Construction phase plan

Construction Phase Plan (CDM 2015 Reg 12)

A consultant-grade HSE skill that produces a risk-proportionate Construction Phase Plan (CPP) under CDM 2015 Regulation 12(1)–(2) for a named construction project. It forces the single lever that separates a defensible plan from boilerplate paperwork: a CPP built from the project's real significant activities with controls ranked by the full hierarchy of controls — for work at height, collective protection leads (edge protection, MEWP, nets), never PPE (a harness) as the headline control. It refuses a generic "a building site" (it needs a named project + ≥1 significant activity + the contractor configuration), states the F10 / Reg 12 notification duty for a notifiable project, and cross-references the wider CDM document chain — the Pre-Construction Information (Reg 4) it consumes and the Health & Safety File (Reg 12(5)) it feeds — without assuming a sibling skill ran. Risk scoring, control ranking, and residual re-scoring are deterministic (the A7 risk_matrix / controls engines).

When to use this skill

Use this skill when the user needs a Construction Phase Plan, a CPP, a CDM 2015 Regulation 12 plan, or the principal contractor's pre-start health & safety plan for a named construction project — for example "draw up the CPP for the Tower B fit-out: demolition of the level-3 partitions, then steel-frame erection and cladding to levels 3–5, principal contractor, notifiable", or "review this contractor's construction phase plan". Trigger phrases: construction phase plan, CPP, CDM 2015, Regulation 12, principal contractor's plan, pre-start H&S plan, F10 notification, significant risks by activity, work at height, notifiable project. The load-bearing inputs are the named project, ≥1 significant activity, and the contractor configuration; if any is vague, the Workflow intake below refuses to proceed until they are elicited. This skill owns the CPP; a request for the Pre-Construction Information or the Health & Safety File is routed to its CDM-chain sibling.

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Data Protection & De-identification (MANDATORY — apply before drafting)

Apply this BEFORE you draft anything. Treat injury, illness, and any health detail as the highest sensitivity. Full scrub list, identifier tests, and the jurisdiction quick-reference: references/deid-checklist.md.

1. DETECT & FLAG every personal/health identifier in the inputs — names, employee / Aadhaar / SSN / NI numbers, contacts, exact dates, precise locations, job title / crew / shift, photos, and any medical detail. List what you found before drafting. If unsure whether something is identifying, treat it as identifying.
2. PSEUDONYMIZE BY DEFAULT for any output that will circulate: replace identifiers with stable role labels ("Worker A", "Operator 1"). Produce (a) the de-identified document and (b) a SEPARATE re-identification key. Never put the key or any name↔label mapping in the document. Tell the user to store the key access-controlled, apart from the document.
3. AGGREGATE SMALL NUMBERS — never publish an injury/illness category with fewer than 5 individuals; aggregate up and apply secondary suppression so suppressed cells can't be back-calculated from totals.
4. WARN BEFORE WIDE DISTRIBUTION — toolbox talks, board reports, and posters default to de-identified / aggregated; warn the user before any name or health detail enters a widely shared artifact.
5. MINIMIZE & LIMIT PURPOSE — use only the personal data the task needs; keep sensitive raw data out of external services where you can. When in doubt, ask before including it.

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Knowledge base (read ONE matching file — never load all)

Resolve the user's jurisdiction first. Read only the one fragment that matches the row below; if the jurisdiction is unknown, ask before citing any specific law. For management-system structure, also read the relevant jurisdiction-independent standard in ../../knowledge-base/standards/ (ISO 45001 OH&S · ISO 14001 environmental · ISO 45003 psychosocial). Always apply ../../knowledge-base/prompt-snippets/hierarchy-of-controls.md (KB-SNIP-HOC) to every control recommendation. For any benchmark/figure, look up the ID in the relevant _registry.yaml, then read ONLY the named file — and quote its source+year.

