Common Non-Compliances Hiding in Plain Sight in Risk Assessments
Jan 14, 2026
Risk assessments are meant to be living documents that actively prevent harm. In reality, many pass audits while quietly failing to meet legal or best-practice requirements. The most dangerous non-compliances are rarely dramatic - they’re subtle, familiar, and often repeated across organisations.
Here are the most common ones that hide in plain sight.
1. Generic Hazards With No Real Context
What it looks like
“Slips, trips and falls”
“Manual handling”
“Working at height”
Why it’s non-compliant. Regulators expect hazards to be specific to the task, environment, and people involved. Generic hazards fail to demonstrate that the risks have been properly identified or evaluated. UK guidance is clear that risk assessments must be “suitable and sufficient” - generic wording often isn’t.
Common miss. The same risk assessment reused across sites with different layouts, equipment, or conditions.
2. Missing or Inadequate Risk Evaluation
What it looks like
No severity or likelihood scoring
Risk rating filled in but never explained
All risks marked “low” by default
Why it’s non-compliant. A risk assessment without a defensible evaluation process cannot justify control measures. Many standards explicitly require a structured method for assessing risk levels. ISO 45001 requires organisations to establish criteria for risk assessment and apply them consistently.
Common miss. Scores are copied forward from old documents without reassessment.
3. Control Measures That Don’t Follow the Hierarchy of Control
What it looks like
PPE listed as the primary control
Training used instead of engineering controls
“Be careful” or “Follow procedure” as a control
Why it’s non-compliant. The hierarchy of control is not optional guidance - it’s embedded in UK and international safety expectations. Relying on PPE or administrative controls when elimination or engineering controls are feasible is a frequent audit finding.
Common miss. No explanation of why higher-level controls were not reasonably practicable.
4. No Clear Link Between Risk and Control
What it looks like
Long lists of controls with no mapping to hazards
Controls copied verbatim between unrelated risks
Why it’s non-compliant. Assessors expect to see a logical relationship: hazard → risk → control. When that link is unclear, it suggests the assessment was assembled, not analysed. This is a common failure highlighted during inspections following incidents.
Common miss. Controls that mitigate a different risk than the one listed.
5. Responsibilities Are Vague or Missing
What it looks like
“Management to ensure…”
“Employees must…”
No named role or owner
Why it’s non-compliant. Risk controls without ownership are rarely implemented or maintained. ISO 45001 explicitly requires assignment of roles, responsibilities, and authorities.
Common miss. Responsibility assigned at organisational level, not task level.
6. Review Dates That Never Trigger Action
What it looks like
Review date set years in the future
“Review annually” with no last review recorded
No review after changes or incidents
Why it’s non-compliant. Risk assessments must be reviewed when circumstances change - not just on a calendar cycle. UK law requires review following significant changes or after an incident.
Common miss. Out-of-date assessments still in use after process or equipment changes.
7. Vulnerable Groups Not Considered
What it looks like
No mention of young workers, new starters, pregnant workers, or contractors
“All staff” assumed to be equally exposed
Why it’s non-compliant. Specific groups often face different levels of risk, and UK regulations require these differences to be assessed explicitly.
Common miss. Contractors covered by generic statements but no task-specific assessment.
Why These Issues Persist
These non-compliances usually exist because:
Documents are copied and edited instead of reassessed
Time pressure prioritises completion over quality
Reviews focus on presence, not substance
They’re rarely intentional - but they’re still enforceable.
A Practical Takeaway
If you want to stress-test a risk assessment quickly, ask:
Could someone unfamiliar with the task understand the real risks?
Can each control be clearly justified?
Is there evidence this document has been actively reviewed?
If the answer is “no” to any of these, there’s likely a hidden non-compliance.
