health-safety-file

name	health-safety-file
description	Produces a CDM 2015 Health and Safety File for a named completed (or near-complete) construction project — the as-built residual-risk record handed to the client for future construction, maintenance, cleaning, refurbishment, and demolition. Use this skill whenever a user asks to compile, write, or review a health and safety file, an H&S file, a CDM completion file, or the residual-risk handover information for a structure. It captures the as-built information, the residual and unusual hazards a future worker could not reasonably anticipate, the location of services and hazardous materials, and the cleaning/maintenance safety arrangements — emitting a branded report. Grounded in CDM 2015 Regulation 12(5)–(9). Decision-support only; a competent person must review the output.
license	Apache-2.0
metadata	{"author":"eyekyam","version":"1.0","category":"compliance","tier":2,"audience":["M","C"],"industry":["Con"],"jurisdiction":["All"],"status":"stable","plugin":"hse-construction","hse_reviewed_by":"","hse_reviewed_date":""}

Health & Safety File — CDM 2015 Reg 12(5)–(9)

A consultant-grade HSE skill that produces a task/site-specific CDM 2015 Health & Safety File for a named completed (or near-complete) structure — the as-built residual-risk record the principal designer prepares and maintains and the client retains for future construction, maintenance, cleaning, refurbishment, and demolition (Reg 12(5)–(9)). It captures the as-built & services information, the residual and unusual hazards (with locations) a future worker could not reasonably anticipate, the hazardous materials left in situ, and the maintenance/cleaning/refurb/demolition safety arrangements, grounded in the L153 Appendix-4 H&S-file content list (KB-SNIP-HS-FILE-CONTENT).

Its signature lever is residual-only discipline: the file records only what a future worker could not reasonably anticipate from the structure itself — a full general-spec dump is flagged, not a file. Each located residual hazard's future-work control is framed by the hierarchy of controls via the deterministic A7 controls engine, and any open completion item becomes an owned/dated smart_actions item. The file is part of the PCI → CPP → H&S File chain (Reg 4 → 12 → 12(5)) — it cross-references its siblings via the single KB-SNIP-CONSTRUCTION-CLAUSE-MAP, never assuming a sibling skill ran (the CDM trilogy stays loosely coupled). The H&S File is a structured residual-risk record, not calculation — it uses no scoring/matrix engine.

When to use this skill

Use this skill when the user needs to compile, write, or review a Health & Safety File, an H&S file, a CDM completion file, or the residual-risk handover information for a named structure — for example "compile the CDM Health & Safety File for the Tower B fit-out at handover", "what residual hazards must the maintenance team be told about for this atrium roof", or "review this H&S file before it goes to the client". Trigger phrases: health and safety file, H&S file, CDM completion file, residual-risk handover, as-built residual hazards, Reg 12(5), L153 Appendix 4, could-not-reasonably-anticipate. The load-bearing inputs are the named structure + use and at least one residual/unusual hazard (or a stated "none beyond the obvious" justification); if either is vague, the Workflow intake below refuses to proceed until they are elicited. The H&S File is the handover record at completion — a request for the Pre-Construction Information (CON-02) or the Construction Phase Plan (CON-01) is routed to its CDM-chain sibling (Q1 disambiguates which CDM document).

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.

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.

Jurisdiction / scope	Read
UK	../../knowledge-base/regulatory/cdm-2015.md (CDM 2015 Reg 12(5) — the principal designer prepares & maintains the H&S file; Reg 12(6)–(9) review, update, handover to the client at completion, client retention/availability; the L153 Appendix-4 H&S-file content list)
USA	../../knowledge-base/regulatory/us-osha.md (29 CFR 1926 — as-built / record-retention equivalents)
India	../../knowledge-base/regulatory/in-state-forms.md (BOCW completion records — defers to hse-india / bocw-compliance, mandatory state detection; emit a literal [GAP], never a minted national form number)
EU	../../knowledge-base/regulatory/eu-osh.md
Unknown	Ask before citing any specific law

