CDM 2015 and the Control of Asbestos Regulations 2012
Construction work in occupied premises, and what stays with you
An extension, a re-roof, a line install, a summer or Christmas shutdown refit: builders on one part of the site while production, or your own staff, carry on around them. Under CDM 2015 you are the client, and the principal contractor runs the construction phase. Not everything moves to them. This page quotes what stays with you, the asbestos information duty and who it sits with, and says what a sign in record at your front door shows while the work goes on, and what it does not.
Sign in on a demonstration kiosk, then open the fire roll call on your phone. Do not enter real details: everything typed is deleted within the hour.
We are not health and safety consultants, CDM advisers or asbestos surveyors. From £599 setup and £150 a month plus VAT, iPad and stand included.
Three roles
Client, principal contractor, contractor
CDM 2015 gives each its own duties, and the rest of this page keeps them apart. Each is defined in regulation 2(1).
Regulation 2(1)
The client
“client” means any person for whom a project is carried out;
HSE’s guidance, L153, says at paragraph 23 that the definition includes non-domestic, or commercial, clients, and that the Regulations apply in full to commercial clients.
Regulations 2(1) and 5
The principal contractor
“principal contractor” means the contractor appointed under regulation 5(1)(b) to perform the specified duties in regulations 12 to 14;
Regulation 5(1): where there is more than one contractor, or it is reasonably foreseeable that there will be, the client must appoint one in writing. Regulation 5(4): “If the client fails to appoint a principal contractor, the client must fulfil the duties of the principal contractor in regulations 12 to 14.”
Regulation 2(1), and L153 Appendix 3
The contractor
“contractor” means any person (including a non-domestic client) who, in the course or furtherance of a business, carries out, manages or controls construction work;
Where there is more than one, L153 says each contractor “must follow the parts of the construction phase plan prepared by the principal contractor that are relevant to their work.”
The client
What stays with you when a principal contractor is appointed
Regulation 4 and HSE’s guidance, in their own words. Each is written as a duty on the client.
Regulation 4(1) and (3)
Arrangements for managing the project
A client must make suitable arrangements for managing a project, including the allocation of sufficient time and other resources. … A client must ensure that these arrangements are maintained and reviewed throughout the project.
Regulation 4(2) says arrangements are suitable if they ensure that “the construction work can be carried out, so far as is reasonably practicable, without risks to the health or safety of any person affected by the project”.
Regulation 4(4)
Pre-construction information
A client must provide pre-construction information as soon as is practicable to every designer and contractor appointed, or being considered for appointment, to the project.
L153 paragraph 42: “Pre-construction information is information already in the client’s possession (such as an existing health and safety file, an asbestos survey, structural drawings etc) or which is reasonable to obtain through sensible enquiry”.
L153 Appendix 3, paragraph 7
Information for the plan
The client must ensure that the principal contractor (or, where relevant, the contractor) is provided with all the available relevant information they need to draw up the plan, eg the pre-construction information
The plan is the construction phase plan, which regulation 12(1) gives the principal contractor to draw up.
Regulation 4(6)(b)
Reasonable steps
A client must take reasonable steps to ensure that … the principal contractor complies with any other principal contractor duties in regulations 12 to 14.
The duties in regulations 12 to 14 are the principal contractor’s. Taking reasonable steps to ensure they are met is the client’s.
Two passages about the site that keeps running
Both are for the principal contractor to meet, not you. They are here because both name what goes on around the work: the industrial activities, and the client’s employees.
Regulation 12(2), a principal contractor duty
The construction phase plan must set out the health and safety arrangements and site rules taking account, where necessary, of the industrial activities taking place on the construction site
L153 paragraph 123, on the principal contractor’s planning
Planning must take into account the risks to all those affected: workers, members of the public and the client’s employees, if working in an occupied premises.
Regulations quoted from legislation.gov.uk and checked against L153, HSE’s guidance on CDM 2015, where they are on pages 14, 15 and 34. Paragraph 42 is on page 18, paragraph 123 on page 38 and Appendix 3 paragraph 7 on page 78. Read on 28 September 2026.
