Sealant work can look minor next to the main build. A few days with a gun and a knife, perhaps some access equipment. But in law it is construction work, and the same framework applies as on any other package. Clients and main contractors who treat it as a quick add-on sometimes find gaps in their paperwork at exactly the wrong moment.
This article sets out the basics of CDM 2015 as it touches sealant work, what risk assessments and method statements (RAMS) should contain, and the site paperwork clients usually ask for. It is a practical overview, not legal advice. For the full picture, HSE’s CDM 2015 pages are the place to start.
CDM 2015 applies to sealant jobs too
The Construction (Design and Management) Regulations 2015, usually called CDM 2015, apply to construction work of all sizes. That includes resealing a run of windows, a floor joint package or fire-rated sealing in a riser. There is no minimum size below which the regulations stop applying.
What changes with size is how much paperwork and coordination is needed. A single-contractor job on an occupied office still needs planning, but it won’t look like a multi-trade new build. The principle is proportion: enough planning and information to manage the real risks, without filling files for the sake of it.
Who does what under CDM
CDM gives specific duties to different parties:
| Duty holder | Key responsibilities in brief |
|---|---|
| Client | Makes suitable arrangements for managing the project, provides relevant information (such as the asbestos register), and allows enough time and resource |
| Principal designer | Plans, manages and coordinates health and safety in the pre-construction phase on projects with more than one contractor |
| Principal contractor | Plans, manages and coordinates the construction phase on projects with more than one contractor |
| Contractor | Plans, manages and monitors their own work, and makes sure workers have the right skills and information |
On many sealant jobs the sealant firm is a contractor working under a main contractor. On direct-appointed maintenance work for an FM, the client relationship is closer, and the FM may be acting for the client.
Risk assessments and method statements
Under the Management of Health and Safety at Work Regulations 1999, employers must assess the risks of their work. In construction, the common name for the package of documents is RAMS: risk assessments and method statements.
The risk assessment identifies hazards and controls. The method statement describes how the work will be done, step by step, so the people on site and the client can see the plan. Both should be specific to the job. A generic template with the site name changed tells the reader very little. Good RAMS name the actual areas, the access method chosen, the products being used and the controls for this building’s occupants. Whoever on site reviews them should be able to picture the work from reading them.
What RAMS for sealant work should cover
For a typical sealant package, useful RAMS address:
- Access: how joints will be reached, whether by steps, podiums, towers or other equipment, and who is trained to use it.
- Removal of old sealant: cutting tools, sharp blades and waste handling.
- Asbestos: confirmation that the asbestos register has been checked before old mastic is disturbed.
- Substances: sealants, primers and cleaners, with reference to their safety data sheets.
- Ventilation and odour in occupied or enclosed spaces.
- Public and occupant protection: barriers, signage and segregation.
- Weather: stopping external work in rain, frost or below the product’s temperature range.
- Fire-rated work: working to the specified product’s tested details, and any permits needed.
- Emergency arrangements and site contacts.
Need the work done? Mastic Doctor covers South East England, London and all of Scotland, with a 12-month guarantee on our workmanship. Send details for a fixed quote.
Asbestos in older buildings
Some older mastics and sealants can contain asbestos, particularly in buildings from before 2000. Before anyone cuts out old sealant in an older non-domestic building, the asbestos register or survey should be checked. Under the Control of Asbestos Regulations 2012, the duty to manage asbestos sits with the dutyholder for the premises.
Mastic Doctor does not remove asbestos-containing materials. If asbestos is suspected, work stops until the material has been tested. See the HSE asbestos guidance and our article on asbestos in old mastic.
Site paperwork clients usually ask for
Beyond RAMS, a sealant contractor is commonly asked for:
- public liability insurance details
- evidence of worker cards, typically CSCS, which show a worker’s training and qualifications for their role
- health and safety pre-qualification, such as CHAS accreditation
- supplier vetting through a register such as Constructionline
- product data sheets and safety data sheets
- for fire-rated work, the manufacturer’s tested details for the specified products
Mastic Doctor is CHAS accredited and a Constructionline member, with CSCS-carded applicators and £5m public liability insurance. Tell us what site paperwork you need (RAMS, insurance certificate, CSCS details) and we’ll confirm with the quote.
Permits and site rules
Many sites run their own permit systems on top of CDM. Common ones affecting sealant work include permits for work in plant rooms and risers, and isolation of fire alarm detectors where dust or odour could set them off.
Healthcare, education and secure sites often add inductions, escort rules and restricted hours. Build these into the programme early. Tell the contractor your site hours and access windows and the work can be planned around them. For healthcare specifics, see our guide to sealant work in hospitals and care homes.
A pre-start checklist
Before the first day on site, it helps if both sides have confirmed:
- the scope, joint locations and product schedule
- asbestos register checked, with results shared
- RAMS received, read and accepted
- insurance details and worker card evidence on file
- induction times, site hours and access windows agreed
- permits arranged, including any detector isolations
- welfare, parking and loading arrangements known
- a named contact on each side for the duration
Ten minutes on this list can save a lost day when an operative arrives to find no permit or induction slot.
Keeping it proportionate
Good CDM practice for sealant packages is about clear, honest information rather than thick files:
- share the asbestos register and any known hazards before pricing
- be clear about access, working hours and occupied areas
- ask for RAMS written for the actual job
- check that what happens on site matches the method statement
- keep records of products used, especially fire-rated ones
If you’re planning a construction mastic package or maintenance programme, send details through our quote form or contact us and we’ll confirm the paperwork with the quote.
Quick answers
Does CDM 2015 apply to a small resealing job?
Yes. CDM applies to construction work of every size. The planning and paperwork should be proportionate to the job’s risks.
What does RAMS stand for?
Risk assessments and method statements. It is the common name for the site safety paperwork a contractor provides for a job.
Who checks for asbestos before old mastic is removed?
The dutyholder for the premises manages asbestos and should provide the register. The contractor should check it before disturbing old sealant, and stop if asbestos is suspected.
Are CSCS cards a legal requirement?
Not in themselves, but they are commonly required on construction sites as evidence of training and qualifications for the role.
Can you provide RAMS before we appoint?
Tell us what site paperwork you need and we’ll confirm with the quote.
Related services
More advice
- Asbestos in Old Mastic: What Duty Holders Need
- How to Choose a Commercial Sealant Contractor
- Sealant Snagging Before Handover
- Sealant Work in Hospitals and Care Homes
- All advice
This guide is general information about sealant work. It isn’t legal, fire-safety or structural advice; for those, speak to a qualified professional.