Working at Height Risk Assessment: What Your RAMS Must Cover
Falls from height killed more construction workers than any other cause in 2023/24 — over half of all 51 fatalities. Yet the risk assessments submitted for height work are frequently the weakest documents in a contractor's RAMS pack. Generic phrases like "use harness where required" and "ensure safe access" tell the principal contractor nothing about how you'll actually prevent a fall on their specific site.
This guide covers what UK law requires in a working at height risk assessment, the hierarchy of controls you must follow, and the specific gaps that get RAMS rejected by principal contractors and flagged by HSE inspectors.
The legal framework: Work at Height Regulations 2005
The Work at Height Regulations 2005 (SI 2005/735) apply to all work at height where there is a risk of a fall liable to cause personal injury. "Work at height" means work in any place where a person could fall a distance liable to cause injury — including at, above, or below ground level.
The Regulations impose three duties in strict order:
- Avoid work at height where reasonably practicable (Regulation 6(2))
- Prevent falls using suitable work equipment or other measures where height work cannot be avoided (Regulation 6(3))
- Minimise the distance and consequences of a fall where the risk of a fall cannot be eliminated (Regulation 6(4))
This is not a pick-and-choose list. It is a hierarchy that courts and HSE inspectors apply in sequence. You cannot jump straight to fall arrest (harness and lanyard) without first considering whether the work can be done from the ground, or whether collective fall prevention (guard rails, scaffolding) eliminates the risk entirely.
Your risk assessment must show you have worked through this hierarchy. If it does not, it fails the "suitable and sufficient" test under Regulation 3 of the Management of Health and Safety at Work Regulations 1999.
Source: Work at Height Regulations 2005, HSE guidance on work at height
What "work at height" actually covers
Tradespeople often assume "work at height" only applies above a certain distance. It does not. The Work at Height Regulations 2005 do not set a minimum height threshold. Standing on a stepladder to fit a light fitting is work at height. Working from a mobile scaffold tower is work at height. Accessing a flat roof to inspect a leak is work at height.
Situations that qualify and need covering in your RAMS:
- Working from any scaffold — independent, putlog, or system
- Working from mobile scaffold towers (including assembly and dismantling)
- Working from mobile elevating work platforms (MEWPs) — cherry pickers, scissor lifts
- Working from ladders and stepladders (even briefly)
- Working on or near roofs — flat or pitched
- Working near unprotected edges, openings, or fragile surfaces
- Working in or near excavations where someone could fall in
- Accessing and working in loft spaces
If any part of your project involves these situations, your RAMS must include a working at height risk assessment with specific controls. Not sure whether your project needs one? Use the RAMS requirements checker to find out what documentation you need for your scope of work.
The control hierarchy in practice
The Regulations require you to work through the hierarchy of controls before selecting your approach. Here is what that looks like for common construction scenarios.
Level 1: Avoid the height work entirely
| Scenario | How to avoid it |
|---|---|
| Inspecting a roof for leaks | Use a drone with a camera instead of climbing up |
| Installing ceiling-mounted services | Assemble at ground level, then lift into position with mechanical aids |
| Cleaning external gutters on a two-storey house | Use a gutter vacuum system from ground level |
| Painting high-level areas | Use paint rollers on extension poles |
If you can do the work safely from the ground, you must. Your risk assessment should explain why height work is necessary if you conclude it cannot be avoided.
Level 2: Prevent falls with collective protection
Where height work cannot be avoided, your first option is work equipment that protects everyone at the working area:
- Independent scaffolding with guard rails, toe boards, and scaffold boards — protects all workers on the platform without relying on individual equipment
- Tower scaffolds — must be erected and used in accordance with the manufacturer's instructions (or PASMA guidance for mobile towers)
- Mobile Elevating Work Platforms (MEWPs) — cherry pickers, scissor lifts with guard rails. Operators need IPAF certification
- Edge protection — temporary guard rails around roof edges, floor openings, and stairwells
Level 3: Prevent falls with personal protection (work restraint)
If collective protection is not practicable:
- Work restraint systems — harness attached to a lanyard short enough to physically prevent the worker reaching a fall position. The worker literally cannot get to the edge.
Level 4: Minimise fall distance and consequences
As a last resort:
- Fall arrest systems — harness with a shock-absorbing lanyard or inertia reel, anchored to a suitable point above the worker. This does not prevent the fall — it catches you. The fall distance and arrest force must be calculated.
- Safety nets — positioned as close as possible below the working surface
- Soft landing systems — air bags or similar positioned below the working area
Your risk assessment must justify your position on this hierarchy. If you have gone straight to Level 4 (fall arrest) without explaining why Levels 1–3 were not practicable, expect questions from the principal contractor and problems if HSE inspects.
