properly, and lands three weeks after the first boots. The interim arrangement is then improvised by whoever is on site, and it is the improvised one an inspector meets.
Five places it goes wrong
- Sized for week one, not for peak. Twelve people in week two, 180 in month five, and a compound sized for the number in front of you. Re-sizing an occupied compound costs more than over-specifying an empty one, and it costs programme as well as money.
- Water assumed. No mains, or a mains connection quoted in months rather than weeks. Drinking water and warm running water are not optional lines that wait for a connection date.
- Waste treated as a delivery, not a service. Tanks get emptied on a frequency somebody guessed at, and the frequency is wrong in the direction that produces a phone call on a Saturday.
- Cleaning with no owner. "Kept clean and orderly" is in the regulations. It is almost never in a contract. It is the single most common thing we find with no named budget holder.
- Welfare travel time not counted. On a linear or rural site, facilities that are compliant but fifteen minutes away are a productivity line nobody has measured, twice a day, for every operative.
What a defensible arrangement looks like
Not gold-plated. Defensible: you can show what was provided, from when, for how many, who serviced it, and how you knew it stayed adequate as the headcount moved.
That is four documents, and the useful thing is that all four are cheap if they exist before mobilisation and expensive to reconstruct afterwards: a welfare schedule tied to the headcount curve, the interim arrangement for the enabling works with its own dates, a servicing regime with frequencies and a named responsible party, and a record of the reviews when the headcount changed. A specimen of the level of detail is published here — we would rather publish the document than describe it.
A worked example, invented on purpose
Invented deliberately, because a real project is identifiable from its constraints alone and nothing here comes from a live engagement.
A 40-week scheme, enabling works starting in week one with eight operatives, main works from week seven, peaking at 120. No mains water; a connection quoted at 22 weeks. The wrong answer is one procurement covering weeks 7 to 40, because it leaves six weeks improvised. The right answer is two arrangements with a planned handover between them, and a bowser regime with a sampling frequency for the first 22 weeks. Same suppliers, same money, different sequence — and the difference is entirely in the define stage.
What this does not solve
A correct welfare schedule does not make a utility connection arrive earlier, and it does not decide the arguable questions for you: how many conveniences is "sufficient" for your shift pattern, whether your work is dirty enough to require showers, or whether a rest facility is adequate for the number using it at once. Those are judgements for a competent person on your project, against your actual conditions.
Anything touching a life-safety question — fire strategy in temporary accommodation, means of escape, or a structural load — belongs with a competent person and, where relevant, the fire and rescue authority. We refer those rather than answer them, and so should anybody selling you a schedule.
Where this leaves you
The list above is the whole legal minimum, and you can hold your next mobilisation against it this afternoon without buying anything. If it is useful, the question worth asking your team is not "have we got welfare" but "from what date, for what number, and who is reviewing it when the number changes".
If you would rather it were somebody's actual job, the Site Systems Diagnostic produces the schedule, the interim arrangement and the servicing regime as issued documents in ten working days, and the three delivery models set out how far we carry it after that. Send us the headcount curve and the programme and we will tell you where the gap is.
Questions people ask
What welfare facilities are legally required on a UK construction site?
Schedule 2 of the Construction (Design and Management) Regulations 2015 sets the minimum: suitable and sufficient sanitary conveniences, adequately ventilated and lit and kept clean; washing facilities at every convenience and changing room with clean hot and cold or warm running water, soap and a means of drying, plus showers where the work is dirty or carries health risks; an adequate supply of wholesome drinking water, marked where necessary; changing rooms and secure storage with the means to dry clothing where special clothing is worn; and facilities for rest including the means to boil water and prepare and eat a meal, with arrangements for pregnant women and nursing mothers where necessary.
When do welfare facilities have to be available on site?
Before construction work starts, not when the compound is complete. The work of building the compound is itself construction work, so the operatives laying the hardstanding are entitled to the same minimum list as the people who will occupy the offices weeks later. This is the gap we see most often: a correct permanent arrangement that lands three weeks after the first boots, with the intervening period improvised on site. The fix is not more money, it is treating the enabling-works period as its own arrangement with its own dates and its own servicing.
How many toilets does a construction site need?
The regulations require facilities that are suitable and sufficient rather than a fixed ratio, which means the number is a judgement against your actual conditions: total headcount at peak rather than at week one, shift pattern and overlap, how far people have to travel to reach them, and whether the site is split across working areas. A competent person on the project should make and record that judgement, and record it again when the headcount changes materially. A schedule tied to the headcount curve is what makes the judgement defensible later.
Who is responsible for providing welfare facilities on a construction site?
Duties run to more than one party. Under CDM 2015 a client has to take reasonable steps to ensure suitable welfare facilities are provided, and the principal contractor has to ensure they are provided and maintained throughout the construction phase. Contractors carry duties for the work they control. The Health and Safety Executive names seven duty holders in total, and the duties follow conduct rather than contract wording: a business that manages or controls construction work carries contractor duties whatever the paperwork calls it. Procuring the facilities from a supplier does not move the duty.
Does welfare have to be provided on a remote or linear construction site?
Yes, and the practical difficulty of a remote site does not reduce the requirement, though it does change what is reasonably practicable in the specific arrangements. On a linear scheme the harder question is usually travel time: facilities that meet the standard but sit fifteen minutes from the working face are a productivity cost twice a day for every operative, and that cost is almost never measured. Mobile and relocatable arrangements exist precisely for this, and the sequencing of their moves belongs on the programme rather than in somebody's head.
Where this connects to the work
- The engagement these agents produce — nine questions in, twelve deliverables out, ten working days.
- A specimen of the actual deliverable — the level of detail, not a description of it.
- The three delivery models — advisory, integrator and prime, and which one fits.
- How an engagement runs — from first enquiry to an issued, numbered document.
- Working with us as a supplier — prequalification, standards and payment discipline.
- Put the eight questions to us — we would rather be asked them than not.
Sources
Primary sources only. Where this piece states a position rather than a fact, it says so on the line.
- The Construction (Design and Management) Regulations 2015 — legislation.gov.uk
- CDM 2015, Schedule 2 — Minimum welfare facilities required for construction sites — legislation.gov.uk
- Welfare on construction sites — Health and Safety Executive
- L24 — Workplace health, safety and welfare: Approved Code of Practice — Health and Safety Executive
- Summary of duties under the Construction (Design and Management) Regulations 2015 — Health and Safety Executive