RAMS – Risk Assessment Method Statements – are a grey area in health and safety. Despite this, there are indications their use is increasing. While the rules on the use of risk assessments are clear, what are the exact requirements for preparing RAMS?
What is the law, what is the current advice on best practice, and is that advice correct? Also, should we be using RAMS more than either the law or current best practice advice requires?
Where RAMS are required, you need to create two types of document:
A risk assessment involves assessing the level of risk and the actions required to mitigate that risk. Wearing PPE is an example of the latter. You must carry out a risk assessment on anything within the workplace that has the potential of causing harm.
RAMS describe the steps required to safely complete a task identified in a risk assessment. In other words, the creation of a RAMS document comes after the creation of a risk assessment.
One of the reasons for having RAMS is to ensure risk assessments don’t become too unwieldy. With RAMS, the risk assessment can remain focused on defining the risk and the mitigating measures that should be taken to reduce that risk.
The RAMS document then takes over to outline the steps for safely completing the work within the parameters laid out by the risk assessment.
This sounds logical, i.e. most businesses will already instruct their employees on how to complete a task. Keeping the employee safe will be a factor in that instruction.
A RAMS document, however, formalises and documents this process with a particular emphasis on safety.
RAMS play an essential role in ensuring the right people with the right levels of competency complete tasks in the right way. Therefore, RAMS play an essential role in ensuring your staff are not involved in a serious accident at work.
What about other benefits of RAMS? Those benefits include:
In addition, you may need to use RAMS to win contracts as they could be a requirement in the tendering or procurement process.
Conducting risk assessments is a legal requirement in all UK businesses, although you don’t have to document the risk assessment in businesses with fewer than five employees. All other businesses must document risk assessments.
Under UK health and safety law, however, it’s not a requirement to use RAMS documents.
The Health and Safety Executive (HSE) does recommend their use in some situations, with several mentions of method statements on the HSE website. Specifically, the HSE says RAMS are one method that companies can use to satisfy the requirements of certain regulations. The Construction (Design and Management) Regulations are a good example.
This is not a strict requirement, however, with mentions of method statements on the HSE website being limited to sections covering the construction industry and sections focused on other high-risk situations and tasks.
So, if there is no legal requirement to use RAMS, what is the driver for organisations doing so? After all, while RAMS are mostly used in the construction industry, they are starting to become more commonly used in other industries too.
This could be down to organisations recognising the benefits of using RAMS, but the introduction of ISO 45001 is undoubtedly a factor as well.
ISO 45001 is the new standard for health and safety and many organisations are now transitioning from older standards like ISO 9001 to this updated standard.
ISO 45001 contains several significant changes from previous standards, and the use of RAMS is regarded by many experts as being key to successful compliance.
Let’s look at two specific areas of ISO 45001 by way of example.
Under ISO 45001, employers must communicate more proactively and effectively with workers in relation to health and safety. This communication requirement includes enhancing awareness of health and safety issues by, for example, communicating company policies in relation to risks as well as updates to policies.
This communication must be documented. Also, like other aspects of ISO 45001, organisations must measure the success of their health and safety communication efforts against their communication objectives.
The advice to many companies working towards ISO 45001 compliance is to use RAMS as part of their health and safety communication strategy.
Another of the key differences in the new ISO 45001 standard is the extension of responsibility for health and safety beyond employees to now include contractors and others undertaking outsourced processes.
In other words, your responsibilities for health and safety now extend into your supply chain.
The standard sets out what this means in practice. This includes the requirement that you must verify that a contractor is capable of doing the job safely before they start working.
Reviewing the contractor’s RAMS documents is one way of doing this.
Certificates of competence, permits to work, training records, and Safe Systems of Work Instructions are other examples of the documentation you can obtain from a contractor to verify its capabilities.
The above two examples of changes between ISO 45001 and previous standards – communication requirements and supply chain responsibilities – include the use of RAMS as potentially being part of the solution to achieving compliance.
The RAMS element, however, is not an explicit requirement.
Instead, the advice is that you should take a risk-based approach to decide the amount of documentation you should prepare/obtain to ensure you achieve compliance with ISO 45001. In words, the greater the risk, the more documentation you need.
So, the greater the risk, the more important it is for you to use RAMS rather than risk assessments alone.
All the above – current UK law and the requirements for ISO 45001 compliance – beg the question: where do you draw the line when it comes to the use of RAMS?
Currently, RAMS are used in the construction sector and for high-risk activities, although this is not universal.
What about other activities where RAMS are not currently commonly used?
What about preventing stress and other mental health issues, for example? With an increasing focus in society generally, and a more specific focus by companies on making improvements in the area of CSR (corporate social responsibility), many organisations now conduct risk assessments on anything that could increase employee stress or impact their mental health.
On the flip side, there are still many companies that have minimal regard for employee mental health or reducing their levels of stress.
So, should there now be an extension to the creation of RAMS for stress-related and mental health issues? Is it even practical to do so?
Work-related driving is another example when exploring the use of RAMS, especially when you consider the high rates of death and serious injury that work-related driving causes. Again, businesses and organisations where employees are required to drive for work will already carry out risk assessments. Examples of these risk assessments include:
What about RAMS? Should companies also create RAMS when they identify the above risks? Do companies need to create RAMS for the above risks to ensure compliance with ISO 45001?
All things considered, is it even practical to complete a RAMS document for all the above risks?
When it comes to RAMS, there are some things we know:
It makes sense that there should now be additional discussions within the industry and, crucially, with the HSE to get further clarification on the use of RAMS and, potentially, to extend their use.
The push to improve health and safety performance in all sectors, and to ensure workers are properly protected, continues. RAMS can and should have a role to play.
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