What a roofing risk assessment must cover, fragile surfaces included

Why roofing risk assessments are different

A roofing risk assessment is not a copy-paste from a generic work at height form. Roofs have got their own traps, from skylights you cannot see in low winter sun to a parapet that looks safe until the coping comes loose in your hand. Falls from height remain the biggest single cause of fatal injuries in construction, according to HSE’s fatal injury statistics, and roof work features again and again. If you want a document that actually keeps people alive, start by facing what makes roofing unique.

HSG33, Health and safety in roof work, is the reference that spells out how to control the real risks on roofs. Pair that with the Work at Height Regulations 2005, which put legal duties on planning, competence, equipment and inspection. In practice, that means choosing the safest way to do the job and documenting how you will prevent both workers and materials from going over the edge, through a fragile deck or onto the public below. The paperwork follows the plan, not the other way round.

We see assessors miss the same points over and over. No mention of roof lights, even though there are fifty on the plan. Vague lines like stop if windy, with no number anyone can use. Edge protection that suits a dry new build, not a wet Tuesday on a live school with kids walking under the exclusion zone. If your assessment tackles fragile surfaces, edge protection choice, weather limits, lifting to height and public protection, you are covering the big hitters the inspector will look for.

If you need a fuller walkthrough of the document structure, see our Roofing RAMS Guide for UK Contractors before you start drafting.

Fragile surfaces and roof lights

Fragile means you cannot trust it to take a person’s weight. HSG33 lists typical culprits, like old roof lights, fibre cement sheets, corroded steel sheets, rotten timber decking and any covering that has been fire or water damaged. Your roofing risk assessment needs a clear plan to find them, mark them and stop anyone stepping on them. That starts with a careful pre-start walkdown, drawings check and photos, not just a glance from the ground.

Controls should be specific to what you find. Over-sheeting a fragile roof? Then you need properly supported staging, crawling boards or proprietary walkways, with collective protection at the edges. Working near roof lights? Fit robust covers that are fixed, load bearing and signed, or install guardrails round them. A blob of red paint is not a control. For temporary covers, use materials of known strength, fix them so they cannot move and label them do not remove.

Never rely on a harness as your only control for a fragile deck. Restraint lines can keep people off danger areas, but anchoring on the fragile structure is asking for a fall. If you cannot make the surface safe to walk, consider access from below or from a mobile elevating work platform. HSG33 is clear that you must prevent falls through fragile materials, not just reduce the distance. If you lack the kit to do that, the right call is to stop the job until you do.

For a starting point you can adapt to your job, use a Roofing RAMS template that already flags fragile surfaces, weather and public protection.

Picking the right edge protection

Edge protection is not one-size-fits-all. A parapet might look like it protects you, but many parapets are too low or too weak to count as a guardrail. Your roofing risk assessment should set out what edge protection goes where, and why. For strip and re-sheet on a big industrial shed, a full scaffold or proprietary temporary guardrail system is often the safest bet. On short domestic work, a properly specified scaffold or a mobile access tower at each elevation may be enough.

Think about the drop distance, roof pitch, temporary openings and where materials will be raised and lowered. If the risk of falling objects is high, add toeboards, fans and debris netting. For internal atriums or voids, plan guardrails and covers as part of the sequence, not as an afterthought. If you are tempted by personal fall protection, decide if it will be restraint or arrest. Restraint stops you reaching the edge and is preferred. Arrest lets you fall and must come with a properly worked rescue plan.

Safety nets and airbags can reduce consequences, but they do not stop a fall. Nets must be installed by competent riggers and inspected, and you still need to manage falling materials. Where MEWPs are used as the working platform, specify the model, outreach, ground bearing, exclusion of pedestrians and rescue method if it fails. The Work at Height Regulations 2005 expect you to prioritise collective measures like guardrails over harnesses, so explain your choice in the assessment.

If you are opting for fall arrest anywhere, read our take on working at height rescue plans so the method is realistic for your site.

Weather: write stop conditions as numbers

Weather ends roof jobs, and a line that says stop if windy will not help on a gusty afternoon. Put exact numbers in your roofing risk assessment, and say where and how you will measure them. For sheet handling, many contractors use a stop at sustained 23 mph, 10 m/s, with a lower trigger of around 17 mph, 7.5 m/s, for long flexible sheets and insulation boards. Check the manufacturer’s handling limits and your lifting method, then set your figures in black and white.

Write who makes the call, what instrument they use and where it is sited. A cheap anemometer at roof level beats a smartphone app in the canteen. Note gusts as well as sustained wind. Add stop points for lightning, hard rain, ice and extreme heat. For torch-on or hot works, list surface dryness tests and ambient temperature limits from the product data. If wind or rain can turn a board into a sail, assume it will, and plan your sequences and lay-down areas so you are not forced into bad decisions.

