CDM 2015 and Construction Dust
The Construction (Design and Management) Regulations 2015 (CDM) allocate specific duties to principal contractors for managing risks during construction — including dust. CDM applies to all but the smallest construction projects and places the principal contractor in the position of overall responsibility for site health and safety management.
CDM does not prescribe specific dust control methods. It requires principal contractors to plan, manage and monitor construction work so that it is carried out, so far as is reasonably practicable, without risks to health. For dust, this means identifying dust-generating activities, planning controls, implementing them, and monitoring their effectiveness.
The Pre-Construction Phase: Planning
CDM requires principal contractors to develop a Construction Phase Plan (CPP) before work begins. The CPP must identify significant risks — including dust — and set out the arrangements for managing them.
For projects involving significant dust-generating activities (demolition, concrete breaking, masonry cutting, earthworks on contaminated land), the CPP should include:
- Identification of activities that generate hazardous dust (including RCS)
- The control hierarchy to be applied (elimination, engineering controls, administrative controls, PPE)
- Specific engineering controls to be used for each high-risk activity
- Monitoring arrangements to verify controls are effective
- Emergency procedures in the event of a dust incident
Engineering Controls: Priority over PPE
CDM, read alongside COSHH, establishes a clear hierarchy for dust control. Engineering controls — including water suppression — must be considered and used where reasonably practicable before relying on RPE. A worker wearing a dust mask is the last line of defence, not the first.
For demolition and construction sites, the most effective and practical engineering control for most dust-generating activities is water suppression at source. The challenge is delivering water to the point of dust generation — which on a live demolition front moves continuously throughout the working day.
The MW Equipment DustBag is designed specifically for this challenge. Its 2,000L integrated tank provides up to 5 hours of standalone operation — no mains connection — and its 180° oscillating cannon delivers suppression at source. Repositioned by excavator to follow the demolition front. Learn more →
Site Management Obligations During Construction
During the construction phase, the principal contractor must ensure that:
- The CPP is implemented and kept up to date as work progresses
- Controls for hazardous activities — including dust controls — are in place before those activities start
- Workers are informed about the hazards and controls
- Controls are maintained and their effectiveness monitored
- Subcontractors comply with the principal contractor's site rules and the CPP
Critically, dust controls cannot be treated as the subcontractor's responsibility alone. The principal contractor has overall accountability for ensuring controls are in place, regardless of who is carrying out the work.
Documentation
Principal contractors should maintain records of: the CPP and its updates; dust risk assessments for significant activities; the controls in place and evidence they are being maintained; any air monitoring results; and health surveillance records where required. This documentation supports regulatory compliance and is typically requested by clients, H&S auditors and, in the event of an incident, the HSE.
HSE Enforcement
HSE proactively inspects construction sites for dust control compliance, particularly on demolition projects. Where they find inadequate controls, they will issue Improvement Notices (requiring improvement within a set time) or Prohibition Notices (requiring immediate cessation of the dangerous activity). Both carry significant programme and reputational consequences. Prosecution follows in serious cases.