Risk Assessments · Mandatory · Pre-Construction

RAMS — Roofing Works

This RAMS addresses risks associated with roofing activities including falls from height, fragile surfaces, weather exposure, and material handling at elevation. It covers edge protection systems, crawling boards for fragile roofs, safety netting, and harness use. Wind speed limits and weather monitoring procedures must be defined for exposed roof work.

Last reviewed: 29 March 2026 — This guide reflects UK law as of this date. WAH Regs 2005 remains current with no amendments enacted as of 29 March 2026. Next scheduled review: 29 March 2027.

RAMS category	B12 Roofing Works
Primary legislation	Work at Height Regulations 2005
Industry guidance	HSG33 (HSE guidance on roof work); ACR[CP]001 (fragile roofs advisory committee); ACR[CP]007 (recommended practices for work on built-up and membrane roofs)
Fragile roofs	Any roof assembly that would not support the weight of a person plus any load they might carry, including deteriorated materials — must be treated as fragile unless proved otherwise
Competence standard	NVQ Level 2/3 in Roofing; NFRC RoofCERT; CSCS card at appropriate grade. CSCS Industry Accreditation (IA) route expired January 2025 — NVQ or equivalent now mandatory.
Fatal statistics	Roof work accounts for a disproportionate share of fatal falls from height — approximately 25% of all WAH fatalities in construction
Enforcing authority	Health and Safety Executive (HSE)

1. What It Covers

A RAMS for Roofing Works covers the installation, repair, maintenance, and removal of all types of roof covering and associated components. This includes pitched roofing (slates, tiles, shingles), profiled metal roofing and cladding, flat roofing (built-up felt, single-ply membrane, mastic asphalt, liquid-applied systems), green and living roofs, rooflights and roof glazing, rainwater goods, ridge and hip tiles, lead and zinc work, and associated structural work such as battening, sarking, and vapour barrier installation.

Roofing work is among the most dangerous activities on any construction site. Falls from the roof edge, falls through fragile roof materials, and falls through openings account for a disproportionate share of fatal and serious injuries. HSE data consistently shows that roof work accounts for approximately 25% of all fatal falls from height in construction — making it the single most lethal category of working at height activity.

The Work at Height Regulations 2005 apply to all roof work. HSG33 (Safety in Roof Work) is the HSE's specific guidance for this sector. The Advisory Committee for Roofsafety (ACR) publishes additional guidance on fragile roofs (ACR[CP]001), working on built-up and membrane roofs (ACR[CP]007), and other specialist roof work scenarios. Every RAMS for roofing must address the specific roof type, the access and egress arrangements, edge protection, fragile material identification, weather constraints, and the competence of the roofing team.

Roof work is the leading cause of fatal falls in construction

HSE enforcement data shows that falls from or through roofs are the single largest sub-category of fatal falls from height in UK construction. Many of these fatalities involve fragile roof materials — fibre cement sheets, plastic rooflights, and deteriorated felt — that fail under body weight without warning. The risk is not confined to old roofs: new profiled metal roofing with unprotected rooflights is one of the most common fatal fall scenarios. Every RAMS for roof work must treat fragile surfaces as a primary hazard.

2. Roof Types

Different roof types present different hazard profiles. The RAMS must be specific to the roof type being worked on, because the edge protection requirements, fragile surface risks, access methods, and fall prevention measures differ significantly between roof types. The following table sets out the principal roof types encountered on construction sites and the key hazard considerations for each.

