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Memorial Testing Policy

Date: April 2023


It is the aim of the Council to provide the highest standards within its Cemetery Service to meet the needs of the bereaved and those who visit Council managed cemeteries.

It is therefore essential that a memorial safety policy is in place to provide an acceptable balance between the provision of a sensitive service with the need to maintain a safe environment for all.

The Council reserves the right to make any amendments or additions to the memorial safety policy as and when necessary.

For the avoidance of doubt, nothing within this document shall prejudice or affect the Council’s rights, powers, duties and obligations in the exercise of its functions as a Local Authority.

On request, a copy of this policy will be issued and a copy will be available on the Council’s website.

In this Policy, except where the context otherwise requires, the following expressions shall have the meanings hereby assigned to them.

“The Cemetery” shall mean:

  • Carmel Cemetery, Heol Hir, Gwaun Cae Gurwen
  • Godre’r graig Cemetery, Graig Road, Godre’r graig
  • Onllwyn Cemetery, Wembley Avenue, Onllwyn
  • Llantwit Cemetery, Llantwit Road, Neath
  • Ynysymaerdy Cemetery, Ynysymaerdy Road, Briton Ferry, Neath
  • Goytre Cemetery, Goytre Road, Goytre, Port Talbot
  • Margam Cemetery, Longlands, Margam
  • Cymmer Cemetery, Eastern Avenue, Cymmer
  • Giants Grave, Briton Ferry , Neath

Should anyone have any queries in relation to the Memorial headstone testing policy, they should, in the first instance, contact the Cemeteries Office or call 01639 686121/686122.  Any complaints will be dealt with in accordance with the Council’s Corporate Comments, Compliments and Complaints Policy.

Cemetery Information


The Council has responsibility as a burial authority for nine cemeteries located at:

Cemetery Address Post Code
Carmel Cemetery Heol Hir SA18 1PL
Cymmer Eastern Avenue SA13 3NT
Godre'r Graig Graig Road SA9 2NY
Goytre Goytre Road SA13 2YN
Giants Grave Giants Grave Road SA11 2ND
Ynysmaerdy Ynysmaerdy Road SA11 2TL
Llantwit Llantwit Road SA11 3LB
Margam Longlands Lane SA13 2NR
Onllwyn Wembley Avenue SA109HG


Cemeteries Office
Directions to SA11 2GG
Neath Port Talbot Country Borough Council
The Quays
Brunel Way
Briton Ferry
SA11 2GG pref
01639 686122 01639 686122 voice +441639686122

Cemetery Office opening hours

  • Monday to Thursday 8.45am to 4.00pm
  • Friday 8.45am to 3.30pm


This policy has been produced to set out the Council’s position with regards to memorial safety, the responsibilities of the Council, its contractors, memorial masons and grave owner’s as well as the actions that will be taken to minimise risk to the users of Council managed cemeteries across the Borough.

Memorials are erected on graves as a permanent reminder of those buried within. It is often wrongly assumed that memorials are permanent structures and will last forever without any need for repair.

Unfortunately, this assumption has cost the lives of people nationally in recent years, most of whom have been children, and there have been countless accidents ranging from bruising to severe crush injuries. The primary responsibility for Health and Safety in Council owned cemeteries lies with Neath Port Talbot County Borough Council as the Burial Authority and land owner, in control of its cemeteries. The Council is required to control the risks associated with any cemetery for which they have responsibility.

Whilst the Council has overall responsibility for the safety of the cemeteries, including risks from unstable memorials, it does not own the memorials. The owner of the memorial is the grave owner. In many cases, there is no record of the identifiable Owner.

Responsibilities for Memorial Safety

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

  • The Council has duties under section 2 of the Health and Safety at work Act 1974, to protect the health, safety and welfare of all their employees within its cemeteries. This duty also extends to contractors, visitors and the general public within its cemeteries. The management of Health & Safety at Work Regulations 1999 also places a legal duty on the council to assess and manage risks to their employees and others arising from work activities within its cemeteries
  • A Monumental Mason has the responsibility to work in accordance with the council’s conditions and specifications for memorials as laid down in the Cemeteries Rules & Regulations and in accordance with current standards available within the industry i.e. British Standard 8415 and the British Register of Accredited Memorial Masons (BRAMM) Blue Book
  • An Owner, the Grant of Right Holder (or successor in title) of a memorial has the responsibility to maintain it so as not to present a hazard.

