Work at Height Regulations for roof work: the owner's checklist
Updated 23 October 2026 · SEO Dons Editorial
Check your re-roof against the rules ↓
What is the legal definition of working at height?
Regulation 2 defines work at height as work in any place, including a place at or below ground level, and getting to or from such a place while at work (except by a staircase in a permanent workplace), where a person could fall a distance liable to cause personal injury if the measures required by the Regulations were not taken. There is no minimum height. HSE's FAQ says you are working at height if you could fall from an edge, through an opening or through a fragile surface. It excludes a slip or trip on the level and walking up or down a permanent staircase. HSE's brief guide to the Regulations, INDG401, names falls from ladders and through fragile roofs as common causes.
On a commercial roof that covers the ladder or hatch used to get up, the walk across to a rooflight or plant, and the work itself.
Do the Regulations apply to the building owner?
They apply to employers and to those in control. HSE says: "If you are an employer or you control work at height (for example facilities managers or building owners who may contract others to work at height) the Regulations apply to you." Regulation 3 sets the limit: the employer's requirements apply to work by an employee of his, or by any other person under his control, to the extent of his control.
An owner can therefore carry three sets of duties at once.
- Work at Height Regulations 2005. For its own staff, and for contractors to the extent it controls their work. This page.
- CDM 2015. The client duties for any roof project, set out in the CDM 2015 guide.
- Health and safety and occupier duties. General duties to people on the premises, covered in the guide to whether an owner is liable when a contractor is hurt.
What order must roof work controls follow?
Regulations 6 and 7 set a hierarchy. Avoid work at height, then prevent falls, then minimise the distance and consequences of any fall that remains. Within each step, collective protection comes before personal protection.
| Step | What the rule says | HSE's roof-relevant example |
|---|---|---|
| Avoid | Work is not carried out at height where it is reasonably practicable to do it safely otherwise than at height | HSG33 suggests a telescopic pole with a camera attachment for roof inspections |
| Prevent | Suitable and sufficient measures to prevent any person falling a distance liable to cause injury | An existing place of work that is already safe, such as a non-fragile roof with a permanent perimeter guardrail |
| Minimise | Where a risk of falling remains, equipment to minimise the distance and consequences | Safety nets and soft landing systems installed close to the level of the work |
The employer doing the work chooses the equipment under regulation 7, giving collective measures priority over personal ones. The owner's part is to make sure that choice has been made, on paper, before anyone is on the roof.
What is a safe system of work on a roof?
It is the planned, supervised and competent way of doing the job. HSE says work must be properly planned, supervised and carried out by competent people with the skills, knowledge and experience to do the job. Regulations 4 and 5 add three requirements that bear directly on an owner's decisions: planning includes emergencies and rescue, work happens only when the weather does not jeopardise health or safety, and regulation 5 says nobody may plan, organise or supervise the work unless competent to do so.
HSE describes a method statement as the common way to manage roof work and communicate the precautions. HSG33 says it should identify working positions and access routes and show, among other things:
- how falls are to be prevented or, where that is not possible, minimised;
- how changes in the work will be dealt with without affecting safe working;
- who will check that the system is effectively controlling risk.
What should the owner do before roof work starts?
- Ask whether anyone needs to be on the roof at all. Remote inspection comes first in the hierarchy.
- Appoint competent people. The ACR says it is essential that anyone wishing to have roof work carried out ensures the company or persons selected are competent, and that in many cases this is a legal requirement. The SSIP, CHAS and Constructionline guide explains how schemes are used to check this.
- Treat the roof as fragile, and pass on what you know. HSE's position is that all roofs, once fixed, should be treated as fragile until a competent person has confirmed that they are non-fragile. Fragile areas, asbestos, access routes and permit arrangements go into the pre-construction information, and the fragile roofs guide lists what to include.
- Ask for the risk assessment and method statement first. HSG33 says a competent person should carry out a risk assessment before work starts on a roof, scaled to the work.
- Do not squeeze the programme. HSG33 warns that unrealistic refurbishment programmes can put undue pressure on the people doing the work.
- Agree the weather rule. Decide in advance who can stop the job when conditions turn, so nobody has to argue it on the roof.
- Agree rescue. HSG33 says the method of rescue should be proportionate to the risk and that you should not rely on the emergency services.
- Co-ordinate trades. Where two or more employers share a workplace, the Management Regulations require each to co-operate and co-ordinate. A roofer, a plant engineer and a cable installer on the same roof are a typical example.
How do you stop your own staff taking a quick look?
Treat every visit as roof work. HSE says all work on roofs is highly dangerous, even if a job only takes a few minutes. For fragile surfaces it asks for effective precautions no matter how short the duration, whether the work is construction, maintenance, repair, cleaning or demolition. The ACR lists an inspection on the roof, or any other work lasting under a day, as minor roof work that still needs planning.
- Write the rule down: nobody goes on the roof unless authorised, with the authorisation tied to a named task.
- Control the routes. HSG33 says access to permanently fixed ladders should be prevented whenever access is not required, for example by blocking or locking them off.
- Give staff an alternative. A leak can be reported from inside, and inspection can use remote methods before anyone climbs.
- Brief visiting trades. A maintenance engineer who goes up to plant is doing work at height too, so ask for their method statement.
For a roof job you want to plan, you can send an enquiry through the form on this site, and the commercial flat roof repair guide sets out the safety points a repair should cover.
Sources
- Work at Height Regulations 2005: regulation 2, 3, 4, 5, 6 and 7, legislation.gov.uk, checked 22 October 2026
- Management of Health and Safety at Work Regulations 1999, regulation 11, legislation.gov.uk, checked 22 October 2026
- HSE: The law, FAQs, Introduction, Step-by-step guide, Roof work and Fragile surfaces, checked 22 October 2026
- HSE: Health and safety in roof work (HSG33), PDF, and Working at height: a brief guide (INDG401), checked 22 October 2026
- Advisory Committee for Roofsafety: IS1, Clients guide and IS3, Planning minor roof works, checked 22 October 2026
Common questions
Is a risk assessment needed before a roof inspection?
The Regulations tell the employer to take account of a risk assessment when choosing measures, and HSE's step-by-step approach starts by assessing the height of the task, how long and how often it is done, and the condition of the surface. HSG33 says a competent person should carry out a risk assessment before work starts on a roof, scaled to the work. A short inspection needs a short assessment, not none.
Can a ladder be used to reach a flat roof?
HSE says ladders can be used for work at height when a risk assessment shows that equipment giving a higher level of fall protection is not justified by the low risk and short duration of use. As a guide, it recommends considering alternative equipment if the task means staying on a leaning ladder or stepladder for more than 30 minutes at a time. The ladder is only the way up. Once on the roof, the fragile surface and weather rules still apply.
What if the weather turns during roof work?
Regulation 4 says work at height is carried out only when the weather conditions do not jeopardise the health or safety of persons involved in the work. HSG33 adds that a roof should always be inspected before work starts to see whether conditions have changed. The owner's contribution is to agree beforehand who can stop the job, and to accept the delay.
What records should an owner keep after roof work?
Keep the risk assessment and method statement, any permits and inspection notes, and the health and safety file where CDM 2015 calls for one. HSE says the file should be revised as necessary and made available to anyone who needs it for subsequent work at the site, which makes it the natural home for fragile areas, asbestos entries and any protection left in place.
Related guides
Check your re-roof against the rules
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