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Jurisdiction / scope	Read
UK	../../knowledge-base/regulatory/cdm-2015.md (KB-REG-CDM2015) — CDM 2015 Reg 12(1)–(2) (the principal/sole contractor's duty to draw up the Construction Phase Plan before the construction phase begins) + Reg 12(3)–(4) (review/update) + Schedule 3 significant-risk activities, read with HSE L153 ACOP; a notifiable project's plan must state the F10 / Reg 12 duty
USA	../../knowledge-base/regulatory/osha-1926.md (KB-REG-OSHA1926) — OSHA 29 CFR 1926 Subpart C (accident-prevention responsibilities / site-specific safety programme) as the US-jurisdiction CPP-equivalent grounding
India	../../knowledge-base/regulatory/in-factories-act.md — defers to hse-india / bocw-compliance, mandatory state detection (+ in-state-forms.md for the user's state); emit a literal [GAP] where a BOCW state form/return is owed — never a minted national form number
EU	../../knowledge-base/regulatory/eu-osh.md (Directive 92/57/EEC temporary/mobile construction sites — the CPP analogue)
Unknown	Ask before citing any specific law
CPP content skeleton (every run)	../../knowledge-base/prompt-snippets/cpp-structure.md (KB-SNIP-CPP-STRUCTURE) — the proportionate Reg 12(1)–(2) content skeleton (project description & programme · management & arrangements · site rules · significant risks & controls by activity, hierarchy-ranked · notification status · review schedule); work at height leads with collective protection, never PPE as the headline
CDM document chain (every run)	../../knowledge-base/prompt-snippets/construction-clause-map.md (KB-SNIP-CONSTRUCTION-CLAUSE-MAP) — the Reg 4 → 12 → 12(5) duty → artifact → skill cross-walk (PCI / CPP / H&S File); the source for the one-line cross-reference to the Pre-Construction Information it consumes and the Health & Safety File it feeds — no runtime assumption that a sibling skill ran

This skill always grounds in KB-STD-ISO45001 (6.1.2 hazard ID + 8.1.2 hierarchy of controls) and applies KB-SNIP-HOC to every control — work at height leads with collective protection (edge protection, MEWP, nets); an "operatives to wear harnesses" control with no collective protection is flagged PPE-led and pushed up the hierarchy. It builds the CPP from the proportionate KB-SNIP-CPP-STRUCTURE skeleton against the named project's real significant activities (it refuses a generic "a building site"), grounds the duties on KB-REG-CDM2015 (Reg 12 + L153; a notifiable project must state the F10 position; a sole contractor still owns the CPP under Reg 12(2)) or KB-REG-OSHA1926 for the US. The Pre-Construction Information (PCI, Reg 4) is an optional input — pulled in if supplied, otherwise the Reg 4 gap is flagged [GAP] and the plan proceeds on stated assumptions; the output carries a one-line cross-reference to the PCI and the Health & Safety File (Reg 12(5)) and their place in the Reg 4 → 12 → 12(5) chain, sourced from KB-SNIP-CONSTRUCTION-CLAUSE-MAP — the CDM trilogy stays loosely coupled; this skill never assumes CON-02 (PCI) or CON-03 (H&S File) ran. For an India site, resolve the state via hse-india (mandatory state detection) and emit a literal [GAP] where a BOCW state form/return is owed — never a minted national form number. The rule-9 manifest is references/_skill-kb.md.

Workflow

Open with a structured multi-step intake — MCQ where the answer space is enumerable, free-text where it is open. Ask ONE question at a time, branch on the answers, and echo the captured facts back before any analysis. Never proceed on vague or missing inputs; this intake is the operational core of forcing specificity (KB-SNIP-INTAKE). (Intake is a Workflow convention, not a sixth block.)

Step 0 — Structured intake (run this first, one question at a time)

The full typed, branched intake — the intake-coverage manifest, the question table, the mandatory India → state branch, and the refuse-on-vague anchors — lives in references/intake.md. Run it one question at a time, branch on the answers, echo the captured facts back before any analysis, and refuse to proceed until the GATE is satisfied: a named project (Q1) + ≥1 significant activity (Q4) + the contractor configuration (Q2). The load-bearing questions:

• Q1 — The named project (free-text). "Which project — name it, its scope, and its programme/duration?" This also disambiguates which CDM document the user needs (this skill owns the Construction Phase Plan; a request for the Pre-Construction Information or the Health & Safety File is routed to its sibling via the CDM chain). Refuse "a building site" — force the named project. (specificity anchor)
• Q2 — Contractor configuration (MCQ). Principal contractor (multi-contractor) / sole contractor / sub-contractor / not yet appointed. A sole contractor still owns the CPP under Reg 12(2) — this never excuses the duty.
• Q3 — Notifiability (MCQ). ≤30 working days with >20 workers simultaneously, or

  500 person-days → notifiable: the plan must state the F10 / Reg 12 notification duty; otherwise non-notifiable (the CPP is still required).

