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Why didn't I think of the pre-submission meeting? That's obvious in hindsight. Will do that on the next job.
Also send your RAMS with a covering note that says 'please provide specific written comments on any areas of non-compliance with reference to the relevant regulation or standard'. Makes them commit to actual reasons rather than vague rejections.
This is increasingly common on large commercial sites where the H&S advisor is a desk jockey who doesn't understand the actual work. The trick is to request a meeting with the H&S advisor before submitting revision 2 onwards so they explain exactly what they want. Gets it sorted in one revision usually.
The real problem is that too many H&S advisors on big jobs are ticking boxes rather than actually understanding the risk. A confined space entry RAMS should be straightforward if it covers the relevant Confined Spaces Regs 1997 requirements. If theirs is 'approved' with no changes from the third version they either didn't read the third version or they ran out of things to query.
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