An effective audit is the final step in the occupational health and safety management system control cycle.
The use of audits enables the reduction of risk levels and the effectiveness of the occupational health and
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and safety standards rather than on enforcement alone. A good health and safety policy involves the development, monitoring and review of the standards needed to address and reduce the risks to health and safety produced by the organisation.
The law requires that the written health and safety policy should include the following three sections:
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u a health and safety policy statement of intent which includes the health and safety aims and objectives of the organisation;
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u the health and safety organisation detailing the people with specific health and safety responsibilities and their duties;
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u the health and safety arrangements in place in terms of systems and procedures.
The Management of Health and Safety at Work Regulations also require the employer to ‘make and give effect to such arrangements as are appropriate, having regard to the nature of their activities and the size of their undertaking, for the effective planning, organisation, control, monitoring and review of the preventative and protective measures’. They further require that these arrangements must be recorded when there are five or more employees.
When an inspector from the Health and Safety Executive (HSE) or Local Authority visits an
establishment, it is very likely that they will wish to see the health and safety policy as an initial indication of the management attitude and commitment to health and safety. There have been instances of prosecutions being made due to the absence of a written health and safety policy. (Such cases are, however, usually brought before the courts because of additional concerns.) X
u The documentation is excessive and not totally related to the organisation due to the use of generic procedures.
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u Other business objectives, such as production targets, lead to ad hoc changes in procedures.
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u Integration, which should really be a benefit, can lead to a reduction in the resources and effort applied to health and safety.
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u A lack of understanding by supervisors and the workforce leads to poor system implementation.
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u The performance review is not implemented seriously thus causing cynicism throughout the organisation.
2.2 Purpose and importance of setting a policy for health and safety
Every organisation should have a clear policy for the management of health and safety so that everybody associated with the organisation is aware of its health and safety aims and objectives and how they are to be achieved. For a policy to be effective, it must be honoured in the spirit as well as the letter. A good health and safety policy will also enhance the performance of the organisation in areas other than health and safety, help with the personal development of the workforce and reduce financial losses. A clear health and safety policy contributes to business efficiency and continuous improvement throughout the operation. The demonstration of senior management involvement provides evidence to all stakeholders that responsibilities to people and the environment are taken seriously. The policy should state the intentions of the business in terms of clear aims, objectives, organisation, arrangements and targets for all health and safety issues.
2.2.1 Legal duties concerning health and safety policy
Section 2(3) of the Health and Safety at Work (HSW) Act and the Employers’ Health and Safety Policy Statements (Exception) Regulations 1975 require employers, with five or more employees, to prepare and review on a regular basis a written health and safety policy together with the necessary organisation and arrangements to carry it out and to bring the policy and any revision of it to the notice of their employees.
This does not mean that organisations with four or fewer employees do not need to have a health and safety policy – it simply means that it does not have to be written down. The number of employees is the maximum number at any one time whether they are full time, part time or seasonal.
This obligation on employers was introduced for the first time by the HSW Act and is related to the employers’
reliance in the Act on self-regulation to improve health
Figure 2.3 Well-presented policy documents
2.3 Key features and appropriate content of an effective health and safety policy
2.3.1 Policy statement of intent
The health and safety policy statement of intent is often referred to as the health and safety policy statement or sometimes, incorrectly, as the health and safety
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u the production of various health and safety arrangements in terms of rules and procedures;
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u arrangements for the welfare of employees;
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u the regular review and, if necessary, updating of the health and safety policy.
The policy statement should be written by the
organisation and not by external consultants, as it needs to address the specific health and safety issues and hazards within the organisation. In large organisations, it may be necessary to have health and safety policies for each department and/or site with an overarching general policy incorporating the individual policies.
Such an approach is often used by local authorities and multinational companies.
The following points should be included or considered when a health and safety policy statement is being drafted:
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u the aims, which should cover health and safety, welfare and relevant environmental issues;
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u the position of the senior person in the organisation or company who is responsible for health and safety (normally the Chief Executive);
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u the names of the Health and Safety Adviser and any safety representatives or other competent health and safety persons;
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u a commitment to the basic requirements of the HSW Act (access, egress, risk assessments, safe plant and systems of work, use, handling, transport and handling of articles and substances, information, training and supervision);
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u a commitment to the additional requirements of the Management of Health and Safety at Work Regulations (risk assessment, emergency procedures, health surveillance and employment of competent persons);
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u duties towards the wider general public and others (contractors, customers, students, etc.);
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u the principal hazards in the organisation;
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u specific policies of the organisation (e.g. smoking policy, violence to staff, etc.);
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u a commitment to employee consultation possibly using a safety committee or staff council;
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u duties of employees (particularly those defined in the Management of Health and Safety at Work Regulations);
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u specific health and safety performance targets for the immediate and long-term future;
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u a commitment to provide the necessary resources to achieve the objectives outlined in the policy statement.
Health and safety performance targets are an important part of the statement of intent because:
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u they indicate that there is management commitment to improve health and safety performance;
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u they motivate the workforce with tangible goals resulting, perhaps, in individual or collective rewards;
policy. It should contain the aims (which are not measurable) and objectives (which are measurable) of the organisation or company. Aims will probably remain unchanged during policy revisions whereas objectives will be reviewed and modified or changed every year.
The statement should be written in clear and simple language so that it is easily understandable. It should also be fairly brief and broken down into a series of smaller statements or bullet points.
The statement should be signed and dated by the most senior person in the organisation. This will demonstrate management commitment to health and safety and give authority to the policy. It will indicate where ultimate responsibility lies and the frequency with which the policy statement is reviewed.
Figure 2.4(b) Responsibilities
Figure 2.4(a) Part of a policy commitment
The most senior manager is normally the Chief Executive Officer (CEO) or the Managing Director. It is the responsibility of the CEO, under the HSW Act, to ensure that the health and safety policy is developed and communicated to