Reasons for memorial instability may include:

  • Accidental Damage
  • Animal activity (e.g. burrowing by rabbits, moles, foxes etc.)
  • Insect activity (e.g. ants' nests)
  • Encroaching tree roots
  • Inadequate fixings
  • Inferior materials
  • Lack of maintenance
  • Poor Workmanship
  • Subsidence
  • Vandalism
  • Weather/storm damage
  • Decay through aging


The Council will inspect the memorials located within its cemeteries on a 5 year rolling programme. This approach has been described as reasonable by the Health and Safety Executive.

Notification & Signage

Prior to any memorials being inspected, reasonable steps will be taken by the Council to inform grave owners and members of the public of the intention to inspect memorials.

This will involve:

  • Giving advance general notice in a local newspaper at least 28 days in advance of any inspection regime commencing, and/or making media announcements giving details of the assessment locations and methodology at least 28 days prior to the commencement of any inspections.
  • The Council’s website will provide information about how the testing is carried out.
  • Signage will be on display in prominent locations in the cemetery providing details of the inspection process.
  • Publicised ‘Open days’ will provide an opportunity for public to observe the inspection process and raise any queries that they may have.

Testing Process

Method Statement

Memorial inspections will be carried out by approved and qualified contractors.

In most cases the inspection, testing and recording will be carried out by a team of two. One trained inspector and one recorder.

Inspection Equipment Required

The following equipment is required to carry out inspections:

  • An appropriate angle measuring device.
  • Recording sheet

Personal Protective Equipment

Inspectors should have the following equipment:

  • Safety Footwear
  • Safety Helmet (where relevant) for larger memorials
  • Gloves
  • Wet Weather Clothing
  • Hi Visibility Clothing

Method of Work

The management of memorial safety is based on a risk assessment approach. As a priority, this will involve attempting to identify those memorials that present an immediate and a significant hazard and making them safe.

Action will also be taken to deal with memorials identified as being unstable but not an immediate hazard, in order to prevent these memorials becoming a risk to safety in the future.

The Council will apply a proportionate approach to testing in each cemetery which will mean that any memorial less than 625mm in height will not be tested, however if any hazards are identified, immediate action will be taken and the grave owner will be contacted.

Memorial inspections are recorded to identify the name of the last interment, cemetery name, plot number and grave number.

Visual Inspection

The inspector will stand to the side of the memorial and visually inspect without touching the memorial and record the following:

  • Cemetery name
  • Plot number
  • Grave number
  • Name of last interred

The inspector will then commence a more detailed inspection looking for the following:

  • Signs of weathering and erosion on the memorial
  • Intrusion of vegetation
  • Are joints intact
  • Signs of soil erosion around memorial base
  • Cracks, splits or damage to the memorial, its kerbs and foundation (where applicable)
  • Loose vases or pots
  • Any deterioration to grave surrounds or rails
  • Obvious or severe leaning (10 degrees or greater)

Manual Inspection

Whilst stood to the side of the memorial, the inspector will start to apply hand pressure to the memorial at a suitable point to establish any initial movement. This pressure should be firm and progressive, but not excessive.

A memorial which has been erected to BS8415 standards may have some movement in the joint, but this will be restricted by the dowel pins between all the components.

It is at this point, the result of pass or fail is recorded. If the memorial fails the inspection process, then it will be noted where the memorial has failed and a risk assessment as to the next step in terms of making safe will be carried out.

Classification of Memorials

After undergoing the testing process, memorials will be classified into three categories.

  • Category Red (High risk) – Poses immediate danger and should be made safe by appropriate means.
  • Category Amber (Medium risk) – No immediate danger, however due to concerns about a longer-term hazard, requires re-inspection within twelve months.
  • Category Green (Low risk) – Good condition, no attention required and re inspect in 5 years.