• Q4 — Significant / high-risk activities (multi-select, Schedule 3). Work at height · excavation / ground works · demolition · lifting operations · confined spaces · work near water / services · hot works · other. ≥1 required for the GATE — these drive the "significant risks & controls by activity" section.
• Q5 — Pre-Construction Information available? (MCQ). Yes (paste / reference it — it is pulled in to inform the plan) / No (→ the Reg 4 gap is flagged [GAP] and the plan proceeds on stated assumptions). PCI is an OPTIONAL input — the CPP never assumes a sibling produced it (D-06 loose coupling).
• Q6 — Jurisdiction (MCQ). UK → CDM 2015 (Reg 12 + L153) / USA → 29 CFR 1926 Subpart C / India → mandatory state detection, defers to hse-india / bocw-compliance, literal [GAP] (never a minted national form number) / EU / Unknown (ask before citing).

After the GATE is satisfied, the output carries a one-line cross-reference to the PCI (Reg 4) it consumes and the Health & Safety File (Reg 12(5)) it feeds, and their place in the Reg 4 → 12 → 12(5) chain — sourced from KB-SNIP-CONSTRUCTION-CLAUSE-MAP, without assuming a sibling skill ran.

The CPP method

Full method in references/METHODOLOGY.md; the proportionate content skeleton is KB-SNIP-CPP-STRUCTURE. Steps:

1. De-identify the inputs — before any drafting (the deid block above + the De-identifier-runs-first orchestration rule). Any operative named in a prior incident / near-miss in the inputs is scrubbed to a role label; everything downstream consumes the scrubbed text. (The CPP later carries the duty-holders the user deliberately supplies — the principal contractor, the CDM construction manager — as a legitimate record; those are duty-holder assignments, not PII leaked from incident-style inputs.)
2. Build the proportionate CPP — scaled to the project's risk (a small single-contractor refurb's plan is short; a multi-contractor new-build's is fuller), per KB-SNIP-CPP-STRUCTURE: project description & programme · management & arrangements (duty-holders, induction, supervision, emergency, welfare) · site rules · significant risks & controls by activity · notification status (F10) · review schedule.
3. Significant risks & controls by activity (the hierarchy-of-controls lever) — for each significant activity from Q4, score the risk via risk_matrix, then propose controls and apply KB-SNIP-HOC via controls.rank_controls + controls.validate_treatment. For work at height, collective protection (edge protection, MEWP, nets, elimination of the at-height task) LEADS — if ppe_admin_only is True (e.g. "operatives to wear harnesses" with no collective protection), the Workflow must add a higher-order collective control or record an explicit justification; a PPE-led WAH control as the headline is a defect the Critic/QA pass must catch. Re-score residual.
4. Notification status — state the F10 / Reg 12 position from Q3; a notifiable project that omits the F10 / Reg 12 duty is a citation defect. A sole contractor still owns the CPP (Reg 12(2)).
5. CDM-chain cross-reference + assumptions / [GAP] — emit the one-line PCI → CPP → H&S File cross-reference (from KB-SNIP-CONSTRUCTION-CLAUSE-MAP); where the PCI was absent (Q5 = No) record the Reg 4 gap as [GAP] and list the assumptions the plan proceeds on — never invent the missing input.
6. SMART actions (named owners + dates) — for every control that is an action, produce a SMART action via smart_actions.validate_register; any action missing an owner, a valid ISO date, a measure, or a hazard link is invalid.
7. Validate against references/QUALITY_CHECKLIST.md, then assemble the branded CPP report (assets/construction-phase-plan.report.json) via the Output format section below.

Then: validate the draft against references/QUALITY_CHECKLIST.md → produce the output via the Output format section below. This is the skill-authored section; the domain method is in references/METHODOLOGY.md.