When you stop, you also need to make the roof safe. That means securing loose sheets and boards, tying down palletised loads, removing temporary covers that could blow away and checking catch nets. If you have cranes or hoists on site, make sure the lift plan includes wind limits for the specific equipment. The Work at Height Regulations 2005 require work to be properly planned and carried out in a manner that is as safe as reasonably practicable, which includes pausing work when conditions breach your thresholds.

Moving materials to and on the roof

Manual handling on a roof is a fast route to strains and near-misses. Your assessment should specify how kit and materials get up, how they move across the roof and how waste comes down. Options include goods hoists, cranes with certified lifting accessories, gin wheels for small loads, and MEWPs for placement. If you crane loads, include a lift plan that names the appointed person, slinger and signalling method, and sets wind limits for the load shape, not just the crane.

On the roof, plan clear routes, staging and lay-down areas away from edges and fragile zones. Part-loaded transoms and makeshift platforms are a classic risk. Use proper load-spreading and never stack more weight than the structure can take. Your sequence should minimise double-handling. If packs must be broken down, do it in a safe zone with temporary edge protection or netting below. Small controls matter, like tethering hand tools, using magnetic trays for fixings and keeping cuttings in enclosed bins so nothing migrates to the edge.

Waste must be managed as carefully as new materials. Chutes need fixing, barriers and a no-go zone below. If you are lowering by MEWP or hoist, write how you prevent collisions and keep people out of the landing zone. COSHH controls belong here too. If you are handling solvent-based adhesives, primers or sealants, include ventilation on the roof and in the store, spill kits and safe decanting. Combine the handling plan with your weather limits so you do not get caught part-lifted when the wind picks up.

Protecting the public and the job below

Most roofing jobs sit over something that keeps running, a shop entrance, a school playground, a hospital corridor. Your roofing risk assessment needs a traffic and pedestrian plan that is as clear as your fall protection. Start with exclusion zones sized for the real drop height, not a token barrier with a tired sign. Use solid barriers, scaffold fans, debris netting and boarded lifts where falling materials are a risk. Time deliveries and noisy works out of public hours wherever you can.

Think about the routes under and around the building. Redirect footfall early with big clear signage and stewards if needed. If you cannot move people, then you must upgrade the protection above them. Small stuff falls too, so tether tools and use bucket lanyards. Fix sheet stacks so a gust cannot move them. Keep scuppers and gutters clear so water does not pour on the entrance. If you are over live plant rooms or clean areas, add dust control and sealing, and plan how to respond if there is a leak.

Coordination is key under CDM 2015. Agree interfaces with other trades so no one strips a section while someone else walks below. Put your inspections on a schedule, daily checks of edge protection, covers, nets and barriers, and record them. The Work at Height Regulations 2005 also expect inspection of places of work at height and guardrails at suitable intervals by a competent person. If the site changes, update the assessment. The public do not get a second chance if something comes off the roof.

Questions we get asked

What should a roofing risk assessment include as a minimum?

Identify fragile surfaces and roof lights, specify edge protection and fall prevention, set numeric weather stop limits, plan lifting and handling to height, and protect the public below. Add access arrangements, inspection and rescue planning under the Work at Height Regulations 2005, and follow HSG33 for roof-specific controls.

How do I set wind limits for roof sheeting?

Use numbers your team can measure, for example stop at sustained 10 m/s, 23 mph, for metal sheets and a lower threshold around 7.5 m/s, 17 mph, for long flexible sheets and insulation. Check manufacturer guidance and your lifting method, measure at roof level with a handheld anemometer, and record readings.

Do I have to treat all roof lights as fragile?

If you do not have proof they are non-fragile to a known standard, treat them as fragile. HSG33 identifies roof lights as common fragile elements. Control by fixed robust covers or guardrails, and mark them so no one steps on them by mistake.

Is a harness enough protection on a fragile roof?

No. A harness cannot make a fragile surface safe and it can increase the risk if anchors are fixed to the fragile structure. HSG33 expects you to prevent falls through fragile materials, for example by covers, staging and guardrails. If you use personal fall protection, plan a workable rescue.

What does the law actually require for roof work?

Plan and carry out the work safely under the Work at Height Regulations 2005, using competent people, suitable equipment and inspections. Under CDM 2015, coordinate with the principal designer and principal contractor so your controls integrate with the wider site. HSG33 gives practical guidance on roof-specific measures.

The short version

Roofing needs a risk assessment that tackles the real hazards: fragile surfaces and roof lights, the right edge protection, weather with numeric stop points, safe lifting to height and proper public protection. Use HSG33 with the Work at Height Regulations 2005 and write controls your crew can follow on a wet Tuesday, not just on paper.

Mark and cover fragile areas, choose collective protection first, set wind limits in mph or m/s, plan materials routes and lay-down, and fence off the drop zones below. Falls from height kill, as HSE data shows, so be specific, measure what matters and stop the job when conditions cross your lines.