Scott Crichton CMIOSH, principal health and safety consultant at WorkNest, identifies common health and safety policy mistakes – and how to get it right next time.
A well-considered health and safety policy is the starting point of any effective safety and health management system. Unfortunately, in our experience, these essential documents often miss the mark. They may be too long (or not long enough), missing important information, compiled incorrectly, or too generic to have any practical value. In some cases, they’re simply created as a box-ticking exercise and left to sit on a shelf.
Here are 10 areas where health and safety policies commonly fall short, and what you can do to address them.
1. No statement of intent
Every policy should start with a written statement of intent that sets out your general approach to managing workplace hazards and risks. It typically takes the form of a one-page document signed by the most senior person within the organisation and can be supported by the chair of the board for extra weight.
Often this document is either missing or not signed, which can lead to a lack of demonstrable commitment from senior individuals in the organisation. This in turn affects health and safety culture. Additionally, a statement of intent should cover not just safety but health: that includes stress, mental health and wellbeing.
Your statement of intent must explain what you’re aiming to achieve by implementing your policy and providing performance indicators. The importance of setting clear and measurable objectives is often overlooked.
2. Doesn’t specify how health and safety is organised
The second part of a health and safety policy usually outlines the structure of your organisation and sets out key health and safety roles and responsibilities. Without this, wires can easily be crossed, making it more likely that things won’t get done. You risk creating a culture of ‘it’s not my job’.
One way to approach this is through an organisational chart that visually defines how health and safety is managed within your organisation. Responsibilities can then be defined in role/job descriptions to support this.
You should capture who:
- Has overall responsibility for managing health and safety within your organisation
- Has day-to-day responsibility for effectively implementing your policy
- Your health and safety champions are – these people play a key role in the implementation and review of the policy.
Health and safety is very much a team effort, and your policy should reflect this.
3. Doesn’t cover all the relevant hazard areas
Your health and safety policy should set out the arrangements for managing relevant health and safety risks. This section should form the largest part of your policy, with real thought given to the specific hazards present in your environment.
However, this is typically where weaknesses and opportunities for development can be found, as employers sometimes miss very obvious and significant hazards. Arrangements typically cover areas such as asbestos, consultation, evacuating your premises, risk assessments and training.
Make sure there is an index in place that lists all the hazards linked to your organisation and ensure that your policy covers all of the significant dangers that you, your employees and others face during the course of their work. This will also help to ensure that your policy isn’t generic – another common downfall.
It may be more appropriate to have shorter policies that cover specific areas such as display screen equipment, first aid and working at height.
4. No worker involvement
Organisations tend to produce health and safety policies with little, if any, input from their workforce. However, involving employees in the creation and review of policies is a great way to increase awareness of risk and encourage ownership.
It’s a good idea to produce an accompanying employee handbook that translates the contents of your policy into the relevant information employees need to work safely, and does so in an easy-to-read way.
Not every organisation has a health and safety handbook; indeed, they are not required by law. But this can be a significant flaw, as it can mean the contents of your policy isn’t properly communicated. After all, it’s far more likely that employees will digest a jargon-free 20-page handbook than a 50-page policy.
5. No evidence the policy has been communicated and read
Employers often share policies with their workforce but have little way of knowing that employees have read them. You should communicate the policy and any subsequent amendments to staff, and ideally obtain documented evidence that this has been received, read and understood. Failing to do so can be a costly mistake – particularly in the event of an accident, where you may need to prove the employee was made aware of your health and safety rules and procedures. To get confirmation, use physical signatures or digital systems that send automatic notifications when a shared document is read, or simply make this a part of your induction process. This will strengthen your defence if an incident occurs.
6. Not easily accessible
Your policy should not be shrouded in mystery or covered in dust. It should be readily available to internal and external stakeholders within your organisation. It should also be easily accessible to employees, perhaps via the company intranet, to address any excuse for not having read it.
7. Too long
Some policies lack important information, but others are much longer than they need to be. While they should cover all bases, policies should be succinct and purposeful. It shouldn’t be a dense, daunting document that no individual has the time or inclination to read, or that people must wade through to get to the information they need.
8. Not discussed with other occupiers/organisations
Within your policy, you should consider how you will cooperate and coordinate with any other employers with whom you share premises. As well as being a legal requirement, failing to do so can lead to a lack of control – there could be an assumption on both sides that the other party is managing certain risks, when neither party is.
9. Not reviewed annually
A health and safety policy is a living, breathing document and should be reviewed often – at least annually. In many cases, organisations assume that producing a health and safety policy is a one-time task, when in reality it’s about effectively managing risk. Therefore, continual improvement is essential to keeping your policy alive.
The policy should be referred to when incidents (accidents and near misses) happen and when there are significant changes to how your organisation operates.
10. Not written by the right people
Organisations can write health and safety policies themselves, and there’s no legal requirement to involve professionals. Indeed, the GB Health and Safety Executive says health and safety policies are best written by someone within the organisation, as they need to reflect the organisation’s values and beliefs, as well as a commitment to providing a safe and healthy environment.
That said, producing these important documents can feel like a daunting task, particularly if you’re not the most safety-savvy, pushed for time, or don’t know where to start. So there are benefits to enlisting specialist experts to assist you.
Your policy will benefit from your unrivalled knowledge of your own business and its risks, combined with their expert industry knowledge. This will ensure your policy is robust, fit for purpose and reflects best practice. What’s more, it’s the safest way to avoid the many common mistakes outlined in this article.
Resource
IOSH competency framework: iosh.com/my-iosh/competency-framework
