Welfare on a construction site is not a courtesy and it is not discretionary. CDM 2015 Schedule 2 sets a minimum standard, and Regulation 13(4)(c) puts the duty on the principal contractor to ensure "facilities that comply with the requirements of Schedule 2 are provided throughout the construction phase."
Two words in that duty do most of the work. "Throughout" means from day one, not once the site is established. And "provided" means actually available to the people working there — not ordered, not on the programme. Regulation 13(4)(c) carries no reasonable-practicability qualifier and is not limited to a contractor's own workers — a point that matters below, because the parallel contractor duty is qualified on both counts.
Schedule 2's own authority line reads "Regulation 4(2)(b), 13(4)(c) and 15(11)", which is the quickest way to see that three different dutyholders are engaged by it, on three different terms.
A jurisdiction note. Regulation 3 applies CDM 2015 "in Great Britain". Northern Ireland has its own instrument — the Construction (Design and Management) Regulations (Northern Ireland) 2016, in operation since 1 August 2016 — so if you work there, check the NI schedule rather than assuming these paragraph numbers apply.
The five categories in Schedule 2
Schedule 2 is titled "Minimum welfare facilities required for construction sites." Minimum is the operative word: it is a floor, not a target.
Sanitary conveniences
"Suitable and sufficient sanitary conveniences must be provided or made available at readily accessible places." So far as is reasonably practicable they must be adequately ventilated and lit, and kept "in a clean and orderly condition". Separate rooms must be provided for men and women, "except where and so far as each convenience is in a separate room, the door of which is capable of being secured from the inside" — a lockable door, on its own, is the whole exception. There is no "one person at a time" test here; that qualifier belongs to washing facilities, below.
"Readily accessible" is the phrase that causes arguments on large or linear sites. A single welfare unit at a compound gate is not readily accessible to operatives working four hundred metres away on a strip-out.
Washing facilities
"Suitable and sufficient washing facilities, including showers if required by the nature of the work or for health reasons, must, so far as is reasonably practicable, be provided or made available at readily accessible places."
Paragraph 2(3) sets what they must include, and the qualifiers are worth reading exactly: "(a) a supply of clean hot and cold, or warm, water (which must be running water so far as is reasonably practicable); (b) soap or other suitable means of cleaning; and (c) towels or other suitable means of drying." The water must be clean; it must be running only so far as is reasonably practicable — which is the provision a genuinely remote or short-duration position turns on, and not a licence to default to a water bowser where plumbed units are achievable.
Separate washing facilities must be provided for men and women, except where they are in a room whose door can be secured from inside and "the facilities in each room are intended to be used by only one person at a time" — both conditions, unlike the sanitary-convenience exception. Facilities provided for washing "hands, forearms and the face only" are outside the separation requirement altogether.
Showers are conditional — required where the nature of the work or health reasons demand them. Work with cement, asbestos-adjacent activity, sewer work or heavy contamination pushes you into that category.
Drinking water
"An adequate supply of wholesome drinking water must be provided or made available at readily accessible and suitable places." Where necessary for health or safety reasons the supply must be clearly marked, and drinking vessels or a jet dispenser must be provided.
The marking requirement exists because non-potable supplies are common on construction sites. An unmarked tap is the failure this addresses.
Changing rooms and lockers
Changing rooms are required where a worker has to wear special clothing for the work and cannot, for reasons of health or propriety, be expected to change elsewhere. They must be provided with seating, and — "where necessary" — facilities to dry special clothing and personal clothing or effects. Separately, "suitable and sufficient facilities must, where necessary, be provided or made available at readily accessible places to enable persons to lock away" special clothing not taken home, their own clothing, and personal effects.
"Where necessary" governs the lockers and the drying facilities. The changing-room trigger itself is the two-limb test in paragraph 4(1) — special clothing and no reasonable alternative place to change — and once both limbs are met the room and its seating are owed without qualification.
Facilities for rest
"Suitable and sufficient rest rooms or rest areas must be provided or made available at readily accessible places." They must have adequate tables and seating with backs — the schedule specifies backs, which rules out benches and upturned crates — plus arrangements for meals to be prepared and eaten, the means of boiling water, maintenance at an appropriate temperature, and, "where necessary, suitable facilities for any woman at work who is pregnant or who is a nursing mother to rest lying down".
That last one is drafted differently from the rest of paragraph 5(2), and the difference is deliberate: sub-paragraphs (a), (c), (d) and (e) are unconditional, while (b) is qualified by "where necessary". So the honest statement of the duty is that it is triggered by need rather than owed unconditionally on every site.
That is not a reason to leave it out of the plan. "Where necessary" is a live assessment, not a default of "no" — it is frequently overlooked on sites that assume an all-male workforce, and a site with women working on it, or one that could reasonably expect them, has to have answered the question rather than never asked it. The practical position is that you decide and record it, not that you can ignore it.
Who provides what
Three duties sit on Schedule 2 at once, and they are not the same duty. Getting this wrong in either direction — assuming the principal contractor's duty covers everyone, or assuming a subcontractor carries nothing — is the common error.