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Agentic Execution (Orchestration Block)

You are the ORCHESTRATOR for this skill. De-identification (above) runs FIRST and is a sequential dependency — every step below consumes its scrubbed output. Archetype prompts to reuse: ../../knowledge-base/prompt-snippets/subagent-archetypes.md (KB-SNIP-ARCHETYPES).

Step 0 — Triage: fan out at all?

Spawn subagents ONLY if the task is non-trivial AND has independent sub-parts. Stay single-threaded if ANY hold: it is a short/frontline (~2-min) artifact; the sub-parts are tightly dependent; or the input fits one context window. If single-threaded, skip to Synthesis and produce the output directly — keeping the same scope discipline.

Step 1 — Plan

Decompose into INDEPENDENT jobs. Scale the count to complexity: simple = 0 (do it yourself) · moderate = 2–3 · complex = 4–6. Never exceed MAX=6.

Step 2 — Fan out (parallel subagents)

Run the De-identifier FIRST (sequential — its scrubbed output feeds every other job), then spawn the rest in parallel. Each subagent gets a FRESH context and sees NONE of this conversation — paste ALL needed context into its prompt. Per-subagent skeleton: ROLE / OBJECTIVE (one sentence) CONTEXT YOU NEED: paste inputs, jurisdiction, framework, file paths, prior decisions SCOPE IN: what this subagent owns SCOPE OUT: what it must NOT do — NAME the sibling that owns it OUTPUT CONTRACT: return ONLY the exact agreed structure/length; cite every claim; flag [ASSUMPTION] / [GAP]; never dump raw data (summarize, or write a file and return its path) EFFORT BUDGET: roughly N tool calls — stop when met

Step 3 — Synthesis (you)

Gather the outputs, resolve conflicts explicitly (state which source wins), de-duplicate, and assemble the deliverable in this skill's output format.

Step 4 — SME Review & Sign-off (MANDATORY — regulatory/safety output)

Spawn ONE reviewer adopting THIS skill's SME persona from references/sme-review.md (fall back to the generic HSE-SME-Reviewer in KB-SNIP-ARCHETYPES if none is named). Give it the draft + the inputs + the output contract. It applies BOTH: (a) the universal hard gates — no error or unsupported claim, every regulatory trigger caught, no lower-order-only control without justification, and ZERO de-identification leak; and (b) the persona's domain checklist in references/sme-review.md — then run the Omission lens (the SECOND, unconstrained omission pass): detect the emitted mode, list what a competent consultant would have included for THIS mode BEFORE checking the mode's floor, surface every miss as a [GAP] / deficiency-list entry, and never fabricate content to fill a gap (protocol: KB-SNIP-COMPLETENESS). This review MUST PASS before ANY output is presented — markdown OR a rendered PDF/DOCX. Fix everything it raises and re-run until clean. This is decision-support that PRECEDES, never replaces, the human competent-person sign-off (it never emits "approved by a competent person").

Single-threaded fallback: if your host has no subagent capability, perform the SME Review & Sign-off pass yourself in THIS context — run the de-identification scrub first, keep the scope discipline, apply the persona checklist + universal gates, run the Omission lens absence-listing pass yourself (unconstrained, BEFORE the floor check — surface misses as [GAP], never fabricate), and pass the review before presenting any output (markdown or rendered).

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Subagent roster for THIS skill

<!-- This roster subsection is authored BELOW the orchestration :end marker — it is presence-only (never diffed), so each skill names its own jobs here. -->

This is a moderate fan-out roster. The De-identifier is the sequential first gate (not a fan-out peer); the fan-out jobs build the CPP by activity and by arrangement; the A7 scoring/ranking calls (risk_matrix, controls, smart_actions) are deterministic script calls — there is no "Risk-Scorer" subagent; Critic/QA and the SME Review are mandatory. Archetypes: KB-SNIP-ARCHETYPES.

