Who Writes a RAMS and Who Approves It? CDM 2015 Roles Explained

The short answer: who writes a RAMS and who approves it

Role	Writes RAMS?	Approves RAMS?
Client	No	No (but must allow adequate time and resource)
Principal Designer	No	No (pre-construction focus only)
Principal Contractor (PC)	For their own direct work; reviews all sub-RAMS	Formally approves all contractor RAMS before work begins
Contractor / Subcontractor	Yes — primary author for their own scope of work	Can self-approve only when no PC exists (single-contractor projects)
Competent Person / H&S Advisor	May assist authorship; technically reviews content	No formal approval authority — advisory role only

The full picture — including re-approval after scope change and who holds the signed copy — is in the RACI table below.

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Why authorship and approval are legally distinct responsibilities under CDM 2015

The Construction (Design and Management) Regulations 2015 (CDM 2015) are the primary UK legislation governing health and safety management in construction, including the duties that underpin RAMS authorship and approval responsibilities (CDM 2015).

CDM 2015 does not use the phrase "RAMS" — the industry practice of producing a Risk Assessment and Method Statement derives from the duty-holder structure CDM 2015 creates. That structure separates:

• The person with operational knowledge of how a task will be done (the contractor or subcontractor carrying out the work), who is best placed to write the RAMS.
• The person with overall construction-phase management authority (the principal contractor), who must satisfy themselves that every contractor's working method is safe before that work begins.

Writing requires task-level knowledge. Approving requires site-level authority and an independent check. These are different competences held by different people at different levels of the project hierarchy. Treating them as the same act is the single most common RAMS governance failure on UK construction sites.

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The CDM 2015 duty-holder map: which role owns which stage of the RAMS lifecycle

RACI table — RAMS authorship and approval

CDM Duty Holder	Writes RAMS	Technical Review	Formal Approval	Re-approval After Scope Change	Holds Signed Copy
Client	✗	✗	✗	✗	Optional (for records)
Principal Designer	✗	Advisory (pre-construction only)	✗	✗	✗
Principal Contractor	✓ (own direct work)	✓ (all contractor RAMS)	✓ (all contractor RAMS)	✓ (must re-approve)	✓ (master site file)
Contractor / Subcontractor	✓ (primary author)	✓ (self-review before submission)	✗ (unless single-contractor)	✓ (must resubmit revised RAMS)	✓ (own working copy)
Competent Person / H&S Advisor	✓ (assists / QAs)	✓ (content accuracy)	✗	✓ (assists revision)	✗

Key: ✓ = Responsible or Accountable | ✗ = Not this role's function

Principal Designer note: CDM 2015 assigns the principal designer duties in the pre-construction phase — coordinating health and safety in design and ensuring the construction phase plan is prepared before work begins. Once work is underway, RAMS approval is a principal contractor function. Do not conflate these separate temporal responsibilities.

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Who writes the RAMS — competence, not job title

The person who writes a RAMS should be the person who knows how the work will actually be done. That almost always means the contractor or subcontractor carrying out the task — not the principal contractor, not an H&S consultant drafting generic text at arm's length.

What matters is competence: the author must have sufficient knowledge of the task, the hazards involved, and the controls available to describe the work method accurately and identify genuine risks. This is a practical test, not a credentialling one.

That said, widely accepted good practice in UK construction uses qualifications as evidence of H&S management competence — for example, a site manager holding SMSTS (Site Management Safety Training Scheme), a supervisor holding SSSTS, or an advisor holding NEBOSH qualifications. These are industry conventions, not statutory thresholds set by CDM 2015 itself. Holding a qualification does not automatically mean someone is competent to write a RAMS for a specific task; competence is task-specific and must include direct operational experience of the work in question.

Practical markers of a competent RAMS author:

• Has personally supervised or carried out this type of work before
• Can name the specific hazards — not just generic categories
• Knows which control measures are actually available and proportionate on this project
• Is aware of any site-specific constraints passed down through the construction phase plan

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Who approves the RAMS — independence, authority, and what they are checking

On any project where a principal contractor is appointed, the PC holds formal approval authority for every contractor's RAMS before that contractor starts work. The PC's approval is not a rubber stamp — it is a substantive check that:

1. The method described is consistent with the construction phase plan
2. The hazards identified are complete and site-specific
3. The controls are proportionate and deliverable on this site
4. The document has been briefed to (or will be briefed to) the workers who must follow it

On a single-contractor project (no PC appointed), the contractor approves their own RAMS — but must still ensure the document reflects a genuine assessment rather than a template completed without thought.

An H&S advisor can technically review content and advise on gaps but does not hold approval authority unless they also hold a formal management role (e.g. they are also the PC's appointed contract manager with delegated authority).