The principal contractor carries Regulation 13(4)(c) on multi-contractor projects: ensuring "facilities that comply with the requirements of Schedule 2 are provided throughout the construction phase." It is unqualified and project-wide. It is not delegable by putting it in a subcontract — you can arrange for someone else to supply the units, but the duty to ensure they are there remains yours.
Every contractor — including a subcontractor on a principal-contractor-managed site — carries Regulation 15(11): "A contractor must ensure, so far as is reasonably practicable, that the requirements of Schedule 2 are complied with so far as they affect the contractor or any worker under that contractor's control."
This is not the same obligation as the principal contractor's and it is not an alternative to it. Read the two side by side: Regulation 15(11) is limited twice over — by reasonable practicability, and to the extent Schedule 2 requirements affect that contractor's own people — where Regulation 13(4)(c) is limited neither way. Two consequences follow. On a single-contractor project there is no principal contractor, so 15(11) is the only contractor Schedule 2 duty in play and it is a weaker one than the multi-contractor position. On a principal-contractor-managed site the subcontractor's duty does not disappear: it does not usually mean bringing your own welfare units, but it does mean satisfying yourself, so far as reasonably practicable, that what is there actually serves your workers — and raising it if it does not. A trade contractor that walks past inadequate welfare for its own operatives has not discharged 15(11) by pointing at the principal contractor.
If a subcontract goes further and shifts welfare provision onto a trade contractor, check carefully what has actually been agreed — that is a commercial allocation on top of 15(11), not the regulation operating by itself.
The client has a direct duty, not merely an upstream influence. Regulation 4(1) requires a client to "make suitable arrangements for managing a project, including the allocation of sufficient time and other resources", and Regulation 4(2)(b) defines arrangements as suitable only if they ensure "the facilities required by Schedule 2 are provided in respect of any person carrying out construction work." That is why Schedule 2's authority line names 4(2)(b) first. A programme or budget that makes adequate welfare impossible is a client failure before it is a contractor one.
Practical points that come up
Shared facilities with an occupied building. Refurbishment and fit-out work often relies on the host building's toilets and canteen. That can satisfy Schedule 2 — the wording is "provided or made available" — but only if access is genuinely available during the hours the work happens, including out-of-hours shifts.
Short-duration work. There is no exemption for short jobs. A two-day job still needs sanitary conveniences and drinking water. Mobile welfare units exist for exactly this.
Sequencing. "Throughout the construction phase" includes the enabling and setting-up period. Welfare that arrives in week two has not met the duty for week one.
Remote or dispersed sites. Linear works, roadworks and multi-plot housing sites need welfare positioned so it is readily accessible from the work face, which usually means more than one location or a mobile unit that moves with the work.
Cleaning and servicing. Schedule 2 requires sanitary conveniences and the rooms containing them to be kept "in a clean and orderly condition" so far as is reasonably practicable, and washing facilities and their rooms to be kept clean and orderly without that qualifier. Provision without a servicing schedule fails the standard within days either way.
A short site check
- Sanitary conveniences: sufficient in number, readily accessible, lit, ventilated, cleaned on a schedule, in separate rooms for men and women or individually lockable from the inside
- Washing: clean hot and cold or warm water — running, so far as is reasonably practicable — soap, drying means; showers where the work requires them
- Drinking water: wholesome, readily accessible, marked where necessary, vessels or jet dispenser available
- Changing: provided where special clothing is worn and changing elsewhere is not reasonable, with seating, and drying facilities where necessary; lockers where necessary
- Rest: tables and seating with backs, means of boiling water and preparing food, adequate temperature — and a recorded assessment of whether facilities for a pregnant or nursing worker to rest lying down are necessary on this site
- All of it in place before anyone starts, and maintained until the phase ends
- If you are a subcontractor rather than the principal contractor, the same list read against Regulation 15(11): is what is here adequate for your workers, and have you raised it if not?
If an HSE inspector visits, welfare is among the first things looked at — it is immediately visible, it needs no document trail to assess, and inadequate welfare tends to signal how the rest of the site is run.
For the principal contractor's wider duties, see our CDM principal contractor duties guide. For the induction that should cover where welfare is located, see our construction site induction guide. For the regulation-by-regulation structure, see our CDM 2015 regulations summary.
SubComply is being built for subcontractor compliance rather than site welfare — tracking the documents, insurance and competence evidence behind the people arriving on your site. Join the waitlist to be notified when it launches.
Sources
- The Construction (Design and Management) Regulations 2015 (SI 2015/51), Schedule 2
- The Construction (Design and Management) Regulations 2015 (SI 2015/51), Regulation 13
- The Construction (Design and Management) Regulations 2015 (SI 2015/51), Regulation 15 (contractor duties, including 15(11))
- The Construction (Design and Management) Regulations 2015 (SI 2015/51), Regulation 4 (client duties, including 4(2)(b))
- The Construction (Design and Management) Regulations 2015 (SI 2015/51), Regulation 3 (application in Great Britain)
- The Construction (Design and Management) Regulations (Northern Ireland) 2016 (SR 2016/146)
- HSE L153 — Managing health and safety in construction: CDM 2015. Guidance on Regulations
This guide is for informational purposes and does not constitute legal advice. For project-specific CDM compliance questions, consult a qualified health and safety professional.
Last reviewed: 21 October 2026