| 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.
- 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.
- 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.
- 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.
- 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.
- 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:
- 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.)
- 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.
- 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.
- 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.
- 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.
- 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:
- Build
report.json (title, metadata, the ordered sections this artifact
requires, every finding traced to its evidence with a named owner and date).
- Resolve branding: the user's
brand.yaml overrides the Eyekyam default.
- Render both DOCX and PDF from the one
report.json via the shared engine.
- 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.
