Health and safety advisor vs doing the paperwork yourself: the trap I watched a decorating firm fall into

I run a scaffolding company, so I spend a lot of time around other trades and around the paperwork that is supposed to keep everyone safe. A while ago I got talking to the owner of a decorating firm about how he handled his health and safety. He was pleased with himself, and on the face of it he had done the responsible thing: he had paid a health and safety consultancy to sort it all out for him. They had written him a health and safety policy and two sets of RAMS - one for indoor work and one for outdoor work. Job done, he thought. He could get on with running the business and leave the safety paperwork to the professionals.

I asked to see them, and my heart sank a little. Because what he had was not protection. It was a false sense of it, which is more dangerous than having nothing at all, because it stops you asking the questions that actually keep people safe. This is the story of that conversation, and of the three things he had badly wrong - because I hear the same assumptions from trades all the time, and every one of them could land a business owner in serious trouble.

One indoor RAMS and one outdoor RAMS, for every job

The first problem was the RAMS themselves. Two documents - one for inside, one for outside - to be used on every single job the firm ever did. I said to him, plainly, that this cannot work, because a RAMS is meant to describe the risks of a specific job on a specific site, and no two jobs are the same.

Think about what "outdoor decorating" actually covers. One day it is painting the ground-floor render of a bungalow off a step ladder. The next it is repainting the fascias and soffits on a three-storey Victorian terrace, working at height, over a public footpath, next to overhead power cables, in whatever wind the day throws at you. Are the hazards the same? Of course not. One job needs a note about a step ladder and a cordoned area; the other needs a proper working-at-height assessment, a decision about ladders versus a scaffold or a tower, an exclusion zone below, a check on the wind forecast, and a hard think about those overhead cables. A single "outdoor RAMS" that is meant to cover both is, by definition, too generic to be any use on either. It names none of the real hazards of the actual job, because it cannot - it was written to be vague enough to apply to everything.

Indoor work is no different. Stripping old paint that might contain lead in a 1950s house is a different job, with different controls, from rolling emulsion in a new-build. Using solvent-based products in a poorly ventilated stairwell is a different job again, and one that needs a COSHH assessment the generic RAMS did not mention. "Indoor" is not a risk profile. It is just a place.

Why generic RAMS are not just weak - they are non-compliant

This is the part most people do not realise. A generic RAMS is not a slightly-worse version of a good one. In the eyes of the law, it may not count as a risk assessment at all. The Management of Health and Safety at Work Regulations 1999 require every employer to make a "suitable and sufficient" assessment of the risks. Those three words do a lot of work. "Suitable and sufficient" means specific to the actual work and the actual workplace - it has to identify the real hazards of the job in front of you and the controls for them. A document deliberately written to be generic enough to apply to every job is the opposite of suitable and sufficient, more or less as a matter of definition. So the firm that thinks its two laminated RAMS have it covered may actually be operating with no valid risk assessment at all, which is a breach in its own right, before anyone has even been hurt.

And if someone is hurt, the generic RAMS becomes evidence against you rather than for you. When an inspector or a court looks at a serious-injury RAMS after the event, the first question is whether the assessment actually addressed the hazard that caused the harm. A generic document that never mentioned the overhead cables, or the wind, or the public below, answers that question in the worst possible way: it shows you had a system, and the system did not think about the thing that went wrong.

The dangerous assumption: "it's the advisor's problem"

When I put some of this to the decorating firm's owner, he gave me the answer I hear most often, and the one that worries me most. He said he was not too bothered, because he had paid a professional to write them - so if anything ever went wrong, it would fall on the health and safety consultant, not on him.

I had to tell him that is simply not how it works, and that believing it is one of the most expensive mistakes a business owner can make. The legal duty to ensure work is carried out safely, and to have suitable and sufficient risk assessments, sits with the employer and with the person in control of the work - under the Health and Safety at Work etc. Act 1974 and the 1999 Regulations. That duty is yours. You cannot sign it away by paying someone to write a document. Hiring a competent person to help you is sensible, and the Regulations even expect you to have access to competent advice - but the help is help with discharging your duty. It does not transfer the duty. When the HSE investigates an accident, it is the company and its directors in the frame, not the consultant who emailed over a template two years earlier.

Could the consultant ever be liable? In civil law, possibly - if you could show they gave negligent advice and that you relied on it, you might have a professional negligence claim against them. But that is a separate, slow, uncertain fight, and it does not make your statutory liability disappear. It does not stop the prosecution, the fine, or the sleepless nights. The idea that the advisor is a lightning rod who absorbs all the risk is a comfortable fiction, and comfortable fictions are exactly what get people hurt and businesses prosecuted.

The signatures nobody was collecting

There was a third problem, and it is one I see constantly. The RAMS were never signed. They sat in a folder in the van and in an inbox, and the lads who actually did the work had never read them, never been briefed on them, and certainly never put their name to them.

