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Memorial Safety Policy


This version: 11 August 2021


This policy has been produced to set out Gainsborough Town Council’s (the Council) position with regard to memorial safety, the responsibilities of the Council, its contractors, memorial masons and Deed Holders. The policy provides an overview of the actions that will be taken to minimise risk to users of the cemeteries within Gainsborough.

Since Victorian times memorials have been erected at the head of graves as a permanent reminder of those buried within. It is often wrongly assumed that memorials are permanent structures, installed to the highest standards, and will last forever without need for repair.

Unfortunately, this assumption has cost lives in recent years, most of whom have been children, and there have been countless accidents ranging from bruising to severe crush injuries and bone breakages. Local authorities now must tackle years of neglect and in some cases poor workmanship. The memorials do not belong to the council; they remain the property and the responsibility of the Deed Holder to the Exclusive Rights of Burial/Memorial.

Responsibilities Required

The following parties have responsibility for memorial safety within Council managed cemeteries:

The Council has Health and Safety responsibilities to its employees, contractors, and visitors to their cemeteries. The Council has a responsibility to employees (Section 2 of the Health and Safety at Work Act 1974) and a responsibility to visitors (Section 3 of the Health and Safety at Work Act 1974). The Management of Health and Safety at Work Regulations 1999 places a legal duty on the Council to assess the risks from Cemetery structures and work activities and ensure that these risks are controlled.

All monumental masons have the responsibility to work in accordance with the Council’s conditions and specifications for memorials, Gainsborough Town Council are a registered member of the British Register of Accredited Memorial Masons (BRAMM) and the Register of Qualified Memorial Fixers (RQMF) and as such all memorial installations and fixings must conform to BS8415.

The Deed Holder or successor in title of a memorial has the ultimate responsibility to maintain it so as not to present a hazard to themselves, members of the public or Council employees, and as such are therefore responsible and liable for all expenditure incurred to make safe their memorial in the event that their memorial is found to be unsafe or in a dangerous condition. This is not the responsibility of the Council.

Notice of Intent

Prior to any memorials being inspected, reasonable steps will be taken by the Council to inform grave owners, Deed Holders or successors in title, and members of the public, of the intention to inspect memorials and reducing the risk posed by unsafe memorials. Deed holders must inform the Council of a change of address so as they can be contacted if any problems with the memorial/grave plot should occur.

This will involve:

  • Giving advance formal notice on the Gainsborough Town Council website, social media pages etc. of any inspection regime commencing.
  • Publishing details of the methodology on the Council’s website.
  • Placing public notices on the cemetery gates and in prominent locations elsewhere in the cemetery affected by the assessment regime.
  • Where practicable, to notify the owner, Deed Holder, or successor in title.

Memorial Fixing

It is imperative that mistakes from the past are not repeated, and all works to new and repaired memorials are carried out to the industry standard BS8415 by BRAMM or RQMF registered memorial masons.

In order that the industry standards are met it is necessary to regulate both the memorial masons and the methodology of memorial works. The Council understands that the memorial masons are an important partner to the cemetery service, therefore a more formal partnership and safer system of work will be implemented in the form of the BRAMM, RQMF registration scheme.

The BRAMM, RQMF registration scheme is essential in ensuring that all memorial masons and their fixers that carry out any work within Gainsborough Town Council managed Cemeteries are properly trained, insured, and following current industry standards.

Companies or individuals that are not registered to the BRAMM, RQMF scheme will not be permitted to carry out any memorial works in any of the Gainsborough Town Council managed cemeteries.

  • All memorial masons will use the latest national standards laid down by the British Register of Accredited Memorial Masons (BRAMM) or the Register of Qualified Memorial Fixers (RQMF) irrespective of whether works are being carried out on new or existing memorials.
  • Memorials that have been laid down following non-compliance by the Deed Holder must not be re-erected by anyone but a BRAMM, RQMF registered memorial mason appointed by the Deed Holder, any attempt to do so may result in the memorial being removed from the grave plot and being stored by the Council until such a time as it can be affixed by an appropriate person.