This skill grounds every run in KB-STD-ISO45001 (6.1.2; 7.5 documented information) and applies KB-SNIP-HOC to every future-work control. It builds the file content heads from KB-SNIP-HS-FILE-CONTENT (the L153 Appendix-4 content list + the "could-not-reasonably-anticipate" residual-hazard test) and grounds the Reg 12(5) principal-designer duty + the handover duty (Reg 12(6)–(9)) on KB-REG-CDM2015 — attributing preparation to the wrong duty-holder, or omitting the handover duty, is a regulatory_citation_accuracy hard-fail. For an India site it resolves the state via KB-REG-IN-STATEFORMS (mandatory state detection) and defers the India leg to the hse-india bocw-compliance skill — legacy-first, never a minted national form number; an un-seeded state → [GAP]. The one-line PCI → CPP → H&S File (Reg 4 → 12 → 12(5)) cross-reference is sourced from KB-SNIP-CONSTRUCTION-CLAUSE-MAP without assuming the PCI or CPP skill ran (loose coupling). 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 (Q1 named structure & use · Q2 file purpose — completion handover / updating an existing file / single-package addition · Q3 residual & unusual hazards present · Q4 as-built information available — each missing item a [GAP] · Q5 future-work scope — maintenance / + refurb / + demolition · Q6 jurisdiction), the UK → CDM 2015 Reg 12(5) path and the mandatory India → state branch (defers to hse-india / bocw-compliance, state detection mandatory, literal [GAP], never a minted national form number), the echo-back, 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 on a generic structure (Q1).

The GATE (refuse-on-vague): no file is produced until a named structure (Q1) AND at least one residual/unusual hazard (Q3) — or a stated "none beyond the obvious" justification — are captured. The file is about what a future worker could NOT reasonably anticipate, not a general-spec dump. Q2 update mode APPENDS, never overwrites prior residual-risk content. Q1 also disambiguates the CDM document — this skill owns the H&S File (the handover record at completion); a request for the PCI (CON-02) or the CPP (CON-01) is routed to its CDM-chain sibling. Full method in references/METHODOLOGY.md.

The H&S-File method (residual-only discipline is the lever)

Full method in references/METHODOLOGY.md, grounded in KB-SNIP-HS-FILE-CONTENT. Steps:

1. De-identify the inputs — before any drafting (the deid block above + the De-identifier-runs-first orchestration rule). Commissioning, survey, or as-built records routinely name an individual (a commissioning engineer with an incident/health note, a surveyor, an occupier) — scrub these to role labels; a leak there is an auto-fail. No worker health detail belongs in the file at all. Flag restricted-distribution where the file carries security-sensitive structural/services detail. (Duty-holders the user deliberately names for the record — the principal designer, the client, owners of open completion items — stay named; those are duty-holder assignments, not leaked PII.)
2. Capture the as-built & services information — what was built and its use; key as-built drawings; the location of services and isolation points — each cited to its source, [GAP] where a record is missing (Q4); never invent an as-built detail.
3. Identify the residual & unusual hazards — apply the "could-not-reasonably-anticipate" test (THE LEVER) — for each system, include an item only if a competent future worker could not reasonably anticipate it from the structure itself (fragile roof glazing, no permanent edge protection at high-level plant, presumed-asbestos lagging, restricted confined-plant egress, buried services on an unusual route). Each residual hazard is LOCATED (where in the structure). A routine/anticipatable hazard or a full general-spec dump is REJECTED — that is a specificity/defensibility failure, not a file.
4. Record the hazardous materials in situ — asbestos register, coatings, insulation, and other materials left in place, with their locations; [GAP] where a survey is outstanding (presumed-present-pending-survey), flagged as a hold-point before disturbance.
5. Frame each residual hazard's future-work control by the hierarchy — for the maintenance/cleaning/refurb/demolition arrangements, propose controls and apply KB-SNIP-HOC via controls.rank_controls + controls.validate_treatment: prefer a higher-order future-work control (specify permanent edge protection / an anchor system at next refurbishment) over a PPE-/admin-only treatment ("wear a harness"); a lower-order-only arrangement with no justification is a defect the Critic/QA pass must catch.
6. Build the maintenance/cleaning/refurb/demolition safety arrangements — for the future-work scope captured at Q5, author the safety information a future worker needs for each foreseeable activity; demolition arrangements still rank controls via .

