An HSE Inspector on Site: What They Can Ask For, and What Your RAMS Has to Survive

What can an HSE inspector do when they arrive on site?

Enter without notice, examine and investigate, take measurements and photographs, require answers to their questions, and require you to produce your documents. Those powers sit in section 20 of the Health and Safety at Work etc. Act 1974 and they are exercisable before the inspector has formed any view about whether you have done anything wrong.

Two of the subsections change how a site visit feels once you understand them.

Section 20(2)(j) lets an inspector "require any person whom he has reasonable cause to believe to be able to give any information relevant to any examination or investigation" to answer such questions as the inspector thinks fit to ask. Section 20(2)(k) lets them require the production of statutory records and inspect and take copies of them, and of "any other books or documents which it is necessary for him to see".

That second phrase is the one that matters for RAMS. The inspector does not have to establish that a document is a statutory record before they can ask for it. It is enough that they need to see it, and a method statement describing how a job was going to be done is the most direct evidence available of whether anybody planned the job at all.

What paperwork will an inspector ask for on a construction site?

The documents that record decisions, in roughly the order they get asked for.

The construction phase plan. Required by regulation 12(1) of CDM 2015 for every project, drawn up by the principal contractor, or by the sole contractor under regulation 15(5) where there is only one. Regulation 12(2) requires it to set out the health and safety arrangements and site rules, including specific measures for any work falling within Schedule 3. Regulation 12(4) requires it to be reviewed, updated and revised throughout the project, and a plan dated week one on a job in month five answers that question by itself.

The risk assessment for the work being done in front of them. Regulation 3(1) 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, where one exists. Not required by name in law. HSE's own construction pages say so: "While not required by law, method statements are also prepared for many other construction activities." One exception, and it is the one most likely to be tested: regulation 20(2) of CDM 2015 requires that the arrangements for demolition or dismantling are recorded in writing before the work begins.

Inspection reports for excavations, cofferdams and caissons. Regulation 22(4) and regulation 23(2) require inspection by a competent person at the start of the shift and after any event likely to have affected stability. Regulation 24 sets what the report contains and how long it is kept: the report goes to the person the inspection was carried out for within 24 hours, and is kept on site until the work is complete and for three months afterwards. An inspector standing at the edge of a trench will ask for this one first.

The F10, where the project is notifiable. Regulation 6(1) makes a project notifiable where it is scheduled to last longer than 30 working days and have more than 20 workers working simultaneously at any point, or to exceed 500 person days. Regulation 6(3)(b) requires the notice to be "clearly displayed in the construction site office in a comprehensible form where it can be read by any worker engaged in the construction work". It is one of the few compliance items that can be checked from the doorway.

Permits, isolations and statutory examination records. Whichever apply to the work in progress. There is more on the permit side in RAMS and permit to work.

The written safety policy. Section 2(3) of the Health and Safety at Work etc. Act 1974 requires every employer to prepare, and revise as appropriate, "a written statement of his general policy with respect to the health and safety at work of his employees and the organisation and arrangements for the time being in force for carrying out that policy", and to bring it to the notice of all employees. Five or more employees is the threshold at which it must be written down.

What does an inspector actually read a RAMS for?

Whether the document and the site are describing the same job.

An inspector is standing in the work. They can see the excavation, the plant, the edge protection, the crew and the sequence. They are holding a document that claims to describe all of it. The comparison is immediate and it does not require them to have any view about your document's format.

The comparisons that produce findings are the same ones a competent reviewer makes before the work starts:

Does the document belong to this project? Address, client, principal contractor, asset references, utility and network operators, emergency contacts. A document carrying a previous job's details forward is not a paperwork error in this context. It is evidence about how the planning was done.

Does the document contradict itself? A task described one way in the summary and another in the method, a role held by two different named people, a duration that does not match the programme. Two restatements that disagree tell the reader that nobody read the document end to end.

