Roofing Risk Assessment (UK — WAH 2005 & HSG33)

By the Riskora Editorial Team · Written to our editorial standards

Roofers are the most-killed trade in UK construction — and roof-work prosecutions are almost always about the same thing: a generic "work at height" document that didn't name the roof type, didn't identify fragile material, or didn't sequence collective protection before harness use. This builder produces roofing risk assessments aligned with WAH 2005 and HSG33, with separate routing for pitched, flat and fragile-surface work. Free first PDF, no card.

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UK (RAMS) example document — Two-Storey Rear Extension — 14 Birchwood Lane, Reading. Client: Mr & Mrs A. Whitfield (Private Client). Site: 14 Birchwood Lane, Reading, RG1 5JT. Scope: Construction of a two-storey rear extension (6.4m × 4.2m) to an existing semi-detached dwelling. Works comprise breaking out of existing rear elevation, trench-fill foundations to 1.0m, traditional cavity blockwork to first floor, pre-stressed concrete lintels, timber roof structure with natural slate finish, plus alterations to existing rear wall to form structural opening with rolled steel joist (RSJ 203×102 UB23). Works programmed over 9 weeks with a peak site team of 6 operatives. Hazards assessed: Manual handling — blocks, lintels, plasterboard, Working at height — independent scaffold & roof structure, Buried services strike during excavation, Collapse of excavation / trench wall, Hand-arm vibration (HAVS) — breaking out, drilling, Silica dust — cutting blocks, brick, concrete, Vehicle/pedestrian segregation — narrow domestic street.

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What does a UK roofing risk assessment need to cover?

It must name the roof type (pitched, flat, fragile), the access method (independent scaffold, roof ladder, MEWP, edge-protection on flat roof), collective fall-protection before personal fall-arrest, fragile-material identification per HSG33 (fibre-cement sheets, roof lights, old plasterboard ceilings, GRP rooflights), the manual handling sequence for tiles / felt / membrane, public protection at eaves level, weather thresholds (wind, ice, surface wet), and the NFRC / CompetentRoofer competency of the operatives. 'Work at height — use harness' is not a roofing assessment.

Roofing assessments fail principal-contractor review for the same three reasons

Three documentary failures appear in nearly every rejected roofing RAMS: the roof type (pitched / flat / fragile) is not named, the fragile-material assumption defaults to "non-fragile" without HSG33 justification, and the access method is "use harness" instead of an edge-protection-first sequence. The Riskora wizard forces each of these to be answered before the document is exportable. For the wider work-at-height framework see work at height risk assessment.

How Riskora Helps

Riskora's roofing preset is built from WAH 2005, HSG33 and the NFRC / CompetentRoofer competency frameworks. You select roof type, pitch, surface and access method, and the builder produces the hazard register, edge-protection schedule, fragile-material register and weather hold-points. The download mirrors the structure principal contractors and CDM clients look for. See also the wider best UK risk assessment software.

Who it's for

  • Roofing contractors producing per-site RAMS for pitched and flat work
  • Strip-and-recover specialists handling slate, tile, felt or single-ply
  • Solar PV installers documenting roof-mounted system installs
  • Maintenance contractors entering fragile industrial roofs
  • Refurbishment principals reviewing roofing subcontractor RAMS

What counts as a fragile roof under HSG33?

HSG33 treats a roof as fragile until proven otherwise. The default fragile list includes asbestos cement sheets, fibre-cement sheets, old plasterboard ceilings, GRP/translucent rooflights, wired glass, slates and tiles in poor condition, and corroded metal sheets. A roof can only be treated as non-fragile after positive identification (manufacturer's information or competent inspection). The assessment must name which fragile materials are present and how they will be controlled.

When is a roof ladder enough versus a scaffold?

Roof ladders are appropriate only for short-duration work on intact pitched roofs where the rest of the access platform (scaffold, MEWP) provides the fall-prevention. They are not a substitute for edge protection. HSG33 makes clear that for any significant duration or scope, an independent scaffold with single-handrail-and-toeboard edge protection at eaves level is required. The assessment should justify the access choice against duration and pitch.

Do I need a separate method statement as well as the risk assessment?

For roofing, almost always yes — most principal contractors require a full RAMS pack. The risk assessment names the hazards and controls; the method statement sequences the work day-by-day (strip, batten, felt, tile, finish), the lift plan for materials, the weather hold-points and the handover criteria. Riskora produces both from the same builder so the documents stay in sync.