The orchestration block (below) sits after this Workflow so the triage gate can judge the assembled work before deciding to fan out. The controls HoC-ranking and smart_actions gap-closure calls (steps 5/7) are A7 script calls in every case — never a fan-out job; the H&S File uses no scoring/matrix engine (it is a residual-risk record, not calculation).

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).

Subagent roster for THIS skill

This is a moderate fan-out roster (A6 "moderate = 2–3") for a large structure: the De-identifier is the sequential first gate (not a fan-out peer), then two fan-out jobs — Residual-Hazard-Compiler and Maintenance-&-Handover-Author — with a mandatory Critic/QA and the CDM Principal Designer SME pre-output gate. A small package file runs single-threaded — no subagents — but the controls HoC-ranking, the smart_actions gap-closure call, and the Critic/QA pass are still made. Archetypes: KB-SNIP-ARCHETYPES.

• De-identifier — runs FIRST (sequential gate, not a fan-out peer); scrub all PII / health detail to role labels before any analysis — a commissioning or survey record naming an individual with an incident/health note, surveyors, occupiers, exact dates/locations — everything downstream consumes scrubbed text; a leak is an auto-fail. No worker health detail belongs in the file at all. Set the restricted-distribution flag where the file carries security-sensitive structural/services detail. (Duty-holders the user deliberately names for the record — principal designer, client, open-item owners — stay named.)
• Residual-Hazard-Compiler — apply the "could-not-reasonably-anticipate" test per system from the scrubbed inputs: include a hazard only if a competent future worker could not reasonably anticipate it from the structure; LOCATE each one; record the hazardous materials left in situ (asbestos register / coatings / insulation) with locations. REJECT a routine/anticipatable hazard or a full general-spec dump (that is the residual-only-discipline FLAG). SCOPE-OUT: the future-work arrangements & handover (Maintenance-&-Handover-Author); the law (the SME / Drafter cites Reg 12(5)).
• Maintenance-&-Handover-Author — author the maintenance/cleaning/refurb/demolition safety arrangements for the future-work scope (Q5), framing each residual hazard's future-work control by the hierarchy via controls (a higher-order future-work control before PPE/admin-only); build the information-gaps register (every unknown a [GAP] with an owner + ISO date via smart_actions) and the revision/version control (an update APPENDS, never overwrites). SCOPE-OUT: compiling the residual-hazard set (Residual-Hazard-Compiler).
• SME Reviewer (MANDATORY pre-output gate) — runs the skill-specific SME sign-off in references/sme-review.md (the CDM Principal Designer persona) before any output: is the file residual-only (could-not-anticipate, located — not a spec dump), are hazardous materials in situ recorded, are future-work controls HoC-ranked, and is the Reg 12(5) preparation duty + the handover duty correctly attributed (never the wrong duty-holder), with the India state resolved before any form?
• Critic/QA (MANDATORY) — only residual/unusual hazards a future worker could not anticipate (no general-spec dump), every hazard located, hazardous materials in situ listed, every future-work control HoC-ranked with no unjustified PPE/admin-only, the Reg 12(5) duty + handover cited, an update appends (never overwrites), every gap owned + ISO-dated, the PCI → CPP → H&S File cross-reference present without assuming a sibling ran, every citation traces to the KB, zero input-derived PII leaked. PASS/FAIL.

A small single-package-addition file runs single-threaded — no subagents — but the controls HoC-ranking, the smart_actions gap-closure call, and the Critic/QA pass are still made.

## 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.

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.

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.