Does the register assess what the document itself names? A hazard named in the introduction, in the cited legislation, in the COSHH register or inside another row's control cell, with no row of its own. A control written to deal with something is the document telling you that thing is present on this job.

Does the method carry out the controls 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. And in the other direction, which catches more: does the assessment cover every step the method plans. Work nobody assessed is unassessed however good the register is about everything else.

Do the controls come before the work that needs them? Isolation after dismantling is not isolation. Access built after the work at height has started is not access.

Is each control an act somebody could carry out? Or is it a hedge: "consideration given to", "where possible", "as required", "wherever practicable". A control nobody is assigned and nothing triggers is a sentence.

Where a hazard is controlled by rescue, does the arrangement exist? A rescue plan pointing at a blank template is a rescue plan that does not exist, and a section the contents page promises that the document does not contain is not an arrangement anybody can act on.

None of those requires the reader to be an expert in your trade. Each one is a comparison between two things that are both in front of them, which is what makes them survivable questions to be asked and unanswerable ones to have failed.

What happens if the inspector is not satisfied?

Three things can follow, and they are not alternatives on a scale. They do different work.

An improvement notice. Section 21 of the Health and Safety at Work etc. Act 1974 allows an inspector who is of the opinion that a person is contravening a relevant statutory provision, or has contravened one in circumstances that make it likely the contravention will continue or be repeated, to serve a notice requiring the contravention to be remedied within a specified period. That period cannot end earlier than the time allowed to appeal under section 24.

A prohibition notice. Section 22 applies where an inspector is of the opinion that activities involve, or will involve, a risk of serious personal injury. The notice states that opinion, specifies the matters giving rise to the risk, and directs that the activities do not continue until those matters are remedied. Under section 22(4) the direction takes effect at the end of the period specified in the notice, or immediately if the notice so declares. The immediate version stops the work that day.

A fee for intervention. Where an inspector forms the opinion that there is a material breach and notifies that opinion in writing, a fee becomes payable under regulation 23 of the Health and Safety and Nuclear (Fees) Regulations 2022. HSE defines a material breach as "something which an inspector considers serious enough that they need to formally write to the business requiring action to be taken to deal with the material breach". The rate is published by HSE and stands at £188 an hour from 1 April 2026, charged for the time it takes to identify what is wrong and help put it right, including the associated office work. Where there is no material breach, nothing is charged.

The point that gets missed about the fee is that it is time-based. The bill is a function of how long it takes an inspector to work out what happened, which means a site whose documents answer the question quickly is in a materially different position from one whose documents do not, whatever the underlying standard of the work.

Is enforcement action against my company public?

Yes. HSE publishes a searchable register of the enforcement notices it issues, and notices stay in the database for five years. They are published five weeks after being served, which is the interval allowed for appeals and quality assurance.

The register is searchable by company, by industry sector and geographically, and it distinguishes improvement notices from prohibition notices. It is a routine part of prequalification checks, which means the commercial consequence of a notice usually outlives the safety one.

That is also why the second-order argument for a well-reasoned document is not really about the regulator. The audience for the file is whoever reads it next, and after an incident that list is long: the inspector, the client, the insurer, the next prequalification, and, in the worst case, a court.

Who has to prove what?

You do, on the part that matters most. Section 40 of the Health and Safety at Work etc. Act 1974 provides that in proceedings for an offence consisting of a failure to comply with a duty to do something so far as is practicable or so far as is reasonably practicable, "it shall be for the accused to prove that it was not practicable or not reasonably practicable to do more than was in fact done to satisfy the duty or requirement".

Read that against the duties themselves. Section 2(1) requires every employer to ensure the health, safety and welfare of employees so far as is reasonably practicable, and section 2(2)(a) names the provision and maintenance of "systems of work that are, so far as is reasonably practicable, safe and without risks to health". Regulation 13(1) of CDM 2015 and regulation 15(2) both carry the same qualifier.

