The Painting and Decorating Association has issued a warning to its members about the quality of risk assessments and method statements (RAMS) submitted by decorating contractors to principal contractors and clients. The trade body says it has observed a growing number of firms submitting documents that fail to meet the required standard for site access and health-and-safety compliance.
RAMS documents—comprising a written risk assessment and a step-by-step method statement—are mandatory for most commercial, industrial and public-sector painting projects in the UK. They must identify hazards, assess the level of risk, detail control measures and outline the sequence of work. Principal contractors and main contractors routinely require RAMS before granting site access, and local authorities or housing associations often audit them as part of framework agreements.
What triggers the association's concern
According to the PDA, a significant proportion of RAMS submitted by small and medium-sized painting firms consist of generic, template-based documents that do not reflect the specific conditions, access constraints or materials of the individual project. Common deficiencies include missing control measures for work at height, inadequate handling instructions for coatings and primers, and vague statements that fail to identify who is responsible for implementing each measure.
The association points out that inadequate RAMS can lead to immediate practical consequences: refusal of site access, termination of contract, exclusion from tender lists, and increased insurance premiums. In more serious cases, the Health and Safety Executive may initiate enforcement action if an incident occurs and the risk assessment is found to be insufficiently detailed or out of date.
Regulatory backdrop and enforcement trends
The Health and Safety at Work etc. Act 1974 places a legal duty on all employers and self-employed persons to assess risks to workers and others who may be affected by their activities. For contractors working on construction sites, the Construction (Design and Management) Regulations 2015 (CDM 2015) make explicit the requirement for written risk assessments and safe systems of work. The HSE's guidance emphasises that risk assessments must be "suitable and sufficient"—a phrase that means they should be specific, proportionate and kept under review.
Recent enforcement statistics from the HSE show that improvement notices and prohibition notices issued to trades working on construction sites increased by 11 per cent year-on-year to March 2025, with inadequate risk documentation cited as a contributing factor in nearly one third of notices. Although painting and decorating work is generally lower-risk than structural trades, falls from height, exposure to solvents in solvent-based coatings and manual handling injuries remain the most frequently reported incidents.
What makes a compliant RAMS document
A compliant RAMS should begin with a project-specific risk assessment that lists every significant hazard—ladder work, mobile tower scaffolds, dust from sanding, vapour from spray application—and assigns a risk rating before and after control measures. Each hazard should be matched to a control: for example, edge protection and harness anchorage for work above two metres, extraction ventilation for spray booths, and appropriate respiratory protective equipment when applying solvent-rich products.
The method statement should then describe the sequence of work in sufficient detail that an HSE inspector or site manager can understand how the controls will be implemented. This includes naming the person responsible for each task, specifying the equipment to be used, detailing emergency procedures and setting out how the work area will be segregated or signed. For exterior facade work, the statement should also address weather constraints, public protection and coordination with other trades.
The PDA emphasises that generic templates downloaded from the internet rarely meet this standard. While templates can provide a useful starting point, they must be tailored to reflect site-specific risks, the competence of the operatives, the access equipment available and the coatings or surface-preparation methods to be employed.
Insurance and procurement implications
Beyond regulatory compliance, RAMS quality increasingly affects commercial relationships. Insurers underwriting public-liability and employers'-liability policies are paying closer attention to contractors' risk-management processes during renewals. Some insurers now request sample RAMS documents as part of their underwriting assessment, and evidence of poor practice can result in higher premiums or exclusions for certain activities.
In the public procurement arena, framework agreements operated by local councils, housing associations and central-government estates frequently require pre-qualification on health-and-safety capability. Contractors who cannot demonstrate a track record of competent RAMS preparation may be excluded at the selection stage, or marked down during tender evaluation. One London borough council, for example, introduced a requirement in 2025 that all painting contractors on its maintenance framework submit project-specific RAMS within 48 hours of instruction; non-compliance triggers automatic removal from the approved list.
Practical steps for painting firms
The association advises firms to invest in training for estimators and site supervisors so that risk assessments are prepared by individuals who understand both the regulatory requirements and the practicalities of painting work. Several short courses—run by bodies such as the Construction Skills Certification Scheme and industry training providers—cover RAMS writing, CDM duties and site-safety management.
For smaller firms without dedicated health-and-safety staff, engaging a competent consultant to review and update template RAMS for recurring job types can provide a cost-effective foundation. The consultant should work alongside operational staff to ensure the documents reflect real working practices and can be easily adapted for each new project.
Regular internal audits are also recommended. Before submitting RAMS to a client, a second person within the firm should review the document to check that it addresses all activities listed in the scope of work, identifies the specific products and equipment to be used, and includes signed confirmation that operatives have been briefed on the controls. Site records, toolbox talks and photographic evidence of implemented controls can support the RAMS and demonstrate due diligence.
Training resources and sector guidance
The PDA has published a checklist on its member portal to help firms self-assess the adequacy of their RAMS. The checklist covers 22 key elements, including hazard identification, hierarchy of controls, emergency procedures and document version control. The association also offers a paid RAMS-review service, under which experienced health-and-safety advisers examine submitted documents and provide written feedback within five working days.
Trade suppliers, including Dulux UK and Crown Paints, have begun to produce product-specific safety data sheets and application guides that include suggested risk-control measures for their coatings and finishes. These documents can be appended to RAMS or referenced in method statements to demonstrate that the contractor has consulted manufacturer guidance.
Several painting firms have reported that upgrading their RAMS documentation has opened doors to larger contracts and reduced the administrative burden during tender submissions. One contractor in the Midlands noted that a single well-written master RAMS, tailored for each project, cut tender-preparation time by 40 per cent and resulted in zero site-access delays over a 12-month period.
Outlook: regulation and client expectations
Looking ahead, the PDA expects principal contractors and clients to continue tightening pre-qualification criteria around health and safety. The trend toward digital site-management platforms—where RAMS must be uploaded, version-controlled and signed off electronically—is likely to increase transparency and make it harder to recycle outdated or generic documents.
For painting and decorating businesses, robust RAMS are no longer a compliance tick-box but a commercial differentiator. Firms that invest in competent risk assessment, clear method statements and ongoing training are better positioned to win work, avoid enforcement action and protect their workforce. The association's warning serves as a timely reminder that shortcuts in documentation can carry long-term costs far exceeding the effort required to get it right from the outset.
Further guidance on sector-specific compliance and training challenges is available in related industry coverage.
