Background
To provide a good foundation for a health and safety culture it will necessary for an organisation’s health and safety management system to go beyond the legal requirements. HSG65 proposes the Plan, Do, Check and Act (PDCA) model, which has its origins in quality systems and is consistent with ISO 9000 family of international quality standards.
According to HSG65 the model is applied as follows:
- Plan – Determine your policy/plan for implementation;
- Do – Profile risks/Organise for health and safety/Implement your plan
- Check – Measure performance (monitor before events, investigate after events)
- Act – Review performance/Act on lessons learned
It is worth noting that previous versions of HSG65 referred to the POPMAR model, which included the following elements:
Policy – set a clear direction for the organisation to follow;
Organising – put a structure and arrangements in place to deliver the policy;
Planning and implementation – establish, operate and maintain good systems;
Measuring performance – against agreed standards to reveal where improvement is needed;
Audit – planned assessment of arrangements;
Review – taking account of all relevant experience and applying lessons.
The key message from this is that information from performance measurement and audit must be reviewed, and then the findings from the review fed back into the appropriate elements of the system. This makes it a living system that adapts as required to ensure it makes a positive contribution to health and safety.
Reference – HSG 65 “Managing for Health and Safety” available free at http://www.hse.gov.uk/pubns/priced/hsg65.pdf
An alternative model for a safety management systems is presented in the international standard ISO 45001:2018: Occupational health and safety management systems (H&SMS). It proposes the following elements
- Context of the organisation (H&SMS framework)
- Leadership and worker participation (H&SMS framework)
- Planning (Plan)
- Support (Do)
- Operation (Do)
- Performance evaluation (Check)
- Improvement (Act).
Health and safety policy
As with many aspects of business, policy is an important part of achieving compliance and managing health and safety. As well as being a specific required of the HSWA 1974, policies form the starting point of safety management systems.
What is a Health and Safety policy?
A health and safety policy is used to convey
- The general intentions, approach and objectives of an organisation;
- The criteria and principles on which its actions and responses are based.
Effective health and safety policies set a clear direction for the organisation to follow.
In a similar vein, ISO 45001[1], the international standard for management systems of occupational health and safety, requires a health and safety policy that states clearly overall health and safety objectives and a commitment to improving health and safety performance.
Reference – HSG65 is available to download free at http://www.hse.gov.uk/pubns/priced/hsg65.pdf
Legal requirements
Under the HSWA1974 an employer has a duty to prepare a written statement of general policy with respect to health and safety together with the organisation and arrangements for carrying out the policy if five or more people are employed at any one time for a single undertaking. In most cases it is quite clear which organisations are exempt from this duty. However, there is some case law (Osborne vs. Taylor of Huyton) that has provided further explanation that may be illustrated by the following scenarios:
1. An undertaking requires three people. It may be that three people are employed for the first part of the week and a different three for the second part of the week. Even though there are six people employed by the business they are never present at any one time, and so there is no legal requirement to prepare a policy.
2. An organisation has two business locations, each employing three people. In this case the two locations are considered to be part of the same undertaking and so there will be six people employed and there is a legal requirement to prepare a policy.
In reality preparing a health and safety policy is not a particularly onerous undertaking and for any organisation that employs people it would be quite reasonable to do this, even if there was not a legal duty.
Contents of the policy
A written health and safety policy needs to cover the following:
1. Statement of intent – this demonstrates management’s commitment to health and safety and sets goals and objectives for the organisation;
2. An organisation overview – allocates key health and safety responsibilities and reporting lines within the organisation;
3. An overview of arrangements – sets how systems and procedures are used to implement the policy in practice.
In most cases a policy can be covered on a single page. It will usually be necessary to provide more information about the organisation and arrangements, to provide the detail necessary to fully implement the policy. Health and safety policies should be signed by the most senior person in the business.
Reference – A template for developing a health and safety policy is available free at http://www.hse.gov.uk/risk/risk-assessment-and-policy-template.doc
Communicating the policy
It does not matter how good a health and safety policy is if no one knows it exists or no one ever reads it. Therefore it is vital that time and effort is put into communication to avoid it becoming a paper only exercise that will make little difference to health and safety performance.
Ensuring a health and safety policy is as brief as possible (whilst covering thing it needs to) and presented in a clear and simple fashion will certainly increases the chances that people will read it and understand what it means. On top of that the options for communication include:
- Giving employees their own personal copy of the policy or a summary of it;
- Displaying the policy on notice boards;
- Explaining the content of the policy at team briefings or tool-box talks;
- Explaining it during induction and refresher training courses;
- Referring to the policy in internal newsletters, booklets, emails and intranet communications;
- Making the policy an agenda item at meetings of the health and safety committee.
It is unlikely that people will choose to read it on a regular basis and are liable to forget what it says over time. Therefore it is important that the policy is communicated in a number of different ways on a frequent basis.
Updating a policy
It is vital to keep the policy up-to-date; otherwise it will lose its relevance and can even become counterproductive. Circumstances in which it should be reviewed include:
- Significant changes in the organisation;
- Introduction of new or changed processes or work methods;
- Changes in key personnel;
- Changes in legislation;
- As a result of risk assessments, monitoring exercises or investigations that show the policy is no longer effective or relevant;
- Following audits;
- Comments from staff;
- Following enforcement action;
- On a regular basis (an annual review is probably a sensible idea).
It is important that any changes are communicated to those likely to be affected. Just telling them the policy has changed is unlikely to be wholly effective, and it is normally necessary to explain what those changes mean to individuals with regard to necessary changes to procedures and behaviours in order to implement the new policy.
[1]. ISO 45001: 2018. Occupational health and safety management systems