So the statutory question is not whether you had a RAMS. It is whether you can prove that nothing more could reasonably have been done, and the evidence for that proposition is a record of what was considered. A document listing the controls you adopted answers half of it. A document that also records what was considered and ruled out, and why, answers the other half, because it is the only artefact that shows a decision was made rather than a topic omitted.

This is the practical form of the problem with a document that reads well and was not thought about. Slips, trips and manual handling come back every time, because they are generic and generic is what assembly is good at. The overhead line does not come back. The gas main two metres off the dig line does not come back. Nothing in the finished document indicates they are missing, because absence has no appearance, and section 40 asks you to prove something about exactly that absence.

What should a contractor do before an inspection rather than during one?

Make the documents answer the comparisons an inspector will make, and make the site match them.

Six checks, all of which can be done from a desk with the file in front of you:

1. Read the front page against the site. Address, client, principal contractor, dates, named roles. Anything that belongs to a previous job goes.
2. Read the document against itself. Every fact that appears twice should agree with itself. Supervisor names, durations, task descriptions and exclusions are where the disagreements live.
3. Count the register against the prose. Every hazard the document names anywhere should have a row. Read the control cells of your own register as a list of hazards being declared.
4. Walk the method against the register. Each control the register relies on should have a step, in the right order, with a person and a trigger.
5. Check the arrangements exist. Rescue, first aid, isolation, permits, the person named to issue them. If a section is promised in the contents and not in the document, an inspector will find it in the time it takes to turn to it.
6. Check the statutory records are on site. Excavation inspection reports under regulation 24, the F10 displayed where regulation 6(3)(b) requires it, statutory examination records for the plant in use.

None of that is preparation for a visit. It is the review the document should have had before anybody worked to it, which is the same reason it holds up when somebody arrives unannounced. The reviewer's side of it is on the home page.

Frequently asked questions

Do I have to answer an HSE inspector's questions? Section 20(2)(j) of the Health and Safety at Work etc. Act 1974 allows an inspector to require a person they have reasonable cause to believe can give relevant information to answer questions. Section 20(7) limits how such an answer may be used in evidence against the person who gave it. If you are unsure of an answer, saying that you will confirm it and following up in writing is better than guessing, because a wrong answer given confidently is corrected later at some cost.

Can an inspector take my RAMS away? They can require its production and take copies. Section 20(2)(k) covers both books and documents required to be kept under the relevant statutory provisions and "any other books or documents which it is necessary for him to see" for the purposes of an examination or investigation, which is where a method statement falls. Providing a clean copy promptly is both the cooperative and the cheaper course, because fee for intervention is charged by the hour.

How long do I have to comply with an improvement notice? The period is specified in the notice, and under section 21 it cannot end earlier than the period within which an appeal can be brought under section 24. Appeals are to an employment tribunal, and bringing one suspends an improvement notice until the appeal is disposed of or withdrawn. A prohibition notice is not suspended by an appeal unless the tribunal so directs.

What is a material breach for fee for intervention? HSE's definition is "something which an inspector considers serious enough that they need to formally write to the business requiring action to be taken to deal with the material breach". The fee follows the written notification of that opinion and is charged for the inspector's time at the published hourly rate.

Will an inspector accept a RAMS produced with software? The question an inspector asks is whether the document describes this job and whether the work matches it. How it was produced is not a statutory consideration. What is a consideration is whether a competent person made the decisions in it, because that is what section 40 will ask you to prove.

Does an inspector need an appointment? No. Section 20(2)(a) allows entry at any reasonable time, and at any time where the inspector has reasonable cause to believe a situation may be dangerous. Construction visits are commonly unannounced.

Where this leaves the file

The document was never the safety. It is evidence that a competent person thought about this work, and section 40 is the moment that evidence is asked to stand up on its own, in front of somebody who was not there when the decisions were made.

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.