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Memorial Safety - An Alternative View

Morning Councillors,

Further to my email of Friday 15th March 2024, please find below:

  • Introduction
  • Dean & Manor Road Cemetery
  • Overview from Douglas Swan/Tomason Consultants
  • MonuGrid - something different
  • What the industry says
  • Scottish Government
  • ICCM Management of Memorials
  • And inspirational video


The importance of memorial safety cannot be underplayed, and it is testimony to Renfrewshire Council that they have a dedicated team solely undertaking these responsibilities.
The Scottish Government legislation allows for many things to happen within "Memorial Safety Inspections", these include:

  • Staking
  • Trenching/Socketing
  • Repair where possible
  • Laying flat

The council as a matter of course choose the latter option, FOHC have an alternative view to this practice.

After extensive research, we wish the following to be considered.

Firstly, the report from Rodger Burnett, a senior official with North Yorkshire Council. 



What was the background to the restoration of the headstones in Dean and Manor Road Cemetery?


Dean Road and Manor Road Cemetery has been in Council ownership since the closure of the Scarborough Burial Board in the 1920’s. The general maintenance had been sufficient to keep the cemetery in reasonable order with the exception of the gravestones and memorials, many of which had been subject to vandalism and general neglect. The path network and kerbstones was also an issue with inconsistent reactive repairs being carried out periodically. The tree cover was aging and there was no understory of young trees with many older specimens having to be removed as they failed. This often led to further damage to headstones with trees toppling onto them and the subsequent tree removals being done in a somewhat rough manner with little regard to the damage caused. At this time there was no procedure in place for topple testing although just after the project stated there was an attempt to carry out some testing in house which led to a number of gravestones being pushed over and smashed. This procedure was halted on my insistence and the subsequent public backlash.  In 2012 I was offered a new role within the Council tasked with engaging with a wider community, with very little in the way of budget and only two members of staff, myself and a colleague, we approached the local Probation Service to develop a partnership working with offenders on a range of projects, the cemetery being one of them. This partnership was backed up by both the council and the Probation managers who funded the initial training in memorial restoration.  


Was a separate company/charity established to manage and coordinate the restoration?


No not as such it was this Partnership between the Council and the Probation Service that delivered the project, they provided the manpower and hands on supervision, we provided the equipment, materials and supervised the project. The initial training and capital equipment was jointly funded by both the Council and the Probation Trust.


Are there any publication/press cuttings detailing the journey?


The partnership was kept at a low key due to the sensitive nature of the work and maintaining the anonymity of the Offenders and although we won a Local Government award for the partnership, overall, we did not court publicity. The Friends group and ourselves helped out by doing tours of the cemetery selling the project to the participants, the Probation Trust did receive a lot of local praise but we did keep the Offenders anonymity paramount in any thing we did.


I can see an early application for lottery funding, are you able to give some indication of how, who, what and when funding was made available? (data protection acknowledged)


The application for lottery Funding was completely separate to the Headstone Restoration project and had no bearing on the outcome.


Were private donations/bequests sought?


No there was no private money involved.


Were the community payback team involved from the outset?


Yes, the key was the Manager from the Probation service at the time (since retired) he saw the value of a high-profile project which had huge community buy in. Together with the obvious benefits for the offenders in learning new skills in a highly disciplined and safety conscious environment.


Was identification of lair holders established?


By this I assume you mean the grave owners, no it was deemed too difficult with the age of the memorials and the time and effort involved.


If so, was there permission required?


Because we decided the age of the memorials would limit the number of family members still contactable, we did a blanket notice informing any relatives to contact us if they had any concerns, no one did. However, once the project started we had numerous relatives contact us with praise and requests for further memorials within the cemetery to be attended to.


Did they contribute to cost of repairs/restoration?


As above no one contributed.


Was VAT applicable?


Again, not applicable.


How were they invoiced?


As above no costs were recovered (bear in mind the majority of the repairs were materials only and some were extremely easy and cheap to repair, only the more complex breaks were slightly more expensive. It was also deemed uneconomic to attempt any recover of costs as the time involved would far outweigh any income received.


Where no identification of lair holders was established, how was permission sought? 


As previously stated, it was a blanket notice of intention to work on one section of the cemetery at a time, this was deemed all that was required and we had no issues from it.


What assurance/guarantee were you able/required to issue?


The work was supervised by myself and my colleague who are both trained in the restoration of memorials as was the main supervisor from the Probation Service. Between us we carried out quality control and rectified any failed repairs immediately. This was not an issue as the repairs were only signed off by us once we had inspected the repair.


Were you able to get the restored headstones insured?


The Council maintain a Public Liability Insurance which cover any general issues within the cemetery.


Did all work undertaken meet BS8415 standards?


Yes, the work was all carried out to British Association of Memorial Masons (BRAMM) and National Association of Memorial Masons (NAMM) standards using only approved practices and materials.


Did the work have a detrimental effect on local monumental masons?


Not that we were aware of.


Was there any employment created, either directly or indirectly?