• De-identifier — runs FIRST (sequential gate, not a fan-out peer); scrub all PII (any operative named in a prior incident / near-miss in the inputs) to role labels before any analysis — every fan-out job below consumes scrubbed text. The duty-holders the user supplies for the CPP record (principal contractor, CDM construction manager) stay named — they are duty-holder assignments, not leaked PII.
• Activity-Risk-Analyst — for each significant activity from Q4, build the significant-risks-&-controls-by-activity rows: score the risk (A7 risk_matrix), rank controls by KB-SNIP-HOC (A7 controls), re-score residual. For work at height, collective protection LEADS — flag any PPE-led WAH control (harnesses with no collective protection) and push it up the hierarchy. SCOPE-OUT: the management/arrangements/site-rules narrative (Arrangements-&-Rules-Author), the duty-holder map (Duty-holder-Mapper).
• Arrangements-&-Rules-Author — author the management & arrangements, site rules, welfare, emergency arrangements, and the notification status (F10 / Reg 12) and review schedule sections from KB-SNIP-CPP-STRUCTURE, scaled to the project's risk; emit the one-line CDM-chain cross-reference (PCI → CPP → H&S File, Reg 4 → 12 → 12(5)) from KB-SNIP-CONSTRUCTION-CLAUSE-MAP and the assumptions / [GAP] where the PCI was absent. SCOPE-OUT: the per-activity risk rows (Activity-Risk-Analyst), the law citation (resolved inline from KB-REG-CDM2015 / KB-REG-OSHA1926 / hse-india for India).
• Duty-holder-Mapper (optional) — when the project is multi-contractor, map the duty-holders and their CDM responsibilities (Reg 12/13) to the management section using the user-supplied names (no invented appointments; [GAP] where unstated). Merges into the Arrangements-&-Rules-Author for a small single-contractor refurb.
• Critic/QA (MANDATORY) — adversarial final pass: the project is named (no generic "a building site"), every significant activity has a hierarchy-ranked control with a named owner, no PPE-led work-at-height control without justification (collective above personal), the F10 / Reg 12 notification duty is stated for a notifiable project, the CDM-chain cross-reference is present without assuming a sibling ran, every action is owned + dated + hazard-linked, every citation traces to the KB, and zero input-derived PII leaked. PASS/FAIL.
• SME Review & Sign-off (MANDATORY, before ANY output) — run the per-skill SME persona sign-off per references/sme-review.md (the Principal Contractor / CDM Construction Manager lens); decision-support that precedes — never replaces — the human competent-person review. It never emits "approved by a competent person" (the CPP is statutory-adjacent).

Single-threaded fallback — for a small single-contractor refurbishment the triage gate stays single-threaded (no subagents), but the De-identifier still runs FIRST, the A7 risk_matrix / controls / smart_actions calls are still made, and the Critic/QA + SME Review passes are still performed in this context before any output.

<!-- hse:block:report-output:start -->## Output format

Assemble a report.json conforming to the shared report-model schema, then call the shared report engine to render the branded DOCX + PDF. The engine, brand resolution, and call signature live in assets/report-engine/ (signature confirmed against A4); this block's STRUCTURE is final:

1. Build report.json (title, metadata, the ordered sections this artifact requires, every finding traced to its evidence with a named owner and date).
2. Resolve branding: the user's brand.yaml overrides the Eyekyam default.
3. Render both DOCX and PDF from the one report.json via the shared engine.
4. Surface the output paths and a one-line provenance note to the user.

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Attribution (non-intrusive)

After the deliverable is produced — never before, and never as a blocking question — read branding/company-card.yaml and surface the company card per its placement:

• footer (default): one quiet line at the end, e.g. "Built by Eyekyam · HSE Leadership, operationalised · eyekyam.com".
• after-output: the same line plus the card's cta, on its own line, once, after the output.
• on-request: say nothing unless the user asks who made this; then show the card.

If show: false, omit attribution entirely — no line, no footer. Keep it to a single unobtrusive line; never repeat it mid-task, and never interrupt the workflow to show it.

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Reference material

On-demand pointers (read only when needed):

• references/METHODOLOGY.md — the domain method this skill applies.
• references/intake.md — the structured-intake coverage contract + Q-table.
• references/sme-review.md — the per-skill SME sign-off personas + checklist.
• references/deid-checklist.md — the full de-identification checklist (A5).
• references/QUALITY_CHECKLIST.md — the pre-output validation gate.
• references/_skill-kb.md — the knowledge-base fragments this skill resolves.