The principal contractor
The construction site’s gate is theirs
These are the principal contractor’s duties. They are set out here so it is plain they are not yours, and not a kiosk’s. Where the guidance says should, so does this page.
Regulation 13(4)
Induction and unauthorised access
The principal contractor must ensure that (a) a suitable site induction is provided; (b) the necessary steps are taken to prevent access by unauthorised persons to the construction site;
Item (c) is welfare facilities. All three are the principal contractor’s duties.
L153 paragraph 134
Inductions for occasional visitors
Site inductions should also be provided to those who do not regularly work on the site, but who visit it on an occasional (eg architects) or once-only basis (eg students). The inductions should be proportionate to the nature of the visit. … Escorted visitors only need to be made aware of the main hazards they may be exposed to and the control measures.
Guidance on the principal contractor’s duty in 13(4)(a), and it says should.
L153 paragraph 135
Only those authorised
The principal contractor should also take steps to ensure that only those authorised to access the site do so.
The paragraph opens: “The principal contractor must ensure reasonable steps are taken to prevent unauthorised access onto the construction site.”
L153 Appendix 3, paragraph 13
Site rules
The rules should be clear and easily understandable. They should be brought to the attention of everyone on site who should be expected to follow them.
About the site rules in the construction phase plan, which is the principal contractor’s.
Regulation 2(1)
What the construction site is
“construction site” includes any place where construction work is being carried out or to which the workers have access, but does not include a workplace within the site which is set aside for purposes other than construction work;
The access duty in 13(4)(b) is about the construction site as defined here.
Regulations 2(1) and 13(4) quoted from legislation.gov.uk and L153 pages 10 and 37; paragraphs 134 and 135 from page 40 and Appendix 3 from page 79, read on 28 September 2026.
The contractor sign in system, the part at your doorA free contractor induction record
Control of Asbestos Regulations 2012, regulation 4
The asbestos information duty, and who it sits with
Regulation 4 is the duty to manage asbestos in non-domestic premises. It sits with the dutyholder, and who that is on your site is in the regulation’s definition, quoted here in full, not in a summary of ours. It is not a CDM role.
Regulation 4(1)
Who the dutyholder is
In this regulation “the dutyholder” means (a) every person who has, by virtue of a contract or tenancy, an obligation of any extent in relation to the maintenance or repair of non-domestic premises or any means of access or egress to or from those premises; or (b) in relation to any part of non-domestic premises where there is no such contract or tenancy, every person who has, to any extent, control of that part of those non-domestic premises or any means of access or egress to or from those premises, and where there is more than one such dutyholder, the relative contribution to be made by each such person in complying with the requirements of this regulation will be determined by the nature and extent of the maintenance and repair obligation owed by that person.
Regulation 4(9)(c)
Information to anyone liable to disturb it
The measures to be specified in the plan for managing the risk must include adequate measures for … (c) ensuring that information about the location and condition of any asbestos or any such substance is (i) provided to every person liable to disturb it, and (ii) made available to the emergency services.
Regulation 4(2)
Everyone else cooperates
Every person must cooperate with the dutyholder so far as is necessary to enable the dutyholder to comply with the duties set out under this regulation.
Quoted from regulation 4 on legislation.gov.uk, read on 28 September 2026, with no outstanding amendment or revocation shown. HSE’s overview of the duty to manage lists among the dutyholder’s steps to “make, and keep up to date, a record or register of the location and condition of the ACMs or presumed ACMs”.
At your front door
What the kiosk records
- Who came in, and for whomName, company and the person they are visiting, all three required, with a vehicle registration if they give one. A contractor signs in on the iPad as any visitor does.
- That they accepted your wordingYour site’s wording on screen, with Go Back and I Accept. The sign in is refused until it is accepted, and the record keeps the exact wording each person accepted, by its fingerprint, after you change it.
- A message to your channelEach sign in posts to your site’s Microsoft Teams or Slack channel, where one is connected, with the name, company, the person they are visiting and the registration. One channel per site, not a message to the host, and nothing is sent on sign out.
