A recent HSE prosecution has demonstrated why an established risk assessment cannot simply be stretched to cover a new task, altered method or different use of work equipment. Employers must review risk assessments when they may no longer be valid or when a significant change affects the work. That does not always mean starting again, but it does mean checking whether the existing controls still match reality.
A fatal incident followed a change in working practice
In July 2026, the Health and Safety Executive reported a prosecution after a worker died following a fall from a mobile loading ramp during a newly introduced activity. HSE found that the work had not been properly assessed, the manufacturer required handrails for pedestrian use, and alternatives that could have avoided work at height had not been adequately considered.
The important point for construction and industrial employers is broader than the equipment involved. When the planned method changes, the assumptions behind the original risk assessment can change with it.
When must a risk assessment be reviewed?
Under Regulation 3 of the Management of Health and Safety at Work Regulations 1999, employers must make a suitable and sufficient assessment of risk. That assessment must be reviewed where there is reason to suspect it is no longer valid or where there has been a significant change in the matters to which it relates.
A review may result in a small amendment, a revised method statement or a completely new assessment. The scale of the paperwork should be proportionate to the scale of the change and the risk created by it.
What counts as a significant change?
The test is not simply whether the change is expensive or permanent. A relatively small operational change can materially alter the hazard profile. Examples include:
- introducing new plant, attachments or work equipment;
- using existing equipment for a different purpose;
- changing the work sequence or access arrangements;
- moving an activity to another part of the site;
- introducing pedestrian access into a plant area;
- changing loads, materials or substances;
- starting lone, night or out-of-hours working;
- using less experienced workers or a different subcontractor;
- departing from manufacturer instructions; or
- responding to changed ground, weather or temporary works conditions.
HSE’s workplace transport guidance similarly advises employers to assess risks before significant changes and to keep assessments aligned with the way work is actually carried out.
Does every change require completely new RAMS?
No. A minor variation that does not materially change the hazards or controls may be dealt with through a proportionate review and briefing. However, foreseeable change should not be pushed into a vague instruction to “dynamic risk assess” the job.
A formal RAMS review is particularly important where the change affects work at height, lifting operations, temporary works, vehicle and pedestrian interaction, excavation support, hazardous substances, isolation, guarding, emergency arrangements or the competence and supervision required.
If a revised method creates a new technical question, the right response may be to obtain specialist input from a designer, engineer, appointed person or other competent professional before work resumes.
Manufacturer instructions matter
The Provision and Use of Work Equipment Regulations 1998 require work equipment to be suitable for its intended use. Manufacturer instructions are therefore important evidence of the conditions under which equipment has been designed and tested to operate safely.
Where a business deliberately departs from those instructions, it should have competent technical justification for the alternative arrangement. Convenience, programme pressure or “we have always done it this way” are not robust reasons.
What should you do now?
- Identify work activities that have changed since the RAMS were approved.
- Check whether the existing assessment still describes the real work.
- Review equipment suitability and manufacturer requirements.
- Apply the hierarchy of control to any new or increased risk.
- Confirm whether additional competence, supervision or specialist advice is needed.
- Update the method before implementing significant changes.
- Brief everyone affected and check understanding.
- Observe the revised method during its first use.
- Update permanent documents if the change becomes established practice.
Our professional view
Many serious incidents happen not because an organisation has no safety arrangements, but because an apparently small change bypasses them. A different attachment, temporary access route, revised sequence or unfamiliar item of equipment can invalidate assumptions that were perfectly reasonable when the RAMS were written.
A practical management-of-change process does not need to be bureaucratic. HSE’s Plan, Do, Check, Act approach provides a useful framework: identify the change, understand the risk, implement the right controls, communicate them and then verify that the revised system works.
Businesses that need an independent review of changed working methods can use our health and safety consultancy service for RAMS reviews, risk assessments and site-based support.