Working at Height Safety for Roofers: UK Compliance Guide 2026

The Work at Height Regulations 2005 apply to all work carried out at height where a person could fall and be injured. They apply regardless of whether the work is above or below ground level, and regardless of the duration of the task. For roofers, they apply to virtually every job.

The key duties under the Regulations are:

• Ensure all work at height is properly planned, appropriately supervised, and carried out in as safe a way as is reasonably practicable
• Ensure those involved in work at height are competent — either trained and qualified, or supervised by someone who is
• Assess and manage the risks from work at height
• Select appropriate work equipment — scaffolding, mobile elevating work platforms (MEWPs), ladders — based on a risk assessment, not habit or convenience
• Protect against falling objects — tools, tiles, or debris that could injure people below

The Regulations do not ban ladders or require scaffolding for all jobs. However, ladders must be the right choice for the specific task based on a documented risk assessment — not simply the default because it is quicker to set up. This distinction is at the heart of most HSE enforcement action against roofing contractors.

The HSE enforces these Regulations actively in roofing. Improvement Notices and Prohibition Notices are issued regularly; the HSE's Roofwork programme has resulted in significant fines and, in fatal cases, prosecution under the Health and Safety at Work Act 1974 and the Corporate Manslaughter and Corporate Homicide Act 2007.

The Regulations establish a hierarchy of controls for work at height — a legal priority order that employers must follow. You must consider higher controls first before moving to lower ones. This is not guidance; it is a legal requirement.

1. Avoid work at height where possible

If the task can be done from ground level — for example, using a long-handled brush to clear debris from gutters instead of climbing — that option must be used. In roofing, this first step often cannot be applied, but it must be genuinely considered.

2. Use work equipment or other measures to prevent falls

Where work at height cannot be avoided, you must use equipment that prevents falls. Scaffolding provides a collective, physical barrier. A properly erected working platform with guardrails, mid-rails, and toe boards prevents the fall itself rather than merely reducing the consequences. Scaffolding is the preferred solution for most re-roofing and significant repair jobs.

3. If falls cannot be prevented, use measures to minimise the distance and consequences

Where collective prevention (scaffolding) cannot reasonably be provided for the specific task — for example, a brief inspection or measurement on a simple pitched roof — personal protective equipment such as a safety harness with a short lanyard or a fall arrest system may be appropriate. The key principle is that personal protective equipment is the last resort in the hierarchy, not the first response.

Common mistake: Many roofing businesses issue harnesses to workers and consider the hierarchy addressed. This is wrong. A harness is at the bottom of the hierarchy — it minimises the distance of a fall after it occurs. If scaffolding is reasonably practicable and has been chosen not for safety reasons but to save money or time, this is a breach of the Regulations regardless of whether harnesses are worn.

The choice of access equipment must be based on a risk assessment and the nature of the specific task — not habit or economics alone.

Scaffolding: The correct choice for most re-roofing jobs and significant repairs. A properly erected scaffold with a working platform at eaves level, with guardrails, mid-rails, and toe boards all around the building, provides collective fall prevention that protects all workers on the site. Scaffolding must be designed, erected, inspected, and dismantled by trained, competent scaffolders. Where the roof has fragile surfaces (old skylights, corroded sheets), additional protection such as roof boards or crawling boards must be provided on the scaffold or working platform.

Mobile elevating work platforms (MEWPs): Scissor lifts and cherry pickers (boom lifts) are appropriate for tasks requiring frequent repositioning at height on flat or commercial roofs, for gutter work, and for jobs where erecting a full scaffold would be disproportionate. MEWP operators must be trained and competent — IPAF (International Powered Access Federation) training is the recognised standard. MEWPs must not be used in wind conditions exceeding their rated limit, and ground conditions must be assessed before positioning.

Ladders: Ladders are appropriate for low-risk, short-duration tasks or as a means of access to a scaffold rather than as a working platform. The Regulations do not prohibit ladder use but require that ladders are only used where a risk assessment confirms they are appropriate — the task is short-duration, there is a secure fixing point, the pitch and surface allow safe use, and three points of contact can be maintained during the work. Using a ladder to carry out extended tile work or ridge repairs is not appropriate under the Regulations.

