Competent Person Sign-Off for RAMS: What the Law Actually Requires

Does the law require a competent person to sign off a RAMS?

No. Nothing in the Construction (Design and Management) Regulations 2015 or the Management of Health and Safety at Work Regulations 1999 requires a named person to sign a risk assessment or a method statement.

What the law requires is narrower and harder. Regulation 3(1) of the Management of Health and Safety at Work Regulations 1999 requires every employer to make "a suitable and sufficient assessment" of the risks, and regulation 3(6) requires an employer with five or more employees to record "the significant findings of the assessment". Record, not sign.

The method statement is not named in the regulations at all. The HSE says so in its own words on its construction pages: "While not required by law, method statements are also prepared for many other construction activities." There is one construction activity where writing is compulsory. Regulation 20(2) of CDM 2015 requires that the arrangements for demolition or dismantling "must be recorded in writing before the demolition or dismantling work begins". Again: recorded.

Search the whole of CDM 2015 for a signature and you find exactly one. Schedule 1 paragraph 15 requires the notification of a project to carry "a declaration signed by or on behalf of the client that the client is aware of the client duties under these Regulations". The only signature the Regulations ask for is a client admitting they know what they have taken on.

So the sign-off box at the bottom of a RAMS is not a legal instrument. It is a claim someone is making, and the interesting question is what the claim says.

What does "competent person" mean in law?

Competence is defined by what somebody has, not by what they have signed. Regulation 7(5) of the Management of Health and Safety at Work Regulations 1999 says a person is competent "where he has sufficient training and experience or knowledge and other qualities to enable him properly to assist" in the measures the employer must take.

CDM 2015 sets the construction version in regulation 8(1). A designer or contractor appointed to work on a project "must have the skills, knowledge and experience, and, if they are an organisation, the organisational capability, necessary to fulfil the role that they are appointed to undertake, in a manner that secures the health and safety of any person affected by the project."

Two things follow from the wording, and both are routinely missed.

Regulation 8(2) makes refusal a duty: a designer or contractor "must not accept an appointment to a project unless they fulfil the conditions in paragraph (1)". Competence is something you are obliged to decline work for lacking.

Regulation 8(3) puts a duty on whoever is doing the appointing: they "must take reasonable steps to satisfy themselves that the designer or contractor fulfils the conditions in paragraph (1)". That is the nearest thing in the Regulations to an approval duty, and note what it attaches to. It attaches to the appointment of a firm, not to the acceptance of a document.

Where does CDM 2015 actually use the phrase "competent person"?

Twice, and both times about looking at ground rather than at paper. Regulation 22(4)(a) prohibits construction work in a supported or battered excavation unless it "has been inspected by a competent person" at the start of the shift and after any event likely to have affected its strength or stability. Regulation 23(2)(a) says the same of a cofferdam or caisson.

Follow what the Regulations then demand of that person and the contrast with a RAMS signature becomes sharp. Under regulation 24, an inspector who is not satisfied must tell the person they inspected for, before the end of that shift, and must produce a written report within 24 hours naming the site, the thing inspected, the date and time, the matters that could give rise to risk, the action already taken and the action still needed, and the inspector's own name and position. The report stays on site until the work is complete and for three months afterwards.

That is what the law looks like when it genuinely wants a competent person to attest to something. A name, a time, a specific object, a stated defect, a stated remedy, and a retention period. Set the sign-off box on the back page of a typical RAMS next to it.

If no signature is required, why does every principal contractor ask for one?

Because the principal contractor carries a duty they cannot discharge by trusting the document. Regulation 13(1) of CDM 2015 requires the principal contractor to "plan, manage and monitor the construction phase and coordinate matters relating to health and safety" so that, so far as is reasonably practicable, the work is carried out without risks to health or safety. Regulation 13(3) requires them to organise cooperation between contractors and coordinate the application of legal requirements across them.

None of that is satisfied by holding a signed PDF. But all of it has to be evidenced somehow, and the signature is the cheapest evidence available. Ask what it is evidence of and the answer is thinner than the file implies: it evidences that a document arrived, and that somebody was willing to put their name to it having read it to an unrecorded standard.

The gap between "this was signed" and "this was read by someone who knew what to look for" is where the whole problem lives. There is more on how those duties divide in who writes a RAMS and who approves it, and the review side of it on the home page.

What is a sign-off actually asserting?

Three claims, only one of which most sign-off boxes are worded to carry.

That the document describes this job. The site is this site, the client is this client, the task is the task that was let, the dates can be true alongside the programme, and the document does not contradict itself between the summary and the method. This is the cheapest thing to check and the most common thing to be wrong, because a document assembled from a previous job carries the previous job forward silently.

That the assessment covers the work. Every hazard the document itself names somewhere, in its contents, its introduction, its cited legislation, its COSHH register or the control cells of its own risk register, has a row that assesses it. A hazard named only in another row's controls is the document telling you that hazard is present on this job.

That the method delivers the assessment. Every control the register relies on has a step that carries it out, in an order where the control precedes the work that needs it, assigned to somebody, with a trigger.

A signature that means the first of those is worth having. A signature that is taken to mean the third, when only the first was checked, is worse than no signature, because it converts an unread document into a reviewed one in the file.

What does a reviewer check before signing?

A reviewer works through three questions in order, and each answer feeds the next: is the scope correct, has the risk been assessed, and does the plan reflect the risks identified. These are the questions our own review engine is built from, and each check is written as a comparison between two things in the document so that both halves can be quoted back.