Roof type	Description	Key hazard considerations
Pitched slated/tiled	Traditional pitched roofs covered with natural or artificial slates, concrete or clay tiles, fixed to timber battens over a breathable membrane or sarking board	Falls from eaves edge and gable ends; falls from ridge; slipping on steep pitch (above 30 degrees requires special measures); manual handling of tiles and slates at height; fragile rooflights if present; battening sequence must ensure edge protection before roof covering
Profiled metal	Industrial and commercial roofs formed from profiled steel or aluminium sheets, typically with insulation and liner panel, often including translucent rooflights	Falls from edge (often high buildings with long fall distances); falls through fragile rooflights that are visually similar to metal sheets; walking on unsupported areas between purlins; wind uplift during installation; cutting debris (swarf) causing eye and skin injuries
Flat built-up (felt/single-ply/membrane)	Low-pitch or flat roofs using multiple layers of bituminous felt, single-ply membranes (e.g. Sarnafil, Firestone EPDM), or liquid-applied waterproofing systems	Falls from unprotected edges (perimeter, upstands, roof access openings); burns from hot bitumen and torches; COSHH exposure from adhesives, primers, and solvents; fire risk from torch-on application; fragile sections on older roofs where felt has deteriorated
Flat mastic asphalt	Specialist flat roofing using heated mastic asphalt applied in layers, typically over concrete decks or timber substrates with isolating membranes	Severe burn risk from molten asphalt (applied at approximately 220 degrees Celsius); manual handling of heavy asphalt blocks to point of use; COSHH fumes from heated asphalt; fire risk; falls from edge; working in proximity to hot materials on an elevated surface
Green/living roof	Roof systems incorporating growing medium and vegetation, ranging from extensive sedum blankets to intensive planted roof gardens, over waterproofing membranes	Heavy dead and imposed loads (saturated growing medium can weigh 80 to 200 kg/m2); structural adequacy must be confirmed before installation; manual handling of growing medium, drainage boards, and planters; edge protection during installation; slip hazard on wet vegetation; ongoing maintenance access requirements

3. Edge Protection Hierarchy

The Work at Height Regulations 2005 require that a strict hierarchy is followed for all roof work. The hierarchy applies specifically to how falls from the roof edge are managed. Collective protection — measures that protect everyone without requiring individual action — must be considered before personal protection. The three levels of the hierarchy must be followed in order, and the RAMS must justify any departure from the highest level.

Level	Principle	Application to roof work
PREVENT falls	Physical barriers that prevent any person from reaching an unprotected edge or falling from the roof	Scaffolding with full guardrails at eaves and gable ends, extended above roof level (minimum 950 mm above eaves or working surface). Permanent parapet walls above 950 mm. Edge protection systems (guardrails, toe boards, brick guards) fixed to the roof perimeter. Scaffolding is the preferred method for pitched roof work because it provides a full working platform, material storage, and edge protection simultaneously.
ARREST falls	Systems that catch a person after they have fallen, limiting the distance and consequences of the fall	Safety nets installed below the roof working area (typically between the purlins or below the roof structure). Soft landing systems (air bags) positioned below the working area. Fall arrest harnesses with lanyards attached to suitable anchor points (with documented rescue plan). Fall arrest is only acceptable where fall prevention is not reasonably practicable.
MINIMISE consequences	Measures that reduce the distance or severity of a fall where neither prevention nor arrest is fully achievable	Working platforms as close to the working level as possible to minimise potential fall distance. Crash decks below the working area. Personal fall protection with energy absorbers that limit impact force. This level of the hierarchy should only apply where both prevention and arrest have been considered and found not reasonably practicable for the specific task.

Scaffold at eaves is the benchmark for pitched roof work

For pitched roof work, an independent tied scaffold at eaves level — with guardrails extending at least 950 mm above the eaves — is the expected standard of edge protection. HSG33 and HSE enforcement practice both treat eaves scaffold as the default for all but the shortest-duration or smallest-scale pitched roof tasks. A RAMS that specifies anything less than eaves scaffold for pitched roof work must provide a clear, documented justification for why scaffold is not reasonably practicable, and must demonstrate that the alternative provides an equivalent level of protection.

4. Key Hazards

The following table identifies the principal hazards associated with roofing works on construction sites, who is at risk, the contributing risk factors, and the controls that must be addressed in the RAMS.

