Writing RAMS that actually get read

Key takeaways

Regulation 3 of the Management Regulations requires every employer to make a suitable and sufficient risk assessment; the significant findings must be recorded at five or more employees.
A method statement is not named in any regulation. It is the practical answer to the risks the assessment found, and principal contractors are entitled to insist on one.
Task-, place- and people-specific beats generic every time; a copied assessment that lists absent hazards and misses present ones fails the suitable and sufficient test.
The document is finished when it has been briefed to the people doing the work and signed by them, not when it has been approved.

What the law requires

Regulation 3 of the Management of Health and Safety at Work Regulations 1999 requires every employer and self-employed person to make a suitable and sufficient assessment of the risks to their employees while at work and to anyone else who may be affected by the conduct of their undertaking. Where five or more people are employed, the significant findings and any group of employees identified as especially at risk must be recorded. The assessment must be reviewed if there is reason to suspect it is no longer valid or there has been a significant change.

Specific regulations add their own assessment duties: the Control of Substances Hazardous to Health Regulations 2002 for hazardous substances, the Manual Handling Operations Regulations 1992 for lifting and carrying, the Work at Height Regulations 2005 for work at height, the Control of Noise at Work Regulations 2005 and the Control of Vibration at Work Regulations 2005 for those hazards. They are not separate exercises so much as the general duty applied with more detail where the hazard justifies it.

The five steps, still

The HSE’s five steps have been reworded over the years but not replaced, because they describe the job:

Identify the hazards, by walking the task and the place, asking the people who do it, and reading the incident history, not by copying a list.
Decide who might be harmed and how, including contractors, visitors, the public, and anyone especially at risk such as new starters, young people and expectant mothers.
Evaluate the risks and decide on precautions, applying the hierarchy of control: eliminate, substitute, engineer, administer, and only then protect with PPE.
Record the significant findings in a form the workforce can use.
Review it when the work changes and at a sensible fixed interval in between.

Where the method statement fits

A method statement is not a legal requirement in itself. It answers the question the risk assessment raises: given these risks and these controls, how exactly will the work be done, in what sequence, with what equipment, by whom, and what happens if something goes wrong? On construction projects the Construction (Design and Management) Regulations 2015 make the construction phase plan the document that pulls the high-risk method statements together, and a principal contractor will not let a high-risk activity start without one. Outside construction the same document is often called a safe system of work.

The two documents have different audiences. The assessment is for the person planning the work and the person checking it. The method statement is for the person doing it, which is why it belongs in plain language, in sequence, with the diagrams and photographs the task needs, and why it is briefed at the point of work and signed by the people who will follow it.

Why generic RAMS fail the test

The HSE describes a suitable and sufficient assessment as one that identifies the significant risks of the actual work, is proportionate to those risks, considers everyone affected, and remains valid for a reasonable period. A generic document taken from the last job fails on the first point immediately: it lists hazards that are not present, misses the one that is, and gives the site team a document they stop reading after the first page. An inspector or a court will treat it as no assessment at all.

Writing them well

One task, one place, one document. A RAMS pack for a whole contract is a filing system, not a control.
Name the actual controls: the type of edge protection, the make of the podium, the exclusion zone distance, the permit number, the competent person on site.
Keep it short enough to be read standing up. Two pages for the assessment, a few more for the method, and the drawings.
Brief it, sign it, keep the briefing record with the document. The signature is the evidence that regulation 13 training and CDM information duties were met.
Change it when the job changes. A method statement for a task that has been re-sequenced on site is a method statement for a different task.

In the record

This guide describes the law. What Stephen Laws has delivered under it is set out in Risk assessments and RAMS, CDM 2015 and construction, Training and courses, and in the construction and housing, civil engineering, fabrication and process sectors.

Questions this guide raises

Does a sole trader need a written risk assessment?

A sole trader with no employees must still make the assessment under regulation 3 but is not required to record it. On a construction site the principal contractor will require a written RAMS regardless, as a condition of starting work.

How often should RAMS be reviewed?

Whenever the task, the place, the equipment or the people change, and at a fixed interval otherwise. Twelve months is common for a standing task; a construction method statement is reviewed whenever the sequence on site departs from it.

RAMS that get read: risk assessments and method statements for the people doing the work