I doubt that I am being remotely controversial when I say that no photographer wants to do more paperwork than is absolutely necessary. Time spent filling out forms, dotting the i’s and crossing the t’s feels wrong – especially when your work and your passion is all about the creative process.

The regularity with which I have to complete RAMS (Risk Assessment and Method Statement) forms and declarations has grown. Conversations with colleagues appear to confirm that this is happening right across the photography industry.

During my first spell as freelance photographer (1986-1994) most of my work was editorial and when I did one of the few advertising and corporate jobs that I was offered, the subject of RAMS was never mentioned. Back then nobody asked about public liabilities insurance either.

Fast forward to my second (and current) spell as a freelancer (2008 onwards). I’ve had to do dozens of them. This could be explained by the relatively high percentage of my work being corporate compared to editorial but, I believe, that it has a lot more to do with the seriousness with which corporates take their responsibility for health and safety and the relative clarity of the UK and European legislation enacted between the two spells. The arrival of COVID-19 served to increase and accelerate the degree of caution involved when planning anything. Times have changed and we just have to accept that the need to prove that we have thought about and tried to reduce all forms of unnecessary risk is here to stay.

I can clearly remember the first request for a RAMS. It was only a few weeks after I had returned to freelancing and the client for whom I was working asked me, quite casually, if I could complete one. I confessed that this wasn’t something that I was used to so they gave me the name and number of their senior H&S Manager and I called him. He couldn’t have been more helpful; a twenty minute telephone interview followed, during which he asked me questions and typed away noisily. At the end of the call he emailed me the paperwork all completed for me to sign and return. From that point on every time I worked for that client I had to submit an edited version of that original and all was right with the world.

Since that day in 2008, and on pretty much every occasion I have ever had to submit a risk assessment to whichever client required one, I have used a version of their template and only once have I had my document questioned regarding its suitability. That was during the tentative period immediately after the first lockdown in 2020 and I have since added a section on health and vaccinations. I get questions; only a few weeks ago I was asked about the safety of the Lithium-Ion batteries that I use. I was able to point them towards the safety certificates that Elinchrom provide for theirs and to point out how tiny the Canon camera ones are and the fact that I would observe the IATA rules about keeping them with me at all times.

So what is a RAMS?

I know what is involved but to explain it here I did a bit of web research and found dozens of explanations but this one does the job pretty well:

Employers are required by law to protect their employees, and others, from harm. Under the Management of Health and Safety at Work Regulations 1999, the minimum they must do is:

• Take action to eliminate the hazard, or if this isn’t possible, control the risk
• Identify what could cause injury or illness in their business (hazards)
• Decide how likely it is that someone could be harmed and how seriously (the risk)

A second explanation helps to understand this a bit better:

Risk assessment determines possible mishaps, their likelihood and consequences, and the tolerances for such events. The results of this process may be expressed in a quantitative or qualitative fashion. Risk assessment is an inherent part of a broader risk management strategy to help reduce any potential risk-related consequences.

More precisely, risk assessment identifies and analyses potential (future) events that may negatively impact individuals, assets, and/or the environment (i.e. hazard analysis). It also makes judgments “on the tolerability of the risk on the basis of a risk analysis” while considering influencing factors (i.e. risk evaluation).

My summary of a risk assessment is that you list absolutely everything that could go wrong and what you are going to do to reduce the chances as far as you can. The method statement element of RAMS simply outlines what you are going to do and how your actions either eliminate or minimise the identified risks so that they are in balance with the expected outcomes that you are contracted to deliver. Where there is a risk it has to be properly mitigated and in proportion to the beneficial outcome of taking those risks. Swinging from a chandelier in order to get a general view of a nondescript room just won’t cut it.

This is where I believe an important difference between corporate and editorial photography lies. Most of the time you are shooting corporate work you are, essentially, a sub-contractor working for the employer and they feel that they have an obligation to make sure that you don’t present them with any unnecessary risk whilst you are working with and for them. Editorially you are a third party visitor not directly under their control and therefore their need to be accountable for your actions is somewhat reduced.

Interestingly the UK Government’s Health and Safety Executive publishes guidance about whether various sections of Health & Safety law applies to you. Under the heading “photographer” it mentions an example of a social photographer whose clients may visit their premises and concludes that the law does not apply. This is a bit misleading because when you are actually working as a photographer with camera in hand and away from your base (which in my case is 100% of the time) you can pose a risk to others: they can trip over cables, you can drop equipment on them from height if you are shooting from above their heads, you can plug electrical equipment into their mains and cause damage if your kit is faulty and you can pass on an illness or infection. The list goes on and that’s why, as painful as it is, we regularly need to complete RAMS.

The Health and Safety Executive offers templates for those who are facing their first RAMS. They are clearly not aimed at photographers so we have to use a bit of common sense and try to imagine what potential harm we can cause by our presence and (potentially) in the publication and distribution of our work.

In order to permanently minimise risks I have done a few things:

• All of my lighting equipment is battery powered which eliminates the chances of damaging electrical circuits in the place I am working and drastically reduces the chances of anyone tripping over training electrical cables
• I no longer use synch cables to trigger flash units and try, wherever possible, to use wireless technologies, again drastically reducing or eliminating trip hazards
• All of my battery chargers and power adapters comply with the PAT (portable appliance testing) regulations
• If necessary I travel with my own safety equipment such as a construction helmet, reinforced toe-cap footwear, site gloves and glasses and a high visibility vest. I also have locking wires that can attach my cameras to my person if I am working at height
• I ask clients, wherever possible, to canvas those who will feature in my work as well as those who work in the vicinity where I will be working whether they have any conditions that may be triggered or aggravated by my presence and/or the use of flash
• I have attended various safety related short courses
• My equipment is regularly serviced and even more regularly checked

You can find a heath and safety statement on my website. I update it regularly and, if needed, I point potential clients towards it so that they can see that I take the subject seriously. My first web statement was brought about by a client who insisted that I had published statements on a range of things although, as a sole trader, some them weren’t directly relevant and they agreed that they weren’t necessary. It was another example of a large business, used to dealing with other large businesses, not making allowances for tiny little ones. Since then, I have published and maintained a privacy policy as I believe that this is both necessary and important.

At the end of the day, having a positive attitude towards the reduction and elimination of risk makes doing my job easier. It also serves to increase the clients’ confidence in me and my services. As I said at the start, nobody enjoys this stuff but it has to be done.

UK HSE RAMS TEMPLATES