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Can the same person write and approve a RAMS? The independence rule explained

The independence rule

The person who approves a RAMS should not be the same individual who wrote it, unless no alternative exists and the risk profile is low.

This is not a statutory rule stated in CDM 2015's text — it is a governance principle that flows directly from the duty-holder separation CDM 2015 creates:

• The contractor/subcontractor writing the RAMS is accountable for operational accuracy.
• The principal contractor approving the RAMS is accountable for construction-phase safety management.

These are different organisations. That structural separation provides automatic independence in most projects. The independence problem arises in two specific situations:

Situation	Risk	Recommended control
PC writes RAMS for their own direct operatives and the same PC manager approves it	Self-review bias; gaps go unnoticed	Have a second manager or H&S advisor review before the approving manager signs
Small subcontractor: one-person business writes and "approves" their own RAMS	No independent check at all	The PC must still review and formally accept the RAMS before work begins — this is the independent check

On any project with a PC, the PC's review and acceptance of a subcontractor's RAMS is, by definition, an independent approval. The issue only truly arises for the PC's own work, where internal governance should require a second-eyes check before sign-off.

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Worked scenario: PC with specialist subcontractor — authorship and approval in practice

Scenario: Temporary works installation on a commercial office refurbishment

• Client: Commercial property owner
• Principal Contractor: BuildCo Ltd
• Specialist Subcontractor: SteelFrame Specialists Ltd (temporary propping works)
• H&S Advisor: External consultant retained by BuildCo

Who does what:

Stage	Action	Person	Role
1. RAMS authored	SteelFrame's working supervisor drafts the method statement and risk assessment for temporary propping	Supervisor, SteelFrame Specialists Ltd	Contractor — primary author
2. Internal QA	SteelFrame's contracts manager reviews for completeness and signs the document as the submitting party	Contracts Manager, SteelFrame	Contractor self-review
3. Technical review	BuildCo's H&S Advisor checks the RAMS against the construction phase plan and flags two gaps: no reference to adjacent excavation and missing emergency de-prop procedure	H&S Advisor, BuildCo	Competent Person — advisory
4. RAMS revised	SteelFrame revises to address both gaps and resubmits	Supervisor, SteelFrame	Contractor — author
5. Formal approval	BuildCo's Project Manager works through the pre-approval checklist (see below), signs the RAMS as approved, and issues a works authorisation	Project Manager, BuildCo Ltd	Principal Contractor — formal approver
6. Site briefing	SteelFrame supervisor delivers toolbox talk to the propping gang; attendees sign the briefing record	Supervisor, SteelFrame	Contractor — workforce briefing
7. Signed copy held	BuildCo holds the accepted RAMS in the site H&S file; SteelFrame retains their working copy	BuildCo Project Manager	Principal Contractor — document control

What the client and principal designer do NOT do: Neither reviews nor approves the RAMS. The client's duty is to ensure adequate time and resource for the project; the principal designer's pre-construction duties have already been fulfilled before this construction-phase activity begins.

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Pre-approval checklist: 12 questions the approver must answer before signing

The principal contractor's approving manager should be able to answer Yes to every item before signing. Any No sends the RAMS back for revision.

#	Question	Yes / No
1	Does the RAMS describe the actual scope of work on this project — not a generic activity?
2	Are the named hazards specific to this site and task (not a copied generic list)?
3	Does the RAMS reference the current construction phase plan where relevant?
4	Are all control measures achievable with the resources the contractor actually has on site?
5	Does the RAMS address any risks identified in CDM 2015 Schedule 3 activities (e.g. excavations, work near high-voltage lines, demolition/dismantling) if applicable?
6	Does the emergency procedure section identify this site's emergency contacts and assembly point?
7	Has the RAMS been signed by a named, competent person at the authoring contractor?
8	Has the RAMS been reviewed since any significant design or scope change?
9	Is there a record of how the RAMS will be (or has been) communicated to the workers carrying out the task?
10	Have any permit-to-work requirements been cross-referenced?
11	Does the RAMS reflect the current site conditions (e.g. adjacent trades, access changes)?
12	Will a copy of the accepted RAMS be held in the site H&S file and be accessible during the work?

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What happens when scope changes — re-approval duties and triggers

A RAMS approved for one scope does not cover a changed scope. Common triggers requiring the contractor to resubmit a revised RAMS and the PC to re-approve include:

• Change to the method (e.g. switching from mechanical to manual handling)
• Change to the location or working area
• Introduction of a new hazard not present at original approval (e.g. discovery of asbestos, adjacent excavation opened)
• Change in personnel where a named competent person was a condition of approval
• Significant change to the programme that alters the interface with other trades

The revision process is similar to the original: contractor revises and resubmits; PC reviews and accepts the revised RAMS through the site change-control process; revised copy replaces the previous version in the site file. Workers must be re-briefed before work under the new method begins.

