COSHH Assessment vs RAMS: Differences, Duties & When You Need Both

Site managers and subcontractors frequently ask whether a RAMS replaces a COSHH assessment, or whether both are genuinely required. The short answer: they are separate legal duties under two separate statutory instruments, and producing one does not discharge the other. This page explains exactly why — and shows, through a worked concrete-cutting scenario, which content belongs where.

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What Each Document Actually Is

COSHH assessment is the written record of an employer's assessment of the risks created by exposure to substances hazardous to health, and the control measures put in place to prevent or control that exposure. It is a statutory requirement under the Control of Substances Hazardous to Health Regulations 2002 (SI 2002/2677) — a specific, substance-focused document.

RAMS (Risk Assessment Method Statement) is an industry term, not a term defined in any statute. In construction, a RAMS combines a risk assessment — identifying hazards and their likelihood and severity — with a method statement setting out the sequence of work steps and the controls to be applied. The term does not appear in legislation; it is the industry-standard document produced to support compliance with planning and management duties, including those established under the Construction (Design and Management) Regulations 2015 (SI 2015/51). RAMS are also used in facilities management and other sectors where CDM 2015 may not apply at all.

Understanding that distinction — one is statutory terminology, one is industry terminology — is the foundation for understanding why they cannot simply replace each other.

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The Legal Basis: Two Separate Statutory Instruments, Two Separate Duties

The duty to carry out a COSHH assessment flows from the Control of Substances Hazardous to Health Regulations 2002 (SI 2002/2677). That instrument imposes duties covering, among other things: assessment of the risk to health created by work involving hazardous substances; prevention or control of exposure; use of control measures; maintenance, examination and testing of control measures; monitoring exposure at the workplace; health surveillance; and information, instruction and training for persons who may be exposed. Each of these is a discrete requirement — the assessment itself is only the starting point.

The framework within which method statements are produced for construction work is established by the Construction (Design and Management) Regulations 2015 (SI 2015/51). CDM 2015 places duties on clients, principal designers, principal contractors and contractors in relation to planning, managing and monitoring construction work. Method statements are the industry-standard means by which contractors demonstrate how they will meet those duties for specific tasks — but CDM 2015 does not use the phrase "method statement" as a defined term, and it does not impose a COSHH assessment duty. That duty remains with COSHH 2002.

These are two separate instruments. Compliance with one does not confer compliance with the other.

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COSHH Assessment vs RAMS: Side-by-Side Comparison Table

	COSHH Assessment	RAMS
Purpose	Assess health risks from exposure to hazardous substances and specify controls to prevent or reduce exposure	Identify task hazards, assess risk, and set out the work sequence and controls to keep workers and others safe
Legal instrument	Control of Substances Hazardous to Health Regulations 2002 (SI 2002/2677)	Industry term — not defined in statute; produced to support duties including those under CDM 2015 (SI 2015/51) in construction
Who must produce it	The employer whose employees (or others) may be exposed to hazardous substances	The contractor responsible for the task; on CDM-notifiable sites, in the context of the principal contractor's construction phase plan
Trigger (what activates the duty)	Any work that may expose people to a substance hazardous to health — regardless of whether the work is construction or not	High-risk or complex construction tasks; also required by principal contractors and clients as a condition of site access across many sectors
Minimum content required	Substance identification; how workers and others may be exposed; frequency and duration of exposure; control measures; who acts and when; monitoring or health surveillance needs where relevant; emergency arrangements	Task description; sequence of work steps; hazard identification; risk ratings; control measures; PPE; competency confirmation; emergency procedures
Review trigger	Significant change in the substance used, the work process, or evidence that controls are no longer effective	Significant change in work scope, site conditions, personnel, or following an incident

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Why One Document Does Not Discharge the Other

This is the gap most guidance glosses over. Here is the mechanism:

A RAMS will typically list a hazardous substance (say, silica dust from concrete cutting) as a hazard, name a control measure (water suppression, RPE), and move on. That is appropriate RAMS content. What it does not — and cannot — do on its own is discharge the employer's obligations under COSHH 2002: it does not fully assess how workers and others may be exposed, how often exposure may occur, whether monitoring or health surveillance is required, and what substance-specific accident or emergency arrangements are needed.