Hazard	Who at risk	Risk factors	Controls
Falls from roof edge	Roofers, labourers, and any operatives working near unprotected eaves, gable ends, or verge edges	Missing or incomplete edge protection; scaffold not extended above eaves level; guardrails removed by other trades; working beyond the protected perimeter; poor visibility in early morning or late afternoon	Scaffold at eaves with guardrails minimum 950 mm above eaves; gable end protection; edge protection installed before roof work begins; scaffold inspected before each shift; no work beyond the protected perimeter without harness and rescue plan
Falls through fragile roof materials	Roofers, maintenance workers, anyone accessing a roof with fragile surfaces (fibre cement sheets, rooflights, liner panels, deteriorated felt, wired glass)	Fragile materials not identified before access; rooflights visually similar to surrounding metal sheets; deteriorated materials not assessed; no crawling boards or staging provided; operatives walking directly on fragile areas	Fragile surface survey before any access (ACR[CP]001); all fragile areas marked with warning signage at access points; crawling boards or stagings across fragile areas; covers secured over rooflights (not just placed but fixed); safety nets below fragile areas; exclusion zones around fragile materials; operatives briefed on fragile locations
Falls during access and egress	All operatives accessing the roof via ladders, scaffold stair towers, or internal routes	Ladder access used for regular roof access (ladders are not suitable for frequent use); access point not protected; step-off from ladder to roof not managed; internal stairwells leading to roof access without edge protection at the transition point	Scaffold stair tower preferred for regular access; ladder access only for short-duration or infrequent tasks; ladder secured at top and extending at least 1 m above landing point; safe step-off arrangement at roof level; gate or barrier at access point to prevent unauthorised access
Burns from hot bitumen and torches	Roofers carrying out built-up felt, torch-on membrane, or mastic asphalt work	Molten bitumen at approximately 220 degrees Celsius (mastic asphalt); open flame from propane torches (built-up felt); splashing during pouring or application; clothing ignition; overheating of substrate causing fire	Hot work permit in place; fire extinguisher at point of work; fire watch maintained for minimum 60 minutes after torch work ceases; appropriate PPE (heat-resistant gloves, boots, face protection); no loose clothing; designated bitumen boiler position away from combustible materials; burns first aid kit on site
COSHH (adhesives, primers, solvents, bitumen fumes)	Roofers using solvent-based adhesives, bitumen primers, liquid-applied membranes, and cleaning solvents	Inhalation of solvent vapours in poorly ventilated areas (particularly around parapets and upstands); skin contact with uncured adhesives and primers; bitumen fume exposure during hot applications	COSHH assessment for all substances used; natural ventilation normally adequate on open roofs, but RPE required in enclosed or sheltered areas; correct PPE (solvent-resistant gloves, eye protection); material safety data sheets available on site; application rates and temperatures within manufacturer limits
Asbestos cement roofing	Roofers, maintenance workers, and anyone disturbing asbestos-containing roof materials	Asbestos cement roof sheets on pre-2000 buildings (widespread on industrial and agricultural buildings); fibre release during cutting, drilling, breaking, or pressure washing; material often deteriorated and more friable than when new	Refurbishment and demolition survey before any work on roofs of pre-2000 buildings; licensed asbestos removal contractor where required; notifiable non-licensed work (NNLW) procedures for asbestos cement removal; operatives trained in asbestos awareness as a minimum; no cutting, drilling, or pressure washing of asbestos cement; wet removal methods
Manual handling	Roofers handling tiles, slates, rolls of felt, insulation boards, and sheet materials at height	Heavy materials (concrete tiles, asphalt blocks, rolls of single-ply membrane) carried by hand to point of use; repetitive lifting above shoulder height; working on sloped surfaces; materials hoisted by gin wheel or crane and requiring manual positioning	Mechanical handling wherever possible (telehandler to scaffold, hoist to upper levels); materials delivered to point of use by crane where practicable; team lifts for heavy items; manual handling assessment for all roof-level tasks; lightweight alternatives specified where available (e.g. lightweight tiles)
Adverse weather	All operatives working on exposed roof surfaces	Wind making materials uncontrollable and operatives unstable; rain making surfaces slippery; ice on pitched roofs; reduced visibility; lightning risk on exposed structures; heat stress in summer on dark roof surfaces	Wind speed monitoring with stop-work thresholds (typically 17 m/s for general work, lower for sheet handling); no roof work on icy surfaces until ice cleared; weather forecast checked daily; RAMS to specify weather-related stop-work criteria; hydration and rest breaks in hot weather on sun-exposed roofs
Falling objects	Persons at ground level, pedestrians, other trades working below the roof	Tiles, slates, tools, or materials falling from the roof edge or through openings; wind displacing loose materials; materials dropped during hoisting; debris from stripping operations	Scaffold with toe boards, brick guards, and debris netting at eaves; exclusion zone at ground level during stripping and material handling; tool lanyards; materials secured against wind; fans or catch nets below openings; controlled lowering of waste materials (not thrown from the roof)

