Key facts
- A principal contractor must plan, manage, monitor and coordinate the construction phase, and make sure contractors follow the construction phase plan where required (CDM 2015 regulation 13). Reviewing RAMS is one of the main ways they do it.
- Contractors must comply with the principal contractor's directions and the parts of the construction phase plan relevant to their work (regulation 15).
- Acceptance does not transfer responsibility. The contractor who wrote the RAMS remains responsible for planning and managing their own work.
- Most rejections are for missing specifics, such as the site address, dates, named supervisor or actual access method, rather than for missing hazards.
- Lifting equipment for lifting people, and lifting accessories, need a thorough examination at least every 6 months; other lifting equipment at least every 12 months, unless a written examination scheme sets different intervals (LOLER regulation 9).
Why your RAMS is reviewed
Under CDM 2015 the principal contractor must plan, manage, monitor and coordinate the construction phase so that work is carried out without risks to health or safety, organise cooperation between contractors and coordinate how they meet their legal duties. Each contractor, in turn, must follow the principal contractor's directions and the parts of the construction phase plan that apply to their work. The RAMS is where those two duties meet: it shows the principal contractor how your work will be done, and lets them check it fits the site, the programme and the other trades.
Clients and facilities managers on non-construction sites do the same thing for a similar reason. Where two or more employers share a workplace, even temporarily, the Management of Health and Safety at Work Regulations 1999 require them to cooperate and coordinate their arrangements, and reviewing a visiting contractor's RAMS is how most organisations do that.
The review checklist
Reviewers work from a list, whether it is written down or not. These are the checks, and the most common reasons each one fails.
| Check | What the reviewer looks for | Why it gets sent back |
|---|---|---|
| Document control | Reference, revision number, date of issue, preparer and approver, review date | Unsigned, undated, or a revision that does not match the copy the site holds |
| Scope and site | The site address, the work area, dates and working hours | "Various locations", the wrong site, or a scope that does not match the order |
| Sequence of works | Numbered steps in the real order, including isolation, permits and inspections | "Install to manufacturer's instructions" as the whole method |
| Hazards and controls | Each significant hazard with who could be harmed, the controls and the residual risk | Controls that never appear in the sequence, or "wear PPE" as the only control |
| Access and work at height | The actual access equipment, why it was chosen, inspection and rescue | A ladder by default, or a harness with no rescue plan |
| Competence | Named operatives and the cards they hold: CSCS, ECS, IPAF, PASMA, CISRS, Gas Safe, SSSTS or SMSTS for supervisors | "All operatives are competent" with nothing to show it |
| Plant and equipment | What is used, and its inspection and thorough examination status | No LOLER reports for lifting equipment, no inspection records for towers or scaffolds |
| Hazardous substances | COSHH assessments for the products used and the dust or fume produced | Safety data sheets attached instead of assessments |
| Permits | Hot works, electrical isolation, confined space and permit to dig, as the site operates them | No mention of a permit the site rules require |
| Emergency arrangements | First aider, site emergency contact, nearest A&E, fire procedure, assembly point, rescue | "Call 999" as the whole plan |
| Interfaces | Other trades, building occupants, the public, deliveries and segregation | Nothing about working in an occupied building |
| Briefing and sign-off | An operative briefing record to be signed before work starts | No briefing record, or one signed by people not on the job |
The evidence that goes with it
Most principal contractors ask for supporting documents with the RAMS, or at induction. Having them ready shortens the review.
- Training and competence cards for each operative, and supervisor qualifications
- Thorough examination reports for lifting equipment: at least every 6 months for equipment that lifts people and for lifting accessories, at least every 12 months for other lifting equipment, or as a written examination scheme sets
- Inspection records for work equipment, towers, scaffolds and MEWPs
- A lifting plan for any lifting operation: LOLER requires every lift to be properly planned by a competent person, appropriately supervised and carried out safely
- COSHH assessments for the substances used and produced
- Employers' liability insurance, which by law must be for at least £5 million where you have employees, and public liability insurance to the level in the contract
- Asbestos awareness training for trades that could disturb asbestos in older buildings
How to get it accepted first time
Most resubmissions are avoidable. The contractors whose RAMS go through first time tend to follow the same routine.
- 1Read the pre-construction information, the site rules and the relevant parts of the construction phase plan before writing anything.
- 2Visit the site, or get photographs and drawings, so the access, work area and interfaces are real rather than assumed.
- 3Use the principal contractor's own format or headings if they have one.
- 4Name the supervisor and operatives, and the cards and qualifications each holds.
- 5Check that every hazard in the risk assessment appears as a control, check or permit in the sequence of works.
- 6Use the site's own names for its permits, and say who issues each one and when.
- 7Include a rescue plan for any work at height, and site-specific emergency arrangements.
- 8Attach the evidence pack, and issue the document with a revision number and date.
When it comes back with comments
Answer every comment, revise the document, raise the revision number and resubmit, noting what changed. If the comment reflects something about the site you did not know, it is information the RAMS needed anyway.
Where a site rule conflicts with your method, the site rule wins on that site: change the method, or agree the alternative with the principal contractor in writing before work starts. If the job has already begun, brief the revised RAMS to the operatives before they carry on, and have them sign the new briefing record.
Questions
Sources
The legislation and HSE guidance this guide is based on. Legislation links go to the revised text on legislation.gov.uk.
- CDM 2015, regulation 12 (construction phase plan and health and safety file) · legislation.gov.uk
- CDM 2015, regulation 13 (duties of a principal contractor) · legislation.gov.uk
- CDM 2015, regulation 15 (duties of contractors) · legislation.gov.uk
- Management of Health and Safety at Work Regulations 1999, regulation 3 (risk assessment) · legislation.gov.uk
- Management of Health and Safety at Work Regulations 1999, regulation 11 (co-operation and co-ordination) · legislation.gov.uk
- LOLER 1998, regulation 8 (organisation of lifting operations) · legislation.gov.uk
- LOLER 1998, regulation 9 (thorough examination and inspection) · legislation.gov.uk
- Employers' Liability (Compulsory Insurance) Regulations 1998, regulation 3 (amount of insurance) · legislation.gov.uk
- Managing health and safety in construction: CDM 2015 guidance on regulations (L153) · Health and Safety Executive
- CDM 2015: principal contractors · Health and Safety Executive
- Safe use of lifting equipment: LOLER Approved Code of Practice and guidance (L113) · Health and Safety Executive
This guide is general information about UK health and safety practice. It is not legal advice, and it does not replace a competent person's assessment of your own work.
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