A RAMS is not a document you write and file. It is a document you use - you brief the people doing the work on the hazards and the method, and they sign to say they have understood it. That signature is the evidence. It is how you show, after the fact, that the people on site actually knew what the risks were and how they were supposed to control them. An unsigned RAMS proves nothing except that a document existed somewhere. If something goes wrong and you cannot show the operative was briefed and signed on, you have a piece of paper, not a defence. The consultancy that wrote the two RAMS had said nothing about any of this, because their job, as they saw it, ended when the document was delivered.

To be fair: where a good advisor genuinely earns their money

I am not saying health and safety advisors are worthless - that would be as lazy as the generic RAMS. A good advisor is genuinely valuable in the right situation. If you are doing complex, high-hazard work - demolition, asbestos, confined spaces, major structural jobs - you want real expertise, and you should pay for it. If you need someone to act as your competent person, to help you build a proper management system, to represent you at a tribunal, or to audit a large operation, a good consultant is worth every penny. Expertise applied to genuinely difficult problems is money well spent.

The problem is not advisors. The problem is using an advisor as a substitute for thinking, on routine work that changes from job to job, and treating the paperwork they hand over as a shield that makes the responsibility someone else's. That is not what you are buying, and it is not what protects you. For the day-to-day RAMS of a decorating firm, or a roofer, or a scaffolder, what you actually need is a suitable and sufficient assessment of each job, briefed and signed - and that is something you are far better placed to produce than a consultant who has never seen the site.

The £2,000 question

Here is the part that really bothered me about my decorator friend's setup. He was paying a substantial annual retainer - the kind of figure, often a couple of thousand pounds a year or more, that these arrangements typically cost - for a policy and two generic documents that, as we have seen, may not even be compliant and certainly were not being used properly. He was paying good money for the feeling of being covered, without actually being covered.

So ask what the two thousand pounds is really buying. If it is genuine expertise on genuinely complex work, fine. But if it is a policy off a template and a couple of one-size-fits-all RAMS that get laminated and forgotten, you are paying a premium for a false sense of security - and still carrying every bit of the legal responsibility yourself. That is the worst of both worlds: the cost of outsourcing, and the risk of doing nothing.

See it in Complys

Answer a few questions, get a complete RAMS

Complys asks the right questions for your trade and project, then drafts a full Risk Assessment and Method Statement around your answers - proper RAMS, not generic templates, with live UK legislation cited. Start free: 90-day trial, 150 credits (around 13 full RAMS), no card needed.

Build your RAMS free for 90 days →

Doing the paperwork yourself, properly

When people hear "do it yourself" they picture sitting down with a blank document and no idea where to start, which is why they outsource in the first place. But that is a false choice. Doing it yourself does not mean writing RAMS from scratch on a wet Sunday. It means using something that produces a proper, site-specific RAMS for the actual job in front of you, quickly, and captures the sign-off - so you keep the responsibility where the law puts it anyway, but you can actually meet it, on every job, without a retainer.

The right tool asks you about this job - the trade, the site, the specific hazards, working at height, the substances involved - and builds a RAMS around your answers, with the real hazards named and the controls that match. It is not generic, because it is built from the details of the actual job. It cites the relevant legislation. It lets you brief your team and capture their signatures, so you have the evidence that matters. And it keeps every RAMS on record, so when a principal contractor or an inspector asks, you can produce the one for that job, signed, in seconds. That is what compliance actually looks like - not two laminated documents and a hope that it is someone else's problem.

The honest position is this: the responsibility is always going to be yours, whether you pay an advisor or not. Nothing changes that. So the real question is not "who can I make responsible?" but "how do I meet a responsibility I cannot give away, on every job, without it taking over my life or my budget?" Generic paperwork from an advisor does not answer that. Producing proper site-specific RAMS yourself, easily, does.

Where Complys fits

This is exactly why we built the Complys RAMS builder. You answer a few questions about the job, and it generates a complete, site-specific risk assessment and method statement - the real hazards of that job, the right controls, the relevant UK legislation - in minutes, not the hours it takes to write one properly by hand. You brief your team and capture their sign-off, so the RAMS is signed and defensible, not sitting unread in a van. You can build a COSHH assessment for the substances the job involves at the same time. And every document is kept on record, current, ready to produce. It costs a fraction of a health and safety consultancy's annual retainer, and unlike two generic templates it gives you a proper RAMS for every job, because every job gets its own.

To be clear about what it is and is not: Complys is a tool that helps you produce and evidence compliant documents and meet a duty that is, and always will be, yours. It does not remove your legal responsibility - nothing can, and anyone who tells you otherwise is selling you the same false comfort my decorator friend had bought. For genuinely complex or high-hazard work, get proper expert input; that is what advisors are for. But for the everyday RAMS that most trades need, on jobs that change every time, doing it properly yourself is not just cheaper than a generic-paperwork retainer - it is safer, because it is actually specific to the work, actually signed, and actually used.