Unsafe memorials

Where a memorial has failed a safety inspection, appropriate measures will be taken to ensure the safety of the memorial. Measures that can be utilised include:

  • Warning notices attached to the memorial to inform grave owners of the failure.
  • Stake and band measures to ensure the stability of the memorial.
  • Socketing the memorial. This involves burying part of the memorial into the ground to ensure the stability of the memorial.
  • Laying the memorial flat. This involves laying the memorial flat onto the ground, where practicable, with the inscription facing upwards.

Once the appropriate measure has been implemented, the information is passed to the cemeteries office for contact to be made with the grave owner. All inspection details will be entered into the Council’s cemeteries database.


Inspected memorials will be given a classification of green, amber or red. Memorials classified as green warrant no further action. For memorials classified as amber, a letter will be sent to the grave owner to inform them of the results of the safety inspection. No temporary stability/safety measures will be taken by the Council; however, the memorial will require a further inspection within a 12 month period.

Where a memorial has been identified as being unsafe (red), and action is taken by the Council to limit the safety risk, the following process is implemented:

  • Letter 1 – A Letter will be sent to the last known grave owner(s), informing of the outcome of the memorial inspection and the temporary measures the Council have had to take to make the memorial safe. The letter will also inform the grave owner that they have a period of 12 months to undertake the required works.
  • Action by grave owners - Owners will need to arrange the necessary remedial work with a memorial mason, for which the mason is likely to charge a fee. The cemeteries officer can supply a list of memorial masons. All works must be carried out by a BRAMM registered mason and to BS8415 standards.
  • Letter 2 - If the grave owner does not contact the cemeteries office within a period of 10 months, a final letter reminding the grave owner of their responsibilities will be sent.
  • Failure to act - Should the required works not be completed within the 12 month period, the Council may take appropriate action to ensure the permanent safety of the memorial, for example, pocketing or laying the memorial flat.

Where a grave owner cannot be traced and it is felt that the memorial is of historic significance or its maintenance is important to preserve the character or ambience of the cemetery, the Council may consider carrying out the repairs subject to funds being available.

No attempt should be made to repair or remove any memorial except by a properly qualified BRAMM memorial mason

Future Installations

In order to limit failures of new memorial installations, the Council requires all installations comply with BS 8415. Although some deterioration to the stonework, foundations and fixings due to weathering and passage of time is inevitable, complying with this standard will significantly reduce the risk of failures.

Memorial Masons

Only memorial masons registered with the British Register of Accredited Memorial Masons (BRAMM) may submit an application to undertake any memorial works in the cemetery.  Persons wishing to carry out any memorial works must satisfy themselves that the memorial masons they engage with are BRAMM registered. 

The BRAMM registration scheme is intended to:-

  • Protect the interests of memorial owners in respect of unsatisfactory workmanship
  • Standardise the quality of fabrication and installation methods
  • Ensure Monumental Masons comply with the Council’s Health and Safety Regulations
  • Ensure minimum levels of public liability and employer’s liability insurance cover are held by all Monumental Masons
  • Ensure that any memorial installed or repaired will pass a future stability test.

Where possible all work on memorials is to be completed by the mason before they are admitted to the cemetery and no labour of any kind (beyond that of affixing) will be allowed within the cemetery, unless previously agreed and at the discretion of the Council.

The ownership, upkeep, maintenance and all repairs, (including those required following stability tests carried out by the Council), of a memorial remain the responsibility of the owner for the grave.  Headstones, crosses, plaques, kerb sets or other structures shall be kept in good order and repaired to the satisfaction of the Council and at the expense of the grave owner.

No memorial is to be installed or structural or restorative works carried out to an existing memorial in the cemetery unless a permit has been granted by the Council.

The Council reserves the right to instruct any person who places any memorial in a cemetery without prior permission, or who places a memorial which exceeds any of the dimensions referred to in the preceding rules, to remove the memorial from the cemetery.

The Council may carry out a check or test of a memorial, including all extensions and inscriptions, to verify compliance with the submitted application form.  The memorial mason will be requested to immediately take whatever action is necessary to ensure compliance should any failings be identified

Comments, Complaints and Compliments

The Council operates its own Comments, Compliments and Complaints procedure. Details are also available from the Cemeteries Office.