- Who is on site nowThe live fire roll call, from the moment they sign in until they sign out, read on a phone at the assembly point.
- The historyEvery sign in and sign out, searchable by name, company or host and by date, kept for your company’s retention period, a year unless you set between one day and two years. It exports as a spreadsheet of name, company, who they visited and both times, in UK time. The export does not carry the wording; the history shows it for each person.
And what it does not do
What stays a person’s job
- Hold, show, link to or check your asbestos register. Your own wording can say where the register is kept and that it must be checked before anyone disturbs the fabric of the building. The kiosk shows that wording and records who accepted it, and when. Nothing more.
- Show contractors a different wording. There is one text per site, falling back to the company’s, not one per kind of visitor, so a line about the asbestos register is shown to every visitor and every driver who signs in too.
- Keep a night shift on the roll call. Anyone still signed in at 23:59 UTC is signed out automatically at that time, which is 23:59 in winter and 00:59 in summer, UK time. A contractor working a night shutdown through it leaves the roll call mid-shift, and the record shows that time, not when they left. To be back on the roll call, they sign in again.
- Check a CSCS card, a trade card or any ID, play an induction video, or ask questions. The contractor accepts your wording, and the acceptance is what is recorded.
- Give the site induction or keep unauthorised people off the construction site. Regulation 13(4) gives both to the principal contractor, and the kiosk opens no door.
- Decide who is authorised, or who is the client, the principal contractor or a contractor on your project. That is in the regulations and your contracts.
This is the platform sign in. With the Permit to Work module, which is in early access, a contractor who uses its separate Contractor button signs on to a permit instead; that route does not show the wording above and is not signed out at 23:59.
See it work
A sign in and a fire roll call, in 100 seconds
A visitor signs in on the iPad. The alarm goes. The marshal opens the live list on their phone at the muster point and reads off who is still on site. A contractor signs in the same way.
The player loads from YouTube only when you press play. Nothing is sent to Google before that. What happens when you do.
Before you ask
The questions a client asks before the builders arrive
Are we the client under CDM 2015 when builders work at our factory?
Regulation 2(1) of CDM 2015 says “client” means any person for whom a project is carried out. HSE’s guidance, L153, says at paragraph 23 that the definition includes non-domestic, or commercial, clients, and that the Regulations apply in full to commercial clients. Whether a given project is yours is in that definition and your contracts.
What stays with us when a principal contractor is appointed?
Among other things, in regulation 4: suitable arrangements for managing the project, maintained and reviewed throughout it (4(1) and (3)); pre-construction information to every designer and contractor as soon as is practicable (4(4)); and reasonable steps to ensure the principal contractor complies with its duties in regulations 12 to 14 (4(6)(b)). L153 Appendix 3 adds that the client must ensure the principal contractor is provided with all the available relevant information they need to draw up the construction phase plan.
Who has to tell the builders where the asbestos is?
Regulation 4(9)(c) of the Control of Asbestos Regulations 2012 says the measures in the dutyholder’s plan must include adequate measures for ensuring that information about the location and condition of any asbestos is provided to every person liable to disturb it, and made available to the emergency services. Regulation 4(1) defines the dutyholder, and this page quotes it in full. Under CDM 2015, L153 paragraph 42 gives an asbestos survey as an example of the pre-construction information a client already holds.
Can the kiosk show contractors our asbestos register?
No. It does not hold, show, link to or check the register. Your own wording, shown at sign in, can say where the register is kept and that it must be checked before anyone disturbs the fabric of the building, and the kiosk records who accepted that wording and when. The wording is one text per site, so every visitor and driver who signs in sees the same line.
What happens to contractors working a night shutdown?
Anyone still signed in at 23:59 UTC is signed out automatically at that time: 23:59 in winter and 00:59 in summer, UK time. A contractor who signed in for a night shift leaves the live roll call at that moment while still on site, and the record shows that time as their sign out. To be on the roll call again, they sign in again.
What does it cost?