Key Risks and Considerations

  • •Fall through fragile material (rooflight, fibre-cement, plasterboard)
  • •Fall from eaves or gable end during strip or re-cover
  • •Material falling onto public, parked vehicles or operatives below
  • •Manual handling injury — tiles, slates, felt rolls, lead sheet
  • •Adverse weather: wind on loose materials, ice on the surface
  • •Hot work (felt torching, lead burning) and fire risk

What UK Law Actually Says

Direct quotes from the named regulations, with plain-English explanations of what each one means in practice.

Regulation 9, Work at Height Regulations 2005 (fragile surfaces)

“Every employer shall ensure that no person at work passes across or near, or works on, from or near, a fragile surface where it is reasonably practicable to carry out work safely and under appropriate ergonomic conditions without his doing so.”

Reg 9 puts fragile-roof work in its own category: it is only permitted when there is no reasonably practicable alternative, and even then only with platforms, coverings or guardrails plus fall-arrest. An assessment that puts a roofer on a fibre-cement or GRP rooflight surface without those controls is failing reg 9 directly.

Read the source on legislation.gov.uk →

HSG33 — Health and safety in roof work (HSE guidance)

“All roofs should be considered fragile until a competent person has confirmed they are not. This includes roofs of asbestos cement, fibre cement, plastics, glass, wired glass, chipboard, slates and tiles, and corroded metal sheets, plus all rooflights regardless of age or condition.”

HSG33 inverts the assumption: every roof is fragile by default. The assessment has to actively justify any 'non-fragile' classification with manufacturer information or competent inspection — not the other way round.

Read the source on legislation.gov.uk →

The Numbers Behind the Risk

Why this matters — the most recent published figures from the Health and Safety Executive and ONS.

50 worker deaths from falls from height in 2023/24

Falls from height remain the single largest cause of fatal injury to UK workers. Roof work — particularly fragile-roof work and short-duration maintenance — is over-represented within that total. The HSE consistently lists roofing as one of the highest-risk activities in construction.

Source: HSE — Fatal injuries in Great Britain →

Construction = 38 fatalities in 2023/24

Construction was the highest-fatality industry in Great Britain in 2023/24, with falls from height the dominant kind. HSE intervention data has repeatedly placed roofing at the top of the per-worker fatality rate within construction — a key reason WAH 2005 reg 9 treats fragile-surface work as a distinct regulatory category.

Source: HSE — Construction statistics 2024 →

Side-by-side: a fragile-roof maintenance prosecution scenario

Weak example. Activity: "Replace damaged rooflights on warehouse". Hazard: "Fall from height". Control: "Operative to wear harness and avoid stepping on rooflights".

Why it fails. This is the exact scenario that produces fatal-fall HSE prosecutions every year. The assessment treats rooflights as something to be "avoided" rather than a fragile surface requiring engineered protection. There is no platform, no covering, no perimeter edge protection, no anchorage justification, and no banksman. Harness alone is not a primary control on a fragile roof under WAH 2005 reg 9.

Passing example. Activity: "Replace 6no. corroded GRP rooflights, warehouse roof, 8m to eaves, fibre-cement sheet decking". Access: "MEWP from external yard for rooflight removal; mobile crawl-board platform with integral guardrails for sheet replacement; perimeter edge protection installed by scaffolder prior to first access". Fragile-surface controls: "Mesh covers fixed over remaining rooflights before any roof access; fall-arrest system anchored to engineer-specified eyebolts (test cert. ref. on file); two-person team with banksman monitoring exclusion zone below". Hot work N/A. The difference is that the passing version treats every rooflight as fragile and engineers around the fragility — not around the operative's harness.

Common Mistakes (and How to Avoid Them)

1. Treating the roof as non-fragile by default

Why it fails: HSG33 reverses the burden of proof: every roof is fragile until competently proven otherwise. Defaulting to non-fragile bypasses reg 9 and the engineered controls it requires.

Fix: List every rooflight, sheet type, slate condition and underlying structure as fragile until justified. The wizard pre-populates the fragile register and forces justification before downgrading.

2. Harness-first on a pitched or fragile roof

Why it fails: WAH 2005 reg 6 requires elimination, then prevention (collective protection), then arrest. PPE-first inverts the hierarchy and provides almost no protection on a fragile roof where the operative falls through, not from.

Fix: Sequence scaffold edge protection, platforms, coverings or MEWP first. Personal fall-arrest only as a backup, with anchorage justified by engineer or eyebolt test.

