This post is inteneded to help explain the purpose and importance of setting policy for health and safety and describe the key features and appropriate content of an effective health and safety policy.
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The importance of setting policy for health and safety
The most effective means of demonstrating the importance of health and safety issues is for organisations to have a health and safety policy that is signed and dated by the most senior member of the management team. The need for all employers to create in writing a safety policy is a statutory requirement under section 2(3) of the Health and Safety at Work etc. Act 1974. Small organisations with less than 5 employees still require a health and safety policy, but not in writing. -
The key features and appropriate content of an organisation's health and safety policy
We must not get mixed up in our minds between a safety policy and a safety manual. These are not the same even though in some organisations they are combined. - The systems by which safety performance is monitored in order to identify, record and take appropriate action to deal with deficiencies in performance
- Identification of the main hazards likely to be encountered by the workforce or other persons who may be affected by work activities.
- Significant findings of generic risk assessments and any circumstances when specific risk assessments will be required with arrangements or cross references for dealing with them
- Employee selection criteria and subsequent training arrangements
- Buildings, plant, machinery, equipment selection criteria along with maintenance arrangements and statutory examination and testing
- Material and substance purchasing policy and arrangements
- Safety arrangements for products and services
- Occupational health facilities including first-aid arrangements
- Environmental monitoring policy and arrangements
- Methods of reporting accidents and incidents
- Methods used to investigate accidents and incidents
- Arrangements to validate, appoint and control the work of contractors
- The policy for the assessment of the need for personal protective equipment, it's purchase, availability, use, storage and replacement arrangements along with training requirements
- Workers consultation arrangements, for example, safety committees
- Fire and other emergency arrangements
- Arrangements for dealing with safety violations and of encouraging conformance
This is only the law emphasising what has been known for many years - good organisations have safety policies at the heart of their safety manag.ement arrangements.
Policies should be 'enabling' like the Health and Safety at Work etc Act itself that is, written in a way that is reasonable and logical and the touchstone against what every activity within the organisation can be benchmarked.
The policy in itself can assign responsibilities and set methods by which the organisation's policy on health and safety issues can be implemented.
These assigned responsibilities and accountabilities must not be in any conflict with any person's job descriptions and should be taken into account when considering if what employees are being asked to do is reasonable within time constraints.
Accountability is the primary key and this is not the same as responsibility. Accountability is responsibility that is evaluated and measured during safety audits and, during annual individual job appraisals.
The policy should include a simple statement of the intent of management, together with the details of the organisation along with delegated responsibilities at each level of the operation.
This policy must be made known to every employee and 'made known' does not mean just displaying it on the company notice board. A useful method to ensure that the policy is 'made known' to every employee is to arrange for them to read it and sign a document to that effect.
The safety policy should set targets and make reference to the safety manual as well as other stand-alone documentation like maintenance manuals or training programmes.
The policy should provide all employees with concise details of the health and safety objectives of the organisation.
That is what everyone must know and take account of.
Employees must also be aware of their responsibilities as related to their particular job within the organisation and how their actions or inaction impact upon other people..
In large organisations with several sites, possibly doing entirely different types of operations, the safety policy of intent will be the same but detailed arrangements for implementing it will be written at local level.
Organisational arrangements
Whether the company is a multi-national corporation or a small business, the policy must contain the same basic matters.
Obviously, the requirements for large corporati6ns will be much more extensive than for amall business where in many cases the management system can be to a great extent informal.
A health and safety policy will normally have three sections:-
The statement of intention - this will set out an expression of intention, and commitment, to matters concerning health and safety.
The organisation section will describe the responsibility of line managers and employees at all levels.
The arrangements section will detail the way in which health and safety is managed. The arrangement section may include:-
Other considerations
Safety policies as written statements of the intention of management should be live working documents. They serve as a record of the standard of care that management is intending to provide.They offer a useful method of evaluating an organisation in terms of their commitment to health and safety matters.
Unfortunately in a considerable number of organisations, especially smaller ones, the policy is merely a useful document to produce if asked to do so by inspectors, insurance companies or clients. In these cases any similarity between what the policy says and what is happening may be only co-incidental!
In using the policy to validate clients it is important to look closely at samples of activities to assess if the policy is indeed a live enabling one or merely cosmetic.
Because the policy is a statutory requirement it may well be used as evidence during a possible prosecution or civil claim for damages.
Revision of safety policy
Safety policies should be revised as often as is necessary. If the statement of intent is well worded in enabling terms it should, like The Health and Safety at Work etc. Act 1974, stand up well to the test of time.It is more likely that changes will be required occasionally for one or more of the following reasons:
- New or amended legislation
- The setting of new case law precedents
- Following an incident that demonstrated a need for change
- products or services
- work processes or machinery
- personnel
- hours of work
- premises
The function of the safety policy
Safety policy statements and associate documentation serve as a structure to demonstrate that the organisation is meeting its common and statutory legal requirements. It should always be remembered that the law demands only the minimum of what is acceptable.Good organisations should use the policy as a stepping-stone to higher objectives that can be based on moral duties and the reduction of financial loss.
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