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Common mistakes: who should NOT be writing or approving RAMS (and why)

Who is doing it (wrongly)	Why it fails
PC writes the RAMS on behalf of a subcontractor	The author has no direct task knowledge; the sub has no ownership; workers don't recognise the document as theirs
Office administrator completes a RAMS template	No operational competence; hazard identification is generic; controls are aspirational not practical
H&S advisor approves without PC management authority	No authority to bind the PC's construction-phase management obligations
RAMS approved by the same person who wrote it (within the PC's own team) with no second-eyes check	Self-review bias; structural independence missing; gaps compounded not caught
RAMS carried forward unchanged from a previous project	Site-specific hazards missed; controls may not be available; emergency details wrong

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How RAMSDocs structures the write–review–approve workflow so nothing slips

RAMSDocs is designed around the CDM 2015 duty-holder separation described on this page:

• Authoring tools guide the contractor through site-specific hazard identification — not generic copy-paste.
• Submission and review workflow routes completed RAMS to the designated PC reviewer before any approval is recorded.
• Version control flags when a scope change invalidates an accepted RAMS and prompts resubmission.
• Audit trail records who wrote, who reviewed, who approved, and when — so the site H&S file is complete without chasing paper.

Every RAMS produced using RAMSDocs should be reviewed and adapted to the specific site, task, and contractor by a competent person before work begins.

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Frequently asked questions

Which specific job role or person is responsible for writing a RAMS? The contractor or subcontractor carrying out the work — specifically whoever has direct operational knowledge of the task. Job title matters less than task competence.

Can a subcontractor write their own RAMS or must the principal contractor do it? The subcontractor writes their own RAMS. The PC reviews and approves it. A PC writing a RAMS on a subcontractor's behalf is a governance failure — the sub has no ownership and no task knowledge was used.

Who has the legal authority to approve or sign off a RAMS before work starts? The principal contractor (or their formally delegated manager) holds approval authority for all contractor RAMS on any project where a PC is appointed. There is no single statutory signature format prescribed in CDM 2015; approval is a documented organisational control.

What qualifications or competence does the author of a RAMS need? Sufficient knowledge of the task, the hazards, and the available controls. Qualifications such as SMSTS, SSSTS, or NEBOSH are widely accepted in UK construction as evidence of H&S management competence, but they are industry conventions, not statutory thresholds set by CDM 2015.

Can the same person who writes the RAMS also approve it? Not when a PC is involved — the PC's review provides the structural independence. For a PC manager approving their own team's RAMS, a second-eyes internal check before sign-off is strongly recommended practice.

What happens if a RAMS is written by someone without adequate competence? The hazard identification will be incomplete, the controls aspirational rather than practical, and the document will not reflect actual site conditions. It provides no real protection to workers and may expose duty holders to enforcement and civil liability if something goes wrong.

At what point in the project does RAMS authorship and approval need to happen? Before the relevant work begins. The RAMS must be approved and briefed to workers before they start the task — not during it or after an incident.

Does the principal designer have any role in reviewing RAMS? No — the principal designer's CDM 2015 duties are focused on the pre-construction phase. Once the construction phase begins, RAMS approval is a principal contractor responsibility. Conflating the two roles creates a false assurance that the PC's construction-phase checks have been done when they have not.

What are a self-employed contractor's RAMS obligations? A self-employed contractor carries the same obligation to produce a suitable and sufficient risk assessment and method statement for their scope of work as any contracting organisation — the duty does not disappear because there is no employer–employee relationship. Where a principal contractor is appointed, the PC must still review and formally accept the self-employed person's RAMS before work starts, providing the independent check that a sole trader cannot give themselves. Self-employed contractors should therefore treat RAMS production as a pre-start deliverable, not an afterthought, and ensure the document reflects the actual conditions and controls on that specific site rather than a generic template.

Should a RAMS submission include a COSHH assessment, and does the principal contractor check for one? In UK construction practice, a complete RAMS package is widely understood to cover risk assessments, method statements, COSHH assessments, and training records — and PC reviewers routinely expect all four elements before granting approval to start. Where a task involves hazardous substances (solvents, cement dust, resins, welding fume and many others), a COSHH assessment identifying the substance, the exposure route, the control measures, and any health surveillance requirements should be included as a matter of course. Submitting a RAMS without a COSHH assessment where one is clearly warranted is a common reason for a PC to reject or return a submission for revision before work can begin.

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This page is for general guidance only. All RAMS documents must be reviewed and adapted to the specific site, task, and contractor by a competent person before work begins. Nothing on this page constitutes legal advice or guarantees regulatory compliance.