Conversely, a COSHH assessment does not describe the sequence of work steps, confirm the competency of the operatives undertaking the task, or address the non-substance hazards present (working at height, proximity to other trades, plant movements). That content belongs in the RAMS.

Producing only a RAMS leaves the COSHH 2002 duty unmet. Producing only a COSHH assessment leaves the task-planning duties unmet. Both documents are required when hazardous substances are involved in high-risk construction work — and the law imposes them independently.

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Worked Scenario: Concrete Cutting on a CDM Site — What Goes Where

Scenario: A groundworks subcontractor is cutting reinforced concrete slabs on a CDM-notifiable commercial development. The principal contractor has requested a RAMS before work starts. Silica dust is generated by the cutting process.

Content that belongs ONLY in the COSHH assessment

• Substance identification: Respirable crystalline silica (RCS) generated from concrete cutting
• Exposure route: Inhalation of fine airborne particles during dry or wet cutting
• Exposure assessment: Assessment of how exposure could occur, how long and how often workers may be exposed, what controls are already in place, and whether workplace exposure limits or monitoring are relevant
• Health surveillance need: Whether ongoing health surveillance (e.g. lung function monitoring) is required given the nature and duration of exposure — this is a COSHH 2002 requirement, not a RAMS requirement
• Monitoring exposure at the workplace: Whether air monitoring is needed to verify controls are achieving adequate reduction
• Emergency arrangements for substance-related incidents: Procedures specific to acute inhalation or skin/eye contact with the substance

Content that belongs ONLY in the RAMS

• Sequence of work steps: Mark-up, set-up, cutting sequence, clearance, reinstatement
• Non-substance hazards: Noise, vibration (HAVS), manual handling, proximity to live services, working near plant
• Emergency procedures (general): Evacuation routes, first-aid contacts, emergency stop procedures for plant
• Competency confirmation: Operator certification, tool-specific training records
• Site-specific controls: Exclusion zones, permit-to-dig confirmation, coordination with other trades

Content that must appear in BOTH documents

Item	In COSHH assessment because…	In RAMS because…
RPE specification	COSHH 2002 requires the control measure to be specified	RAMS must state the PPE operatives will use during the task
Water suppression / on-tool extraction	COSHH 2002 requires control measures and their maintenance to be recorded	RAMS must confirm the equipment is in place and will be used at each work step
Information and instruction to workers	COSHH 2002 requires that persons who may be exposed receive information, instruction and training	RAMS must confirm workers have been briefed on the method and controls before work begins

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When You Need Both: Triggers That Activate Both Duties Simultaneously

Both a COSHH assessment and a RAMS are required whenever a construction task involves a hazardous substance. Common triggers include:

• Concrete cutting, grinding or breaking — respirable crystalline silica
• Paint removal, surface preparation — solvents, lead in older coatings
• Bonding, sealing and resin application — isocyanates, epoxy resins
• Welding and hot works — fume from coated or galvanised steelwork
• Application of bituminous products — fume and vapour exposure
• Work in confined spaces with chemical hazards — oxygen deficiency, solvent vapour

CDM 2015 Schedule 3 specifically identifies work that puts workers at risk from chemical or biological hazards as work involving particular risks — reinforcing the expectation that such tasks receive elevated planning attention on CDM-notifiable sites. That planning attention does not substitute for the COSHH duty; it sits alongside it.

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How to Embed a COSHH Assessment Within a RAMS Without Losing Compliance

It is a widely accepted practical approach to incorporate COSHH assessment content within a RAMS document — for example, as a dedicated section or appendix — rather than producing two entirely separate documents. This can satisfy both duties in a single file, provided every required content item from each duty is genuinely present.

