The short answer: the contractor carrying out the work produces the RAMS for that work. If you are the subcontractor doing the roofing, you write the roofing RAMS. Nobody else can, because nobody else knows your method, your plant or your people.
The longer answer matters, because "RAMS" is not a term the Construction (Design and Management) Regulations 2015 use at all. The document is the industry's way of discharging two separate legal duties at once, and knowing which duty sits where is what settles the arguments about who produces what.
Where the duty actually comes from
The risk assessment half comes from regulation 3 of the Management of Health and Safety at Work Regulations 1999: every employer must make a suitable and sufficient assessment of the risks to employees and to others affected by the work, and record the significant findings where there are five or more employees. That duty attaches to the employer of the people doing the work. It cannot be delegated up the chain.
The method statement half comes from CDM 2015 regulation 15, which requires a contractor to plan, manage and monitor construction work so it is carried out without risks to health and safety so far as reasonably practicable. The method statement is how that planning is written down and communicated.
Put together: your employer duty produces the risk assessment, your contractor duty produces the method statement, and the combined document is what gets submitted. CDM 2015 explained walks through the full set of duty holders and what each one owes.
The contractor
The contractor writes it, and someone competent in that work signs it off. Competence under CDM 2015 is framed in regulation 8 as skills, knowledge, training and experience, and for an organisation the organisational capability to match. In practice that means the author understands the trade, not just the template — a QS or an office administrator producing a scaffolding RAMS from a previous document is exactly the arrangement that produces documents nobody can defend.
The contractor is also responsible for briefing it to the operatives, for supervising the work against it, and for revising it when things change. Producing the document is the smallest part of the duty.
The principal contractor
On projects with more than one contractor, the principal contractor plans, manages and monitors the construction phase and coordinates the work of all contractors. That includes reviewing the RAMS submitted to them, checking that the arrangements are compatible with the construction phase plan and with what other trades are doing, and refusing work that is not adequately planned.
What the principal contractor must not do is write your RAMS for you. Beyond the practical problem — they do not know your method — it breaks the accountability that makes the document worth anything. A RAMS the principal contractor wrote and you signed is a document neither of you can properly stand behind. They can, and should, tell you their format requirements, give you the relevant pre-construction information and site rules, and be specific about what was inadequate when they reject one.
They also produce the construction phase plan, which is a different document at a different altitude. Construction phase plan versus RAMS sets out the boundary, because submitting one when the other was asked for is a common and entirely avoidable rejection.
The client
The client — the organisation the project is being carried out for — must make suitable arrangements for managing the project, ensure those arrangements are maintained, provide pre-construction information to every designer and contractor, and appoint the principal designer and principal contractor in writing where there is more than one contractor. On domestic projects the client duties normally pass to the contractor or principal contractor.
Clients do not write RAMS. But a client who fails to provide pre-construction information has made it impossible for you to write a good one, and that failure is theirs. Ask in writing and keep the request.
The principal designer and designers
The principal designer plans, manages and monitors the pre-construction phase and coordinates health and safety in design, eliminating foreseeable risks where possible and reducing what cannot be eliminated. Designers have the same duty for their own designs. They do not write RAMS either — but the residual risks they identify and pass on are meant to feed directly into yours, and the design information you receive is one of the inputs to your hazard register.
What about self-employed workers and labour-only gangs?
CDM 2015 applies duties to a self-employed person carrying out construction work in the same way as to a contractor with employees. A self-employed bricklayer working alone on a commercial project still has to plan the work and, where the principal contractor requires it, submit a RAMS. Where a labour-only gang works under your direction, you are the one managing the work and the RAMS is yours.
Can you outsource the writing?
You can use a health and safety consultant, and many contractors do. What you cannot outsource is the responsibility: the document is still yours, it must still describe your actual method, and your competent person must still review and approve it. A consultant working from a phone call and a template will produce something generic, and the gap between the document and the site remains your problem.
The same applies to software, including ours. A tool can check the document against a fixed structure and flag gaps consistently — which documents Valify can review sets out what that covers — but it does not know your site and it does not carry your duty. Every decision about whether a method is safe stays with the competent person who signs it.
The practical summary
- Contractor: writes, briefs, supervises and revises the RAMS for its own work.
- Principal contractor: reviews, coordinates, sets the format, provides site information, refuses inadequate submissions.
- Client: provides pre-construction information, makes suitable arrangements, appoints in writing.
- Principal designer and designers: eliminate and reduce risk in design, pass residual risks on.
- Everybody: cooperates with the others, which regulation 8 requires explicitly.
If you are ever unsure who should be producing a particular document, ask who is managing the work it describes. That is nearly always the answer.
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.