Is the scope correct? Does every site-identifying fact belong to this project: address, postcode, client, principal contractor, asset numbers, utility and network operators, hospital, emergency contacts. Is the task described the task the project asked for. Can the dates and the programme both be true. Does the project require work the document explicitly declines to cover. Does the document claim scope, or authority over work, that somebody else holds. And where the document states its scope more than once, do the restatements agree: a role held by two different named people, an address that changes between page one and page fourteen, a duration that does not match the programme table.

Has the risk been assessed? Does the register assess every hazard, substance and regulation the document names anywhere in itself. Does each score follow the convention the rest of the table establishes, and does any residual score simply repeat the initial one. And for each row, does the control hierarchy meet the harm that row itself names, or is a serious hazard held up by nothing but PPE, administration and behaviour where elimination, substitution or engineering is reasonably practicable.

Does the plan reflect the risks identified? Does the method carry out every control the assessment relies on: an assessment promising "services isolated and proved dead" with no such step in the method is a residual score the document has not earned. Does the assessment cover every step the method plans, which is the reverse comparison and the one that catches the most. Does every step touching energised, pressurised or stored-energy equipment name isolation, proving dead, or a permit. Does each control appear before the step that needs it, because isolation after dismantling is not isolation and access built after the work at height has started is not access. Could somebody carry out each control as written, or is it a hedge rather than an act: "consideration given to", "where possible", "as required". And where the control for a hazard is that somebody will be rescued, does the named arrangement exist and work.

Every one of those is answerable by holding two parts of the document against each other. None of them requires the reviewer to be an expert in the trade. That is the point: a check that names what is compared against what cannot be satisfied by finding one reassuring sentence.

What makes a sign-off worthless?

A sign-off is worthless when the thing it was calibrated to detect has been removed rather than fixed.

Reviewers built their judgement on a visible tell. A generic document announced itself: the wrong site name, the copied hazard list, the prose that could have described any job of that type. Spotting it, bouncing it and making the contractor do it again was the industry's quality control, and it worked because the genericness was on the surface.

Documents that read specifically without having been thought about specifically defeat that. The tell has gone. The underlying document has not improved. A reviewer who is still reading for the signs of a template is calibrated against a signal that is no longer transmitted, and their signature now certifies the absence of a symptom rather than the presence of thought.

This is why the ruled-out set matters more than it sounds. A hazard that was considered and dismissed, with the reason recorded, is evidence that consideration happened. A hazard that was never considered leaves no mark at all. Absence has no appearance, which is the single hardest thing about reviewing this class of document: you cannot notice what nobody thought about, and nothing in the output tells you it is missing.

Who should sign, and what should they write?

The person who could be questioned about it afterwards, and they should write what they checked.

Take regulation 24 as the template, because Parliament has already worked out what a useful attestation contains. A sign-off worth the ink names the person and their role, the date, the version of the document they read, what they compared it against (the pre-construction information, the construction phase plan, the programme, the permit register), what they found and asked to be changed, and what remains outstanding at the point of signature.

Two lines of that are worth more than a signature block, because they are falsifiable. Somebody can check whether the thing you say you compared actually says what you say it says. That is the whole difference between a record and a formality.

If your firm is the one being asked to sign, the practical position is straightforward: sign for what you actually checked, name it, and say what you did not check. A reviewer who writes "coordination with the site traffic plan checked; ground conditions and the temporary works design not reviewed" has protected everybody, including themselves. A reviewer who writes nothing has signed for all of it.

Frequently asked questions

Is a RAMS a legal document? The risk assessment inside it is: regulation 3 of the Management of Health and Safety at Work Regulations 1999 requires a suitable and sufficient assessment, and regulation 3(6) requires an employer with five or more employees to record its significant findings. The method statement is not required by name anywhere in health and safety law, though HSE describes it as an effective and practical way to plan, manage and monitor construction work, and CDM 2015 regulation 20(2) does require demolition and dismantling arrangements to be recorded in writing before work begins.

Who is the competent person for a RAMS? There is no such statutory role. Competence is defined by regulation 7(5) of the Management of Health and Safety at Work Regulations 1999 as sufficient training and experience or knowledge and other qualities, and by regulation 8(1) of CDM 2015 as the skills, knowledge and experience, plus organisational capability where the appointee is an organisation, needed for the role appointed to. In practice the person writing a RAMS should be someone who has done the work or supervised it, with input from the crew who will carry it out.

Can a principal contractor reject a subcontractor's RAMS? Yes, and the mechanism is regulation 15(3)(a) of CDM 2015: a contractor must comply with any directions given by the principal designer or the principal contractor. A principal contractor coordinating the construction phase under regulation 13 can direct that work does not start until a document is fit to work from. What they cannot do is turn their acceptance into the author's competence.

Does a RAMS need to be signed by everyone briefed on it? Nothing in law requires it. Regulation 15(8) and 15(9) of CDM 2015 require a contractor to provide workers under their control with appropriate supervision, instructions and information, including a suitable site induction and the procedures for serious and imminent danger. A briefing signature sheet is evidence that information was provided. It is not evidence that the plan was understood, which is the thing that matters when the plan is being carried out.

Who signs the RAMS if the contractor is a sole trader? The same person who wrote it, and the recording duty changes rather than disappears. Regulation 3(2) of the Management of Health and Safety at Work Regulations 1999 applies the assessment duty to self-employed people, and regulation 3(6)'s recording duty bites at five or more employees. A principal contractor will still ask, because their own regulation 13 duty does not scale down with your headcount.

Where this leaves the document

The RAMS was never the safety. It was the receipt: evidence that a competent person thought about this work before anybody stood in the excavation. A signature is a claim about that thinking, and a claim is only worth what the reader can check.

About the author

Dylan Squires is the founder of Tarian and a former Royal Engineers officer and site manager, SMSTS qualified, with delivery experience across UK civil engineering projects. He writes about the reasoning behind construction safety documents rather than the format of them.