The risk of the combined approach is that the COSHH content gets condensed to a single line ("refer to SDS") while the method statement content dominates. That is not a COSHH assessment — it is a reference to one. For the embedded approach to work:

1. The COSHH section must stand as a complete assessment in its own right — substance, exposure route, risk evaluation against standards, controls, monitoring, health surveillance determination, and emergency arrangements.
2. The method statement section must stand as a complete task description — sequence, hazards, controls, competency, emergency procedures.
3. The three overlapping items (RPE, engineering controls, worker information) must appear in both sections, not just one.
4. The document must be reviewed and adapted each time either the substance or the task changes — not just when one of them changes.

Frame the combined document as a practical efficiency, not as a legal shortcut. The quality and completeness of the content determines whether both duties are met — not the number of files produced.

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Documentation Gap Checklist: Confirming Neither Document Is Deficient

Use this checklist before submitting your documentation pack. Each item is mapped to its source authority.

COSHH Assessment checks (source: COSHH 2002, SI 2002/2677)

• Hazardous substance(s) identified by name
• Exposure route(s) recorded (inhalation / skin / ingestion)
• Risk assessment completed — likelihood and severity of exposure assessed
• Control measures specified (elimination, substitution, engineering controls, RPE)
• Maintenance and examination requirements for control measures recorded
• Workplace exposure monitoring need assessed and decision recorded
• Health surveillance need assessed and decision recorded
• Information, instruction and training requirement identified
• Emergency arrangements for substance-related incidents recorded
• Review date or review trigger recorded

RAMS checks (source: CDM 2015, SI 2015/51 — planning and management duties)

• Task description and scope defined
• Work sequence set out step by step
• All significant hazards identified (not limited to substances)
• Risk rating applied (likelihood × severity) for each hazard
• Control measures specified for each hazard
• PPE requirements listed
• Competency and training confirmation included
• Site-specific factors addressed (access, proximity to services, other trades)
• Emergency procedures (evacuation, first aid, plant stop) included
• Operative briefing / toolbox talk confirmation included
• Review date or review trigger recorded

Overlap checks (must appear in both documents, or in both sections if combined)

• RPE specification consistent across COSHH assessment and RAMS
• Engineering controls (e.g. on-tool extraction, water suppression) consistent across both
• Worker information and instruction requirement addressed in both

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Decision Tree: COSHH Assessment, RAMS, or Both?

The following describes a decision tree suitable for rendering as a diagram.

Start: Does the task involve a substance hazardous to health?

• No → Is the task high-risk construction work?

  • No → Standard risk assessment may suffice; review with your competent person
  • Yes → RAMS required (to support CDM 2015 planning and management duties)

• Yes → COSHH assessment required (duty under COSHH 2002 is triggered)

  • Is the task also construction work?
    • No → COSHH assessment required; RAMS may still be required by the client or principal contractor as a site access condition — confirm with them
    • Yes → Both COSHH assessment and RAMS are required
      • Can they be combined into one document?
        • Yes, if all required content from each duty is fully present
        • No if the COSHH content would be compressed to a cross-reference only

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How ramsdocs Helps You Produce Both Documents from a Single Workflow

ramsdocs is built around the reality that most construction tasks triggering a RAMS also trigger a COSHH assessment. The workflow prompts you through both sets of required content in sequence — substance identification, exposure route, control hierarchy, and health surveillance determination alongside the task sequence, hazard register, and competency confirmation — so that neither document is left with gaps.

The output is a PC review-ready documentation pack designed to reduce RAMS rework. It does not replace the judgement of a competent person, and every output must be reviewed and adapted to the specific site, task, and contractor before use.

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Frequently Asked Questions

What is the difference between a COSHH assessment and a RAMS? A COSHH assessment is a statutory document required by the Control of Substances Hazardous to Health Regulations 2002, focused specifically on hazardous substance exposure. A RAMS is an industry term for a combined risk assessment and method statement, used to plan and communicate how a task will be carried out safely. They address overlapping but distinct sets of requirements.