3. No weather hold-points

Why it fails: Roofs become lethal in wind (loose materials), wet (surface slip) and frost (slate / membrane unstable). 'Stop work in adverse weather' is too vague to enforce.

Fix: Set numeric thresholds: wind speed (e.g. 23 mph 5-min average at ridge), surface wet, ice, temperature for membrane laying. Anemometer on site; Met Office daily check named.

4. Public protection treated as a single line

Why it fails: Eaves-level work creates the highest risk of falling material to footpath / driveway / public realm. A single 'barriers in place' line is not actionable.

Fix: List each public-facing edge separately. Debris netting, chute discipline, exclusion zone, banksman during lifts, S.169 highways licence where the footpath is closed.

Worked example: strip and re-cover a 120m² pitched slate roof

Scope. Strip and re-cover 120m² of natural slate on a 2-storey Victorian terrace, 35° pitch. Replace battens and breathable membrane. Lead flashings to chimneys and abutments. 5-day programme, two NFRC-registered roofers and one labourer. Property occupied — pavement bordering the property below the eaves.

Access. Independent tube-and-fitting scaffold to front and rear, lifts to eaves and ridge, working platform 1.5m below eaves. Single handrail + toeboard at eaves level (not a substitute for the scaffold platform). Debris chute to skip in driveway. No reliance on roof ladders for routine work.

Fragile material. Existing slates assumed sound but treated as fragile until lifted (HSG33 default). Original boarded sarking confirmed sound on first courtyard test square; remaining roof not walked-on until breathable membrane and counter-battens installed. No rooflights on this elevation.

Material handling. Slates loaded to scaffold via Hiab on day 1; daily distribution by hand within 3m carry. Old slates lowered by debris chute, not thrown. Lead sheet rolls limited to 25 kg per lift, two-person carry above 15 kg. Tiles never stacked higher than 1m on the scaffold platform.

Weather. Stop work if 5-min average wind exceeds 23 mph (Beaufort 5) at ridge, if surface is wet/icy, or if temperature falls below 2°C during membrane laying. Met Office region forecast checked at 06:30 daily; on-site handheld anemometer at start of each lift.

Public protection. Pavement closed during strip phase (S.169 highways licence), debris netting full height to street side, banksman during chute use, scaffold sheeted to gable to prevent slate fragments leaving site.

Why it supports a competent review. The assessment names the roof type, pitch and area; defaults the surface to fragile until proven; sequences scaffold edge-protection before any personal fall-arrest; lifts materials mechanically; sets numeric weather thresholds; and protects the pavement by closure plus netting. Each control is testable on site.

From example to your own document

The wizard above starts you on the same structure as the worked example. Two-line description, confirm roof type and access method, and the builder produces the edge-protection schedule, fragile-material register and weather hold-points. First PDF is free, no card.

For the matching method statement see RAMS for roofing, or the trade-hazard variant at working at height RAMS for roofers.

Key Features

  • Roof type routing: pitched / flat / fragile / hybrid
  • HSG33 fragile-material checklist with default-fragile presumption
  • Edge-protection schedule (scaffold + eaves + access)
  • Material lift plan (manual / hoist / telehandler / lift platform)
  • Weather hold-point table (wind, surface wet, ice)
  • Public protection at eaves and gable

Example Structure (UK Standard)

  1. Activity: roof type, area, pitch, location, programme
  2. Access method: scaffold / MEWP / roof ladder + justification
  3. Edge protection: eaves, gable, valley, around openings
  4. Fragile-material register per HSG33 (default fragile until proven)
  5. Material handling sequence (load-up, distribution, removal)
  6. Hot-work permit if torch-on or lead-burning involved
  7. Weather thresholds: wind speed, surface wet, ice, temperature
  8. Public protection at ground level (debris netting, exclusion zone, banksman)
  9. Competency: NFRC / CompetentRoofer / CSCS card per operative
  10. Inspection regime: pre-use, handover, weekly, post-weather
  11. Sign-off and review trigger

Common Questions Before Getting Started

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All documents generated by Riskora should be reviewed by a competent person before use on site. Riskora provides structured templates — professional judgement is always required.

Inside the document

What your RAMS actually contains

Riskora builds a structured, client-facing document — not a generic AI paragraph. Every section is shaped around your job, your site and your team.

  • Hazards

    Task-specific hazards for the job, captured row by row — not a generic list pulled from an old RAMS.

