The CDM health and safety file has to outlive every system that IT retires
CDM 2015 puts a duty on the principal contractor and the client. In practice, the platform that duty depends on, is the one your IT team owns, and decommissions on its own schedule
Every construction IT team has a decommissioning list. A collaboration platform gets replaced, a legacy file share gets switched off, a CDE contract lapses and the project moves to whatever the business standardizes on next. Normal lifecycle work, signed off, archived, done.
None of that list usually mentions the CDM health and safety file. It should. The file doesn't belong to a project phase or a platform generation. It's built to survive both, for as long as the structure stands.
What the regulations actually put on IT's desk
The Construction (Design and Management) Regulations 2015 assign the health and safety file a life span that has nothing to do with any system's refresh cycle. Under regulation 4(5)(b) and 4(7), the client keeps the file for the life of the structure, which on most infrastructure and building projects means decades beyond the platform it was first assembled in.
Two duties inside that timeline land squarely on contractors, and by extension on whatever system holds their records:
Regulation 12(7) obliges the principal contractor to give the principal designer any information in its possession that's relevant to the file. Preparation itself sits with the principal designer under regulation 12(5).
Regulation 12(9) can shift review and revision of the whole file onto the principal contractor, where the principal designer's appointment ends first. This is common on design and build contracts, and it means a contractor can end up the long-term custodian of a file it only ever contributed to.
None of this is unusual as a compliance obligation. What's unusual is the mismatch: a duty measured in decades, sitting on infrastructure that's typically replaced every three to seven years.
The gap most IT teams don't know they're carrying
Handover into the file is one-way. A contractor surrenders its information into the principal designer's or client's system, and from that point the contractor's own copy is no longer the record of authority. The problem is that nothing in most environments captures what was surrendered, or when.
That gap shows up in three places IT already owns:
- Platform migration.
When a CDE, SharePoint site, or legacy archive gets retired, files usually migrate. The metadata proving who handed over what, and on which date, doesn't always travel with them. A principal contractor can lawfully hold the entire file mid-project and retain none of it once the project closes.
- Format obsolescence.
A file with a 30- or 50-year retention obligation will outlast the software that created it, more than once. If nothing is actively managing format migration, records become unreadable exactly when a claim or audit needs them open.
- Vendor and contract churn.
CDE vendors get acquired, contracts lapse, hosting arrangements change. Every one of those events is a point where a file with no independent, portable proof of custody can quietly lose its evidentiary value.
“The file outlives every system that produced it, and nothing receipts what the contractor surrendered.”
None of this is a records-management footnote. When a claim, audit, or Building Safety Act inspection arrives ten or twenty years after handover, the question isn't whether the health and safety file exists somewhere. It's whether it's still readable, and whether anyone can prove what was in it, and when it arrived.
Separating the file's survival from any one platform's lifecycle
The fix isn't a better CDE, or a stricter migration checklist for the next platform swap. It's putting the file's long-term custody on infrastructure that's built for a multi-decade retention horizon in the first place, independent of whatever collaboration or storage platform the business runs day to day.
That's what Preservica's Active Digital Preservation does for construction and engineering organizations already managing decades-long retention obligations:
Proves what was surrendered, and when. Every file gets a cryptographic fingerprint on ingest and a tamper-evident audit trail of every action taken on it since. You can demonstrate, mathematically, that a record is identical to the one that was handed over, and produce that proof on demand for a regulator, auditor, or court.
Keeps the file readable past the system that made it. Active format migration runs continuously in the background, so records stay usable long after the authoring software, and often the vendor, is gone.
Lets IT decommission with confidence. A major US construction and engineering firm consolidated long-term records from 11 business units into one preservation archive, replacing ad hoc retention across file shares and legacy systems with a single, defensible, single-query source of truth spanning 15 or more years of data.
- 11 business units consolidated onto one preservation archive, independent of the systems that originally held their records
- 15+ years of historical project data kept format-safe, auditable, and legally defensible throughout
The health and safety file was never really a records-management problem or a construction problem alone. It's an infrastructure problem, and infrastructure with a decades-long duty needs a home that isn't tied to this year's platform roadmap.
To discover how to find, prove, open and defend your records long term, contact us, we'd be delighted to talk it through.