Do I need both a COSHH assessment and a RAMS, or does one replace the other? When a task involves hazardous substances and falls within construction work, both are required. Neither replaces the other — they are grounded in separate legal instruments with separate content requirements.

Can a COSHH assessment be included inside a RAMS document? Yes, as a practical approach, provided the COSHH content is complete — not condensed to a cross-reference — and all required content from both duties is genuinely present in the combined document.

What law requires a COSHH assessment, and what law requires a RAMS? The COSHH assessment duty is imposed by the Control of Substances Hazardous to Health Regulations 2002 (SI 2002/2677). RAMS is an industry term, not a statutory term; in construction, method statements are produced to support compliance with the planning and management framework established by the Construction (Design and Management) Regulations 2015 (SI 2015/51).

Which trades or tasks trigger the need for a COSHH assessment alongside a RAMS? Any construction task involving a hazardous substance — concrete cutting (silica dust), welding (fume), paint removal (solvents), resin application (isocyanates), bituminous product application, and work in chemically contaminated environments, among others.

What happens if you only produce a RAMS but fail to do a COSHH assessment? The duty under COSHH 2002 remains unmet. A RAMS does not fully assess how exposure may occur, how often and for how long people may be exposed, whether monitoring or health surveillance is required, or what substance-specific emergency arrangements are needed. In the event of a health incident, the absence of a COSHH assessment will be identifiable in any investigation and will not be remedied by the existence of a RAMS.

Does the Management of Health and Safety at Work Regulations 1999 have any role in RAMS, or is CDM 2015 the only relevant instrument? MHSWR 1999 is arguably the primary instrument requiring risk assessments: as noted in The safe use of vehicles on construction sites, regulation 3 of the Management Regulations requires employers and self-employed workers to identify the measures they need to take by carrying out risk assessments. CDM 2015 adds construction-specific planning and management duties on top of that baseline obligation. In practice, a RAMS produced for a construction task needs to satisfy both instruments — the MHSWR 1999 duty to assess risk and the CDM 2015 duty to plan, manage and monitor the work — which is why principal contractors routinely request RAMS before granting site access regardless of whether a project is formally CDM-notifiable.

Where does PUWER 1998 fit into the RAMS picture for tasks involving powered equipment? The safe use of vehicles on construction sites lists the Provision and Use of Work Equipment Regulations 1998 as applying to the selection, use and maintenance of work equipment on construction sites. For trades using powered cutting saws, disc cutters or on-tool extraction equipment, PUWER 1998 means the RAMS should address equipment selection, pre-use checks, operator competency and maintenance requirements — not just the task hazards in general terms. This is separate from both the MHSWR 1999 risk assessment duty and the COSHH 2002 obligation to control substance exposure, reinforcing why a single generic document rarely covers all the relevant regulatory ground.

Some principal contractors ask for a four-component RAMS package including training records — is that a legal requirement or a contractual one? No regulation explicitly requires a four-component package. The broader interpretation — Risk Assessments, Method Statements, COSHH Assessments, and Training Records bundled together — is a practice-level standard that has developed because principal contractors need to verify hazard identification, control measures, and operative competence in a single submission before granting site access. Training records sit outside the literal RAMS acronym but address the COSHH 2002 obligation to provide information, instruction and training to persons who may be exposed, as well as the competency confirmation that any well-constructed method statement should contain. If a principal contractor specifies a four-component package in their pre-qualification or subcontract conditions, that becomes a contractual requirement — but the underlying duty to maintain each component arises from the separate regulations that govern it.

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Disclaimer: This page provides general guidance on the relationship between COSHH assessments and RAMS. It does not constitute legal advice. All documentation must be reviewed and adapted to the specific site, task, substances involved, and contractor by a competent person before use. Document production alone does not constitute compliance — the accuracy, completeness and implementation of controls determines whether duties are met.