What your working at height risk assessment must include
A working at height section in your RAMS needs to address these specific elements:
Equipment selection and justification
| Element | What to record |
|---|---|
| Access equipment | Specify exactly what you will use — "3.2m podium steps" not "suitable access equipment" |
| Why this equipment | Brief justification against the hierarchy: "Scaffold tower selected because task requires sustained work at 4m height over 3 days — ladder not suitable for duration" |
| Inspection requirements | Scaffold: inspected before first use, after any event likely to affect stability, and at intervals not exceeding 7 days (Regulation 12, Schedule 7). Ladders: pre-use visual check. MEWPs: daily pre-use inspection |
| Competence | Who is erecting the scaffold (CISRS card holder for scaffolding, PASMA trained for tower scaffolds)? Who is operating the MEWP (IPAF certified)? |
Site-specific fall hazards
Do not list generic hazards. Identify specific hazards present on your actual site:
- Fragile surfaces — does the roof have rooflights, cement fibre sheeting, or old corrugated asbestos? These require specific controls (crawling boards, barrier/warning systems)
- Edge conditions — unprotected edges, parapets below 950mm, gaps in guard rails
- Overhead hazards — power lines within falling distance, overhead structures
- Weather exposure — wind limits for scaffold use (typically 17 m/s), ice on access platforms, rain making surfaces slippery
- Ground conditions — is the scaffold or tower base on solid ground? Soft ground, slopes, or excavations nearby?
- Other trades — is anyone working below you? Does your work create falling object risks for them?
Emergency and rescue plan
This is the section most working at height risk assessments miss entirely, and it is a legal requirement.
Regulation 4(1) of the Work at Height Regulations 2005 requires that every employer must plan for emergencies and rescue. You cannot rely on the emergency services as your rescue plan — fire service response times vary and the casualty may not survive suspension in a harness long enough (suspension trauma can become life-threatening within 15–20 minutes).
Your rescue plan should cover:
- How will a fallen worker be reached? If someone is suspended in a fall arrest harness at 8 metres, how will you get to them? A rescue plan that says "call 999" is not adequate.
- What rescue equipment is on site? Rescue kits, trauma straps (to relieve pressure on legs during suspension), additional harnesses for the rescuer
- Who is trained in rescue? At least one person on site must be competent to carry out rescue from height. This person must be identified by name in the RAMS.
- Communication — can the fallen worker communicate with rescuers? What if they are unconscious?
Specific competence requirements
For working at height, competence means more than a general CSCS card:
| Activity | Required competence |
|---|---|
| Erecting scaffolding | CISRS Scaffolder card (Part 1 or Part 2 depending on complexity) |
| Erecting tower scaffolds | PASMA Tower for Users or PASMA Towers for Riggers certificate |
| Operating MEWPs | IPAF PAL Card (category specific to the machine type) |
| Using harness/fall arrest | Training in correct harness fitting, anchor point selection, and pre-use inspection |
| Working on roofs | Competence in the specific roof access method — assessed, not assumed |
| Rescue from height | Specific rescue training — not just general first aid |
Common reasons working at height RAMS get rejected
Principal contractors see hundreds of RAMS packs. These are the reasons height-work sections get sent back:
1. "Use appropriate PPE" without specifying what. Appropriate for what? Specify the harness model, the lanyard type, the anchor rating, and the fall clearance calculation. If you are using fall arrest, you need to show there is enough clear space below the anchor point for the lanyard, shock absorber extension, harness stretch, and the worker's height — typically 6.5m minimum clearance for a standard 2m lanyard with shock absorber.
2. No hierarchy justification. Going straight to a harness without explaining why guard rails or scaffolding were not suitable. The hierarchy is not optional — it is a legal requirement.
3. Missing inspection schedule. Scaffolding must be inspected by a competent person before first use and at least every 7 days. The written inspection record must be kept on site. Tower scaffolds must be inspected after assembly, after modification, and at suitable intervals. If your RAMS do not mention inspections, the PC will notice.
4. No rescue plan. Easily the most common omission. A fall arrest system without a rescue plan is half a system. Suspension trauma is a genuine and documented risk.
5. Weather limits not stated. What wind speed stops work? What happens if it rains on the scaffold platform? What is the procedure for lightning risk on exposed steelwork? If conditions change mid-shift, who makes the call to stop?
6. Fragile surfaces not addressed. If the site involves any work near or on a roof built before 2000, the risk assessment must address the possibility of fragile materials (rooflights, deteriorated sheets). Assume fragile until confirmed otherwise.