No however many of the offenders went onto work in the building trade using the skills they had learned through the project.


Are there any testimonials from the public with regards to the restoration work?


We had lots of positive comments from members of the public but did not keep a record of these. Mostly it was verbal feedback.  


Is there any feedback, positive or negative from those involved in the restoration work?


Lots of the offenders involved in the project said it was the most rewarding job they had been assigned as part of their community orders, however due to the sensitive nature of the client base we did not keep any records of these. We generally had no negative feedback apart from the usual weather-related nature of the work.


Are you aware of any other burial authority/friends group seeking details with regards to undertaking a similar restoration?


We based our restoration on a similar project at Harrogate, however I could not recommend their method at it simply involved burying the broken portion on the headstone in the ground making the text on them unreadable. We decided from the outset this was not something we would want to emulate, and took the view of “Do it once do it right”.


With hindsight is there anything you would have done differently?


Not really the project came to an end with the retirement of the trained supervisor and a change in the management of the Probation Service who refused to accept some Public Liability issues with working generally on public owned land, not just the cemetery.

In fifty years of working for the Local Authority this was probably the most rewarding job I have ever undertaken with the biggest community impact. But I was lucky and was able to work on the scheme without any interference and although we did it on a shoestring budget finance was never questioned. This project from the outset was not a race it was a slow laborious but highly rewarding job; it did involve a lot of our time both as council officers inside our normal working day and outside.


Would you consider a visit to Dean and Manor Road cemetery by FOHC to be worthwhile?


We would always welcome anyone to come and have a look or indeed we would be happy to come and look at your project.


Do you think we have a chance in succeeding?


Our project succeeded simply because the supervisor and the management at the time found the work interesting and a worthy project. Together with the sheer effort and determination of my colleague and myself, we had good days and bad ones, sometimes you achieved a lot sometimes very little depending on the calibre of the offenders. One thing it taught us was working with Offenders is highly challenging, often frustrating but highly rewarding, you need a thick skin and deaf ears but determination and a forgiving temperament.  Once people initially involved left the employment of the Probation Service the whole scheme fell apart. Luckily by then we had completed Dean Road Cemetery. A new management regime took over with different views and ideals not compatible with the project. However, by then we had restored 99% of Dean Road Cemetery, Subsequent topple testing has identified about twenty memorials in need of further restorative work but this is literally out of thousands of stones repaired.

The key to any projects like this is a very dedicated and committed Community Payback team, a clear objective with lots of co-operation from the Local Authority, who if they invest in the scheme with a dedicated officer to help out, sourcing small amounts of funding and ensuring the political wheels are oiled the rewards are tremendous.

In a nutshell this worked because of the close working relationship between  the Community Payback supervisor and myself as lead Officer, we both are skilled hands on people with an interest and dedication which went way beyond the normal. We both saw the benefits of the project to the community, the Council, the Community Payback Organisation and the Offenders. We never saw problems only solutions, we saw the opportunity and ran with it regardless of the bureaucracy.

We still have Manor Road to complete, in the short term we have little hope of being able to do that but given time and some creative thinking it may be possible.





We invited Douglas Swan of Douglas Swan & Sons Monumental Sculptors, Kirkcudbright. Douglas, whilst being impressed with the condition of the Cemetery,  he highlighted that the money could have been better spent. Here is what he said: 

Douglas Swan & Sons <>


You <>

Sun 16/07/2023 15:20


Hello Desmond

I am sorry for the delay in responding to your email and thank you for meeting me on the 10th.

Hawkhead Cemetery is in really good condition compared to many I have visited in the greater Glasgow area, it is actually encouraging to see a council with a maintenance programme and a safety policy in place.

The intervention by officials did not trouble me at all I have been around long enough to know we had tweaked their curiosity.

The good news is that Renfrewshire Council appear to be following the Government Guidelines, however it would be good to know just how qualified the staff who are carrying out the work actually are.

I hope that in time they shall consider restoring some of the memorials which have been laid flat. We would love to re set the firefighters memorial just to show how simple a task it can be. However, if we are not invited by them to do so then I am afraid we cannot do that. They may however come to us for some training and when we carry out training, we repair a number of memorials as part of the training course so there is hope yet.

It is obvious that there seems to be a bit of conflict between your group and Renfrewshire Council, friends groups tend to be seen as a bit of a pest to such bodies as by just being there you are keeping an eye on what they are doing.

If you can find some common ground then this may assist you both to meet your aims, I would say that I found Hawkhead good, but with a bit of guidance and not too much expenditure it could be even better.

If for example the Council can claim ownership of certain lairs and memorials then Heritage Lottery funding could become available to them to restore some of these headstones which are after all recording the heritage of Paisley.

I did enjoy my visit as I had never been to Hawkhead before and despite the headstone which are lying flat and the official intervention, it was a pleasant experience.

Kind regards

Douglas Swan

Tomason Consultants


You can view some of Douglas' work by following the Facebook link





Please see the website link and YouTube link for a short demonstration video.