  • Controls

    Control measures mapped to each hazard with residual risk scoring after controls are applied.

  • PPE

    PPE requirements tied to the activity and site, ready to brief to the team.

  • Method steps

    Step-by-step method statement structured around how the work is actually sequenced on site.

  • Emergency arrangements

    First aid, rescue plan, emergency contacts and site-specific escalation routes.

  • COSHH prompts

    Substance prompts when the work involves chemicals, dusts, fumes or sealants — flagged early, not missed at review.

  • Sign-off

    Operative sign-off captured against the document — names, dates and acknowledgement of the brief.

  • Version history

    Every change tracked so you can show what was issued, when, and which version the team signed.

  • Approval status

    Clear approval state on every document — draft, in review, approved, issued — visible across the team.

  • Audit trail

    Who created it, who reviewed it, who signed it. A complete trail you can hand to a principal contractor or auditor.

Before & after

From copied-and-pasted to site-specific

The reason RAMS get rejected is rarely the format — it's that the document is obviously generic. Riskora rebuilds it around this job, this site and this task.

Before

Generic template copied from an old job.

  • • Hazards and controls that don't match this site or task.
  • • Method steps written for a different sequence of work.
  • • No emergency arrangements specific to the location.
  • • Client flags it as generic and asks for a rewrite.
After

Site-specific document structured around this job, site and task.

  • • Hazards captured from the actual scope you pasted in.
  • • Method steps sequenced for how the work runs on site.
  • • Emergency arrangements and rescue plan tied to the location.
  • • Approved internally, briefed to the team, signed off and stored.
How it works

From job details to signed-off document

A four-step workflow used by contractors, consultants and safety teams to turn informal job details into client-ready safety paperwork.

  1. 1
    Paste job details

    Drop in a client email, a WhatsApp from the site manager, a scope of works or a tender note. Anything that describes the job.

  2. 2
    Riskora structures the document

    Riskora turns your brief into hazards, controls, method steps, PPE, emergency arrangements and COSHH prompts.

  3. 3
    Review, edit and download

    You stay in control of every section. Tweak anything, then download a clean PDF or share a link.

  4. 4
    Brief the team and record sign-off

    Brief operatives, capture their sign-off and keep a full audit trail of who signed which version.

Built for site reality

Built by people who've written this paperwork on real sites

Riskora is built by a founder with hands-on site and document experience — designed for contractors, consultants and safety teams who need to issue, brief and prove safety paperwork without losing a day to admin.

  • Built for contractors, consultants and teams
    Solo trades, principal contractors and in-house safety teams all run on the same workflow.
  • Supports multiple countries
    UK, Ireland, Australia, New Zealand, US and Canada — wording and document types match the local standard.
  • Not just documents
    Sign-off, approvals, version history and an audit trail — the management workflow around the paperwork.

Frequently Asked Questions

Yes. The wizard routes pitched, flat, fragile and hybrid roofs separately. Pitched picks up access ladders, ridge work and slip risk; flat picks up edge protection, ponding and rooflight perimeter; fragile picks up reg 9 controls (platforms, coverings, fall-arrest). The hybrid route handles re-roofs where new flat upstands meet pitched tiles.

Yes. When the wizard detects hot-work activities, it adds a hot-work permit section: 60-minute fire watch, extinguisher type and proximity, combustibles cleared, no torching in the last hour of the shift. The permit prints alongside the assessment.

Yes. The wizard captures the additional PV-specific hazards: penetration through membrane, DC isolation, micro-inverter handling, panel manual-handling weight, lightning-protection bonding and roof load check. The base WAH controls carry through.

It's the wording from the Management of Health and Safety at Work Regulations 1999. In practice it means the assessment identifies the significant hazards, evaluates who could be harmed, considers existing controls, and is proportionate to the risk — not generic, not exhaustive, but enough to actually inform safer work.

Not always. If the work, site conditions and people are genuinely the same as a previous job, you can reuse a risk assessment — but you must review it and confirm nothing has changed. As soon as the site, scope or team changes, it needs revisiting.

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References & Further Reading

Primary UK sources covering the legal and practical framework behind RAMS, risk assessments and method statements.

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Final RAMS must be reviewed and approved by a competent person before use.

Riskora is an assistive document preparation tool. All documents generated must be reviewed, verified, and approved by a competent person before use on site. Riskora does not replace professional safety judgment, and no output should be treated as a legal compliance guarantee.