A worked example: roofer replacing tiles on a 1960s semi
To show what a specific working at height assessment looks like, here is a summary for a common domestic scenario.
Project: Strip and re-tile the rear roof slope on a 1960s two-storey semi-detached house. Ridge height approximately 7.5m. Rear garden access.
Hierarchy assessment:
- Level 1 (avoid): Not practicable — tiles must be accessed from the roof surface
- Level 2 (collective prevention): Independent scaffold with guard rails along the eaves and gable ends. Scaffold platform at eaves level with additional lift for ridge access. Scaffold to be erected by CISRS-carded scaffolder, inspected before first use and every 7 days.
- Level 3/4: Not required — scaffold with guard rails provides collective fall prevention
Key hazards identified:
| Hazard | Who at risk | Controls |
|---|---|---|
| Fall from scaffold platform (7m) | Roofer, labourer | Guard rails, toe boards, fully boarded platform. Pre-use check daily. |
| Falling materials (tiles, battens) | Anyone below, public on pavement | Debris netting on scaffold. Exclusion zone at ground level. Brick guards on scaffold. Hard hats for ground workers. |
| Fragile surfaces | Roofer | Existing rooflights identified during survey — marked with warning signage and barrier. Crawling boards used when accessing near rooflights. |
| Weather | All workers at height | Wind speed limit: 17 m/s (check forecast morning of each shift). Wet scaffold boards: non-slip boards specified in scaffold design. Work stops in thunderstorm. |
| Manual handling at height | Roofer | Tiles supplied to platform by hoist — no manual carrying up ladders. Maximum bundle weight 25kg. |
Rescue plan: Site foreman (named) holds rescue-from-height training. Rescue kit stored on scaffold platform level 1. In case of fall arrest activation: immediate rescue using rescue device, casualty lowered to scaffold platform. If suspension trauma suspected: keep legs elevated, call 999, administer first aid for shock.
This is the level of detail a principal contractor expects. Compare it with "Working at height — use appropriate fall protection" and you can see why generic templates get rejected.
Frequently asked questions
At what height do I need a risk assessment?
There is no minimum height. The Work at Height Regulations 2005 apply to any height from which a fall could cause personal injury. A 600mm step platform counts if someone could fall off and injure themselves. In practice, the higher the fall distance and the more complex the access, the more detailed the risk assessment needs to be.
Can I use a ladder without a risk assessment?
Technically, any work at height requires a risk assessment. For brief, low-risk ladder work (changing a light bulb in a domestic property), the assessment can be simple and proportionate. But for construction work, especially on sites with a principal contractor, you need a documented assessment covering ladder selection, condition, setup angle (1:4 ratio or 75 degrees), securing method, and maximum duration of use.
Who can inspect scaffolding?
Under Schedule 7 of the Work at Height Regulations 2005, scaffolding must be inspected by a "competent person." For basic scaffolds, this can be a CISRS Advanced Scaffolder. For complex structures, a CISRS Scaffold Inspector is typically required. The inspection must be recorded, and the report kept on site.
What is suspension trauma and why does my RAMS need to address it?
When a worker is suspended in a harness after a fall, blood pools in the legs. Without prompt rescue (typically within 15–20 minutes), this can cause loss of consciousness, cardiac arrest, and death. Your RAMS must include a rescue plan that accounts for this — "call 999 and wait" is not sufficient because ambulance response times may exceed the safe suspension window.
Key regulations and guidance
| Document | Reference | What it covers |
|---|---|---|
| Work at Height Regulations 2005 | SI 2005/735 | Core legal duties for all work at height |
| Management of Health and Safety at Work Regs 1999 | SI 1999/3242 | General risk assessment duty (Reg 3) |
| CDM 2015 | SI 2015/51 | Construction-specific duties including fall prevention |
| INDG401 | HSE guidance | The Work at Height Regulations: a brief guide |
| INDG455 | HSE guidance | Safe use of ladders and stepladders |
| NASC SG7:19 | Industry guidance | Risk assessments and method statements for scaffolding |
| PASMA Code of Practice | Industry guidance | Safe use of mobile access towers |
Getting working at height right in your RAMS is not about producing a longer document — it is about addressing the specific hazards of your specific site with controls that follow the legal hierarchy. That takes time if you are writing from scratch for every project, which is exactly the problem TradeRAMS is being built to solve. Trade-specific questions, site-specific outputs, hierarchy built in. Join the waitlist for early access.
Sources: Work at Height Regulations 2005, HSE: Work at height, HSE INDG401 (rev2), HSE: Workplace fatal injuries in Great Britain 2024, NASC SG7:19, PASMA Code of Practice.