5. Competence

Roofing competence requirements have recently tightened following the expiry of the CSCS Industry Accreditation (IA) route in January 2025. All roofers on UK construction sites must now hold a qualification-based CSCS card, underpinned by an NVQ or equivalent qualification. The RAMS must specify the competence requirements for every member of the roofing team and the principal contractor must verify these before work begins.

Requirement	Standard / Qualification	Notes
NVQ / SVQ qualification	NVQ Level 2 or 3 in Roofing Occupations (various pathways: slating and tiling, built-up felt, single-ply, mastic asphalt, sheeting and cladding)	The NVQ pathway must match the type of roofing work being carried out. A roofer qualified in slating and tiling is not automatically qualified for single-ply membrane installation. The RAMS must specify the relevant NVQ pathway.
NFRC RoofCERT	National Federation of Roofing Contractors RoofCERT competence scheme	RoofCERT is the NFRC's competence card scheme for the roofing industry. It provides occupation-specific cards linked to NVQ achievement. RoofCERT is increasingly required by principal contractors as evidence of trade-specific competence alongside the CSCS card.
CSCS card	CSCS Skilled Worker card (blue) or Advanced Craft (gold), with roofing occupation listed	The CSCS card must be at the appropriate level and must list the roofing occupation. The CSCS Industry Accreditation (IA) route expired in January 2025. Cards issued under the IA route are no longer valid for renewal — operatives must now hold an NVQ or equivalent to obtain or renew a CSCS card. Expired IA-route cards must be flagged during competence checks.
Asbestos awareness	Category A asbestos awareness training (mandatory for all construction workers who may disturb asbestos-containing materials)	All roofers working on pre-2000 buildings must have completed asbestos awareness training. For work specifically involving asbestos cement roof sheets, additional training or a licensed contractor may be required depending on the scope and condition of the material.
Supervisor qualification	SSSTS (Site Supervisors’ Safety Training Scheme) or SMSTS (Site Management Safety Training Scheme)	Roofing supervisors and foremen must hold SSSTS or SMSTS in addition to their trade qualifications. This confirms they understand their duties for managing health and safety on site, including the management of working at height, COSHH, and fire risks.

CSCS Industry Accreditation (IA) route expired January 2025

The CSCS Industry Accreditation (IA) route — which allowed experienced roofers to obtain a CSCS card based on employer endorsement without a formal NVQ — expired in January 2025. Cards issued under this route cannot be renewed. Roofers who previously held IA-route cards must now achieve a relevant NVQ (or equivalent qualification recognised by CSCS) to obtain a new card. The RAMS competence checks must flag any expired IA-route cards and ensure that all operatives hold qualification-based cards.

6. Common Mistakes

Starting roof work before edge protection is in place

Edge protection must be installed before any roofing operative sets foot on the roof. This means eaves scaffold with guardrails, gable end protection, and any other perimeter protection must be complete, inspected, and signed off before roof work begins. Starting work with partial or incomplete edge protection — or relying on individual operatives to stay away from the edge — is the single most common cause of fatal falls from roofs.