Edge protection requirements: Any working platform at height must have guardrails (at least 950mm high), an intermediate rail (positioned to prevent a person passing through or under the guardrail), and toe boards (at least 150mm high). These dimensions are specified in the Regulations and in BS EN 12811. Improvised or missing edge protection is one of the most common issues found on HSE roofing site visits.

For domestic re-roofing on terraced properties where full perimeter scaffold is not accessible, alternative edge protection must be provided — for example, a fixed parapet or working platform with front and side guardrails even if the rear of the scaffold is against the party wall.

Fragile roof surfaces: Fragile roofs present a significant risk because a worker can fall through the surface rather than off the edge. Fragile surfaces in roofing include:

• Fibre cement (asbestos-cement or non-asbestos) corrugated sheets — common on older industrial buildings
• Older glass rooflights and obscured polycarbonate panels in flat roofs
• Lead-covered roofs with underlying rotten timber
• Old bituminous felt flat roofs that have blistered, split, or become saturated

HSE guidance (HSG33 — Health and Safety in Roofwork) requires that fragile surfaces are identified before work begins and that measures are put in place to prevent a fall through the surface — typically crawling boards, roof ladders, or additional working platforms spanning between supporting structural elements.

Every roofing job requires a written risk assessment before work begins. This is a legal requirement under both the Work at Height Regulations and the Management of Health and Safety at Work Regulations 1999. For businesses with 5 or more employees, the risk assessment must be written down and retained.

A roofing risk assessment must address:

• The height involved and the specific fall hazards — roof edge, roof lights, internal voids
• The condition of the roof and access surfaces
• The access equipment selected and why it is appropriate for the task
• The edge protection or collective fall prevention measures in place
• The competence of the workers involved — qualifications, training, experience
• Environmental factors — weather forecast, wind, expected hours of work
• Overhead hazards — power lines, overhead cables that could be struck by a crane or scaffold
• Third-party risks — pedestrian access, parked vehicles, adjacent properties

The risk assessment must be reviewed and updated if circumstances change during the job — for example, if the condition of the roof turns out to be different from what was expected before stripping began, or if weather conditions deteriorate significantly.

Generic risk assessments are not adequate. The assessment must be specific to the site, the job, and the conditions present on the day. Using a template is fine as a starting structure, but the specific hazards of each job must be filled in meaningfully.

The HSE's roofwork enforcement programme targets the highest-risk scenarios in the trade. Understanding what inspectors look for helps roofing businesses ensure compliance and avoid prohibition notices that stop work immediately.

Priority inspection triggers:

• Workers visible on a roof with no edge protection or with clearly inadequate arrangements
• Scaffolding with missing guardrails, boards, or toe boards
• Workers on fragile roofs without crawling boards or spanning equipment
• Ladders used as working platforms for extended work rather than access only
• No evidence of a risk assessment or method statement on site

Common enforcement outcomes:

• Improvement Notice: Requires the business to fix a specific safety issue within a set timeframe
• Prohibition Notice: Stops work immediately — the activity cannot resume until the specified conditions are met. A Prohibition Notice on a roofing job typically means significant delay and financial loss
• Fee for Intervention (FFI): HSE charges inspectors' time (currently £163/hour) when they find a material breach. A day of follow-up after a site visit can generate a bill of several hundred to a few thousand pounds
• Prosecution: Serious breaches, especially those causing or nearly causing injury, are prosecuted. Fines under the Health and Safety at Work Act can be unlimited for Crown Court cases; smaller businesses frequently receive fines of £20,000–£100,000 and the reputational damage of a conviction

The single most effective compliance investment is a structured safety management system: standard risk assessment and method statement (RAMS) templates for each type of roofing job, a regular scaffold inspection regime (weekly and after any incident or severe weather), competency records for all workers, and a culture where stopping work for safety concerns is normal and supported.