IOWAT - Reinforced Soil Structures (





Advice and guidance from the Local Government Ombudsman England and Wales                 

Executive Summary

General Advice

  • Councils have an overriding duty to take, as far as reasonably practicable, measures to prevent injury or death from unstable memorials.
  • Councils must balance the (sometimes slight) risk of injury on the one hand and the certainty of distress and outrage if memorials are laid down on the other.


  • Councils should give public notice in advance of carrying out a general testing programme.
  • Councils should notify individual owners of rights of burial that testing is to be carried out, unless records are out of date, or urgent action is required in the interests of health and safety.
  • Councils should notify the owner of the right of burial, if known, if a memorial fails the test.
  • A council should display, in the cemetery itself and on the council’s website, lists of memorials which failed the test. Individual notices should be placed on or near a memorial which fails the test, giving the council’s contact details and the period for making contact.
  • Councils may offer demonstrations of their safety testing procedure to owners and interested members of the public.

Risk Assessment

  • Councils should have a system for assessing the risk posed by individual unstable memorials. Simply to lay down all memorials that move is inappropriate.

Making memorials safe

  • Councils should have regard to alternatives to laying down if a memorial fails the test.
  • A temporary support and warning notice is likely to cause less public outrage than laying large numbers of memorials flat.
  • Laying down may be necessary but only to prevent a genuine hazard to health and safety that cannot be remedied by a temporary support.
  • Temporary stabilisation for a reasonable period affords owners the opportunity to repair the memorials.

We commend the practice of councils that establish hardship funds to assist owners who cannot meet some or all of the repair costs, and councils that pay for all repairs themselves in the interests of preserving the amenity of their cemeteries or where no responsible person can be found.

"In comparison to Renfrewshire Council's Policy, which is as follows"


Renfrewshire Council's Policy

It is unfortunately not possible to reach lair owners in advance of an inspection and work being carried out, but marker notices and signage at each cemetery are in place to provide lair holders with information to contact us for details on how to ensure their memorial meets the required safety standards.


Burial ground memorial safety: Local authority guidance!&&p=3a5a6a9a701fd7c7JmltdHM9MTcxMDYzMzYwMCZpZ3VpZD0wN2JhMGYyNS02NDAzLTYxMWEtMDFjOC0wMDJhNjU0MzYwYjUmaW5zaWQ9NTMwNA&ptn=3&ver=2&hsh=3&fclid=07ba0f25-6403-611a-01c8-002a654360b5&psq=tomas+memorial+safety&u=a1aHR0cHM6Ly93d3cuZ292LnNjb3QvcHVibGljYXRpb25zL2J1cmlhbC1ncm91bmQtbWVtb3JpYWwtc2FmZXR5LWd1aWRhbmNlLXNjb3RsYW5kcy1sb2NhbC1hdXRob3JpdGllcy9wYWdlcy83Lw&ntb=1




Notifying Grave Owners – Burial authorities must advise grave owners when memorials are found to be unsafe, although consideration of the practicalities of this process must be considered. This will mean writing to the last known address of the owners of memorials less than 30 years old (see LACO Schedule 3 Para. 4 for detail), in addition to all other publicity. This is an extremely important part of the process, as burial authorities have been severely criticised for not attempting to communicate with owners. There is a danger that if the proper notification process is not followed, including publicity of the process, warning signs and letters to grave owners, the authority could be reported to the Local Government Ombudsman and accused of maladministration of the process.  Whilst raising awareness cannot guarantee that there will not be complaints about the process it has been proved to reduce the numbers of complaints to a manageable level in most cases. Should complaints be received, experience has shown that the clear majority of unstable memorials are due to a lack of dowelling on construction and installation, or the use of unsuitable foundations.

Risk Assessment

Deciding on the most suitable means of making safe and ensuring that this is proportional to the potential risk:

Identify hazards and their potential to cause harm (large memorials) – large memorials can kill and if they are unstable immediate action should be taken to remove the risk if at all possible, by setting into the ground, repairing the memorial or by laying flat. Cordoning and barriers may be inappropriate and a more substantial barrier, to standards indicated in HSE:HSG 151 – Protecting the Public.

Identify hazards and their potential to cause harm (lawn type memorials) – consideration should be given to the fact that these smaller memorials tend to result in less serious injuries and, particularly if the memorials are back-to-back, they are less likely to fall in such a way as to result in a major injury. In addition to this the owners of lawn type memorials, as they are predominantly the newer memorials in a burial ground, are more likely to be contactable. Actions such as simply placing notices on ‘back-to-back’ type memorials, cordoning individual graves or even whole sections, dependant on the number of failures, may be considered by the authority to be an appropriate way of managing the risk. In addition to physical action each memorial should have a notice placed upon it, as indicated previously. This type of action may be deemed both appropriate for the control of the risk and sensitive to bereaved families.


This is what we can achieve if we pull together. Below is a video of footage from Dean & Manor Road Cemetery.


I appreciate this is a lot to read, but with some serious consideration, I think you would agree that together we can make a difference.

Best regards

Desmond Barr
On behalf of FOHC