Failing to identify and protect against fragile roof surfaces

Fragile surfaces are the second leading cause of fatal falls in roof work. Every RAMS for roof work must include a fragile surface assessment carried out before access. Rooflights, fibre cement sheets, liner panels, deteriorated felt, and wired glass are all fragile. If the fragility of a surface is unknown, it must be treated as fragile until proved otherwise. Protection measures include crawling boards, fixed covers over rooflights, and safety nets below.

Using the CSCS IA route after its January 2025 expiry

The CSCS Industry Accreditation (IA) route expired in January 2025. CSCS cards issued under this route cannot be renewed without a formal NVQ or equivalent qualification. Any roofer on site holding an expired IA-route card does not hold a valid CSCS card. The RAMS competence checks must identify these cards and require the operative to obtain a qualification-based card before returning to site.

Not issuing a hot work permit for torch-on felt and asphalt work

Torch-on felt application and mastic asphalt work both involve open flames or extremely hot materials on a combustible substrate. A hot work permit is essential. The permit must specify the fire precautions (extinguisher at point of work, fire watch for minimum 60 minutes after completion, combustible materials cleared from the work area), the person responsible, and the duration of the permit. Omitting the hot work permit from the RAMS for these activities is a significant gap.

Omitting adverse weather stop-work criteria from the RAMS

Roof work is one of the most weather-exposed activities on a construction site. Wind, rain, ice, and extreme heat all materially increase the risk of falls and other injuries. The RAMS must include specific stop-work criteria for wind speed (typically 17 m/s for general work, lower for sheet handling and work at exposed edges), procedures for ice clearance, and arrangements for monitoring weather throughout the working day. A RAMS that does not address weather is incomplete.

7. Frequently Asked Questions

How do I know if a roof surface is fragile?▾

The Advisory Committee for Roofsafety guidance ACR[CP]001 defines a fragile surface as any roof assembly that would not support the weight of a person (plus any load they might carry) and would fail without warning. Common fragile materials include fibre cement sheets (including those branded as non-asbestos), plastic and GRP rooflights, metal liner panels without structural purlins beneath, deteriorated felt on timber decks, and wired glass. If there is any doubt about the fragility of a roof surface, it must be treated as fragile until tested and confirmed otherwise. The RAMS must include a fragile surface assessment before any access.

Is scaffold at eaves always required for pitched roof work?▾

HSG33 and HSE enforcement practice treat eaves scaffold as the expected standard for all pitched roof work. A RAMS that specifies any lesser form of edge protection must provide a documented justification for why scaffold is not reasonably practicable for the specific project. Short-duration maintenance tasks on domestic properties may, in limited circumstances, justify alternative edge protection such as an eaves guardrail system — but the justification must be explicit and the alternative must still prevent falls. For new-build and commercial projects, eaves scaffold is the benchmark.

What changed with the CSCS IA route expiry in January 2025?▾

The CSCS Industry Accreditation (IA) route allowed experienced roofers to obtain a CSCS card based on employer endorsement and a health, safety and environment test, without holding a formal NVQ. This route expired in January 2025. Cards issued under the IA route cannot be renewed without a formal NVQ or equivalent qualification. Roofers who held IA-route cards must now achieve an NVQ to obtain a new CSCS card. Principal contractors must check for expired IA-route cards during competence verification and must not accept them as valid.

What fire precautions are needed for torch-on felt roofing?▾

Torch-on felt application involves an open propane flame directed at bituminous material on a potentially combustible substrate. The minimum fire precautions are: a hot work permit issued and signed before work begins; a suitable fire extinguisher at the point of work (minimum 9 kg dry powder or equivalent); all combustible materials cleared from the work area and the area directly below; a fire watch maintained for a minimum of 60 minutes after the last torch is extinguished; the permit holder to carry out a final inspection before leaving the roof. The RAMS must include all of these measures and must name the person responsible for the fire watch.

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