The kiosk platform is £150 a month plus VAT per site, with setup from £599, and the iPad and stand are included. There is no charge per visitor, and a contractor signs in as a visitor does. The two optional modules are £150 a month each.
Being straight with you
What this does not do
- We are not health and safety consultants, CDM advisers, asbestos surveyors or competent persons, and nothing here is safety or legal advice. The regulations and HSE’s guidance are quoted and linked; read them at source.
- For construction work in scope of CDM 2015 there are duties on you that a sign in system has nothing to do with. This page quotes some of them, not all.
- The kiosk does not make you compliant with CDM 2015 or the Control of Asbestos Regulations 2012, and discharges no duty under either. It produces a record: who signed in, for whom, when they left and the wording each person accepted.
- It is not a construction site system. A construction site with a turnstile and card checks needs a different kind of system; the kiosk is for the front door of the site that keeps running.
Sources
Check any of this yourself
- HSE, L153, Managing health and safety in constructionGuidance on CDM 2015, published 2015, free from HSE. Paragraphs 23, 42, 123, 134 and 135 and Appendix 3 paragraphs 7, 13 and 15 are quoted. Paragraph 123 prints a dash after “affected”; a colon is set here. Read 28 September 2026.
- The Construction (Design and Management) Regulations 2015SI 2015/51 on legislation.gov.uk, latest available, with no outstanding effects shown. Regulations 2(1), 4, 5, 12(2) and 13(4) are quoted from here, and match L153 but for one word in the definition of principal contractor. Where a regulation prints a dash before a list, the list follows without it. Read 28 September 2026.
- The Control of Asbestos Regulations 2012, regulation 4SI 2012/632 on legislation.gov.uk, latest available, with no outstanding effects shown. Regulation 4(1) is quoted in full, and 4(2) and 4(9)(c) as printed. Read 28 September 2026.
- HSE, The duty to manage asbestos in buildingsFree. Among the dutyholder’s steps it lists: “make, and keep up to date, a record or register of the location and condition of the ACMs or presumed ACMs”, and it says the duty covers “all non-domestic premises, like factories or shops”. Read 28 September 2026.
- HSE, Commercial clients: roles and responsibilitiesFree. HSE’s own page for the client under CDM 2015. Read 28 September 2026.
General information about published legislation and HSE guidance, not safety or legal advice. HSE has no connection with Noon Elite.
ISO 45001 and contractorsWhat an HSE inspector can ask to see
Also asked of sites like yours
The other things somebody may ask you to evidence
Each of these is a page about one standard, one duty or one visitor, written the same way as this one: what it actually asks for, what an iPad at reception records towards it, and where it does not help.
Every standard on one page: the clause numbers, the version and the date each was read, on one printable table.
- GDPR and the visitor book
- CMMC physical security
- List X visitor control
- ITAR visitor log
- Def Stan 05-138 visitor access
- ISO 27001 visitor access
- PCI DSS visitor log
- AEO visitor access control
- CTPAT visitor log
- TISAX visitor management
- TAPA FSR visitor log
- BRCGS visitor control
- BRCGS packaging visitor control
- BRCGS storage and distribution visitors
- BRCGS unannounced audit
- Visitor control non-conformity
- SALSA visitor control
- IFS Food visitor hygiene
- UFAS feed mill visitor control
- GMP visitors in production areas
- GDP wholesale visitor control
- Fire roll call
- Contractor management
- HSE inspection records
- ISO 45001 contractor control
- Visitor NDA sign in
- Visitor record retention
- What a visitor log must contain
- Standards calendar
- Sign in sheet template
- Visitor health questionnaire template
- Contractor induction template
- Permit to work template
- Hot work permit template
- Fire drill record template
Advise sites on this standard? Referral terms are on one page.
Next step
Tell us about the work, and the door your own people use
Fifteen minutes on the phone. What the work is, how many trades, whether it runs through the night, and who comes through your front door while it does. We will tell you straight whether a kiosk helps, and what it will not do.
Book a 15 minute callNo site visit needed and nothing to install. If it is not a fit we will say so on the call.
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