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Memorial testing policy


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 the Council’s cemeteries.

A memorial testing policy is important for the safe management of the Council’s cemeteries and to maintain a safe environment for everyone who visits.

Neath Port Talbot Country Borough Council reserves the right to make any amendments, alternations or additions to the Memorial testing 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.

Bereavement Services


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
Neath Port Talbot Country Borough Council
The Quays
Brunel Way
Briton FerrySA11 2GG
 01639 686122

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 Neath Port Talbot County Borough Council’s (the council) position with regards to memorial safety, the responsibilities of the Council, its contractors, memorial masons and Grant of Right Holders (grave owner) as well as the actions that will be taken to minimise risk to the users of Council managed cemeteries across the Borough.

Since Victorian times memorials have been erected on graves as a permanent reminder of those buried within. It is often incorrectly assumed that memorials are permanent structures, installed to high standards, and will last forever without any need for maintenance. Memorials which have become unsafe have cost the lives of six people nationally in recent years, most of whom have been children, and there have been numerous accidents ranging from bruising to severe crush injuries. Local authorities have to tackle general degradation as well as neglect and in some cases poor workmanship. Primary responsibility for Health and Safety in council owned cemeteries lies with Neath Port Talbot County Borough Council as the Burial Authority in control of its cemeteries. The Council is required to control the risks associated with any Cemetery for which it has responsibility.

Whilst Neath Port Talbot County Borough 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. But in many cases there is no identifiable owner.

Responsibilities for memorial safety

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

  • The Council has health and safety responsibilities to its employees, contractors and visitors to its cemeteries. The council has a responsibility to staff (Section 2 Health and Safety at Work Act 1974). The Management of Health & Safety at Work Regulations 1999 places a legal duty on the Council to assess the risks from cemetery structures and work activities and ensure the risks are controlled.
  • 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


An inspection programme has been drawn up and is in place for all cemeteries. This is a ‘5 year rolling programme approach’ which the Health and Safety Executive describe as reasonable.

Notification and signage

Prior to any Memorials being inspected, reasonable steps will be taken by the Council to inform grave owners, Grant of Right Holders and members of the public of the intention to inspect memorials and address risk from unsafe 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 providing information about how the testing is carried out.
  • Displaying signage in prominent locations in the cemetery providing details of what is happening.
  • Publicised ‘Open days’ to provide an opportunity for the public to observe inspection processes.​

Testing process

method statement

Memorial inspections should only be carried out by competent persons who have attended industry training in memorial works. Staff will also be competent in the use of equipment and techniques involved in the making safe of unstable memorials and also in the use of memorial stability testing devices.

In most cases 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 (Appendix A)

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 any immediate and 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 24”/610mm inches in height will not be tested, however if any hazards are identified, immediate action will be taken and the grave owner contacted.

For each memorial, the inspector will record the name of the last internment, 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 interred

Inspector to 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 and record any initial movement. This pressure should be firm and progressive, but not excessive.

Is any movement:-

  • At the foundation?
  • Between the foundation and plinth?
  • Between plinth and base or joints in memorial?
  • Are Dowels or ground anchors fitted?
  • Is the foundation base of satisfactory size and material?

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.
This method of inspection is appropriate and can be used for memorials up to 70”/1778mm in height. Memorials above this height will require the expertise of a relevant qualified person.

Load testing of memorials

Whilst this is not recommended by the Ministry of Justice as routine practice, a confirmatory load test of memorials which have failed the Manual inspection might be considered. This would be carried out by a competent tester, using a calibrated stability tester and would accurately quantify the manual test and will be recorded where carried out.

Where mechanical resting is undertaken the tester will again, where possible stand to the side of the memorial (as per the manual test) and will gently and progressively increase the load on the memorial, centrally at the top edge or approx 1 metre up the stone. As soon as unacceptable movement occurs, load is removed from the memorial. The load figure will be retained on the electronic screen and will be recorded on the inspection report sheet.

Classification of memorials

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

  • (High risk) – Poses immediate hazard and should be made by safe by appropriate means i.e. Stake and band, Pocketed or Laid Down (last resort). Kerbsets to be laid within the grave space.
  • (Medium risk) – No immediate hazard, however due to concerns about a longer-term stability, requires re-inspection within twelve months.
  • (Low risk) – Good condition, no attention required and re inspect in 5 years.

For Memorials identified as High risk the inspector should record this on the inspection sheet then add what work they have carried out to address the risk or what work needs to be urgently arranged. The inspector will then re-evaluate the risk and record with the probability of the Hazard now becoming a Medium Risk or Low Risk.

Unsafe memorials

The assessment process may be upsetting for Grant of Right Holders and visiting families. Neath Port Talbot County Borough Council regrets any distress that it may cause. However, it is better that the memorial is assessed rather than it is left to pose a potential hazard to others.

Where a memorial is classified as High Risk, immediate action will be taken and in the first instance (where permitted to do so) the memorial will be carefully staked and banded to make safe. Alternatively if unable to stake and band the memorial will be pocketed (a method of lowering the memorial into the ground) to a 1/3 of the height or so that an inscription is visible. At the same time, a notice will be attached to inform anyone of the reason and who to contact for further information. (Appendix B).

The Laying down of a memorial will only be undertaken as a last resort with the inscription details face up.

Kerbset memorials will be laid within the grave space, with inscription details face up.

Memorials over 70”/1778mm in height will require the expertise of a relevant qualified person. The use of specialised equipment may be required which is to be operated by trained personnel only.

After this, 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.


Where a memorial has been identified as being unsafe and action taken to remove the immediate risk, the following actions as a minimum will be taken:

  • A Letter will be sent to the last known grave owner, if the information held is less than 30 years old. (the authority will not write to anyone where the information is older than this, because we have no way of knowing if the owner has since died themselves and the Council would not wish to distress relatives in this respect. Any unsafe memorials on graves over 30 years old will simply be made safe by the most economical means).
  • 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, and applied for through the Council’s Memorial application Process.
  • Owners of memorials that have been temporarily supported will have 6 months to contact the council and carry out repairs. Should no repairs be made, the council may Pocket the memorial as per the above practice.
  • Pocketing will allow for memorials to remain upright allowing continuation of the grave and cemetery uniformity. This measure can be reversed if at some point a relative wishes to have the memorial reinstated to its original position.
  • Where a grave owner cannot be traced or the grave is over 30 years old, 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 as opposed to simply making safe. Any repairs would need to be sanctioned by the appropriate Cabinet Member of the Council.
No attempt should be made to carry out any work on any memorial except by a properly qualified BRAMM memorial mason No attempt should be made to carry out any work on any memorial except by a properly qualified BRAMM memorial mason

Future installations

Although some deterioration to stonework, foundations and fixings due to weathering and the passage of time is inevitable, the Council requires that in order to minimize these effects, all installations comply to BS: 8415.

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 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.

All work to memorials shall be carried out to BS:8415. The Council shall be informed of dates and times of intention to carry out all works on memorials.

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 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 rights holder 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. In default of their being so kept, the Council may carry out the necessary work and recover the cost from such owners, or remove the same.

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.