The control measure column is where most RAMS documents fall short. Writing effective control measures requires applying the hierarchy of control systematically and being specific about what is actually being done rather than what is hoped for.
The hierarchy of control
The hierarchy of control is the framework for structuring control measures from most to least effective. It requires that higher-level controls be considered before resorting to lower-level ones.
Elimination means removing the hazard entirely — can the task be redesigned so the hazard does not exist? This is the most effective control because it removes the risk at source.
Substitution means replacing a hazardous material or process with a less hazardous one — using a lower-toxicity solvent, switching to pre-cut materials to reduce manual handling, choosing mechanical fixing over chemical where possible.
Engineering controls are physical measures that do not depend on human behaviour to work — edge protection, machine guarding, local exhaust ventilation, a vehicle exclusion zone with physical barriers. These controls work whether the operative remembers to use them or not.
Administrative controls rely on procedure and human behaviour — safe systems of work, permit to work systems, two-person working requirements, training, supervision. They are less reliable than engineering controls because they depend on people following the procedure correctly every time.
PPE is the last resort. It is the only control in the hierarchy that must be used correctly by the operative every time it is needed in order to work. All other controls work whether the operative remembers or not.
What a good control measure looks like
A good control measure is specific, actionable and tied to the exact hazard it is controlling.
For a working at height hazard, a poor control measure reads: "Ensure safe access and egress. Use appropriate PPE."
A good control measure for the same hazard reads: "Scaffolding to be erected to BS EN 12811 by a CISRS-qualified scaffolder and inspected weekly and after adverse weather. Operatives to use full harness clipped to a designated anchor point rated to minimum 22kN when working within 2m of any unprotected edge. Ground-level exclusion zone to be maintained by physical barriers for the duration of the task."
The difference is specificity. The first tells the operative nothing they did not already know. The second tells them exactly what has been done, what they are required to do and what the standards are.
Common failures
Avoid these in every control measure column:
- "Take care" — not a control measure
- "Use appropriate PPE" — too vague, specify what PPE
- "Follow site rules" — not a control measure
- "Be aware of your surroundings" — not a control measure
- "Trained operatives only" — specify the required training or qualification
Checking your control measures
Before submitting a RAMS document, check each control measure against these questions. Is the control specific enough that an operative who has never worked on this site could follow it? Does the control address the hazard at the highest level of the hierarchy that is reasonably practicable? Is there a residual risk score that reflects whether the control has adequately reduced the risk?
If the answer to any of these is no, the control measure needs to be revised.
Control measures are only as good as the hazards they are written against, so the two jobs go together: the hierarchy of control for the order to apply them in, and how to conduct a site-specific risk assessment for identifying what needs controlling in the first place. Vague controls are among the first things flagged in a review — see what critical means in a report.
This article is general guidance on UK construction documentation practice. It is not legal advice, a compliance certification or a substitute for review by your own qualified health and safety personnel, who remain responsible for deciding whether any particular document is adequate. See our disclaimer.