Existing Memorials

The problem with existing memorials that are insecure is that historically masons were not fixing memorials to any industry standards and for many years this was accepted. The older Churchyard monolith headstones, (memorials that are sunk a third of their height into the ground) can be far more stable than their modern multi block contemporaries.

Formal Inspection Programme

All individuals carrying out memorial safety inspections shall be trained by the Institute of Cemetery and Crematorium Management (ICCM) and obtain certificates of competence which shall be held on their personnel file.

Information notices regarding all inspections shall be displayed within the Cemetery grounds at appropriate locations.

Imminent Failures

Memorials that are deemed in danger of imminent failure will have a notice attached (usually with warning tape) in an attempt to ensure that the deed holder is made aware of the memorials poor condition but also to inform other visitors to the Cemetery of the risk of failure posed. Notices placed on memorials include the Council’s contact details and must not be removed until essential repairs have been carried out and the memorial has been reinspected.

The timescale given for action to memorials at risk of imminent failure is 6 weeks from the date of inspection, however, should the deed owner/appointed memorial mason contact the Council within this timeframe to request flexibility this may be considered dependent upon the level of identified risk from the memorial.  

The use of a Topple Testing Device

As a condition imposed by the Church of England Faculty, permission to use this type of device may only be used when a memorial fails the hand test. The device can then be used by a suitably qualified person to give an accurate reading at what calibration point the memorial failed the test (this type of device is typically used by an accredited memorial safety company and would not normally be used by Gainsborough Town Council employees unless they are trained to do so).

Where memorials fail this inspection, the council will attempt to contact the grave owners to inform them of the failure of their memorial.

Category 1 Memorials

Memorials up to 36 inches/914mm in height will first be visually inspected and then will be physically checked to ensure that all joints are sound and that the memorial is stable on its plinth. Memorials in this category are not to be used to lean against or act as leverage when standing up from a kneeling position.

Make safe – category 1 Memorials

Category 2 Memorials

Memorials above 36 inches/914mm but not exceeding 78 inches/1980mm in height will first be inspected visually and then hand tested as per the training received by the ICCM. A forced measuring device (topple tester) may be used by a suitably qualified person when a memorial fails the hand test to confirm the fail-force threshold.

Make safe – category 2 Memorials

  • Tape off the memorial
  • Notify grave Deed Holder where possible.
  • Laying down of memorial where no owner can be contacted or rights for the grave have expired (this method must be carried out by a fully trained person/contractor).

Category 3 Memorials

Memorials above 78 inches/1980mm in height will be first visually checked and if no problems are noted then no further action is required; however, if a memorial is deemed unsafe then a further check may be carried out by a suitably qualified person such as an accredited memorial safety contractor or structural surveyor. The cost of this will be the responsibility of the grave deed holder.

Memorials found to have failed this inspection will be made safe by:

Make safe – category 3 Memorials

  • Cordoning off, for larger memorials in category 3 that fail the visual test, the cordon will need to cover the fall radius of the highest point of the memorial and not just the memorial itself.
  • Notify grave Deed Holder where possible.
  • Laying down of memorial where no owner can be contacted or rights for the grave have expired (this method must be carried out by a fully trained person/contractor).

Rolling Programme of Inspections

Memorials which fail the test will be inspected again following the expiration of the make safe date to ascertain whether they have been repaired by a BRAMM, RQMF registered memorial mason that has been instructed by the grave deed owner. Informal visual inspections will also be carried out by Council staff during their normal work activities i.e., locally to where graves are being dug and grass cutting operations are taking place; should any memorials fail these random visual tests the employee will report their findings to the Council office.


Gainsborough Town Council is aware that memorial testing is a sensitive issue for those involved. Regular communication will be maintained so that the public, staff and members are aware and understand each stage of the testing process. Communication will take place through:

  • Council’s website
  • Council’s social media pages
  • Signage within the areas affected.

Memorial Safety Policy

Adopted: 11 August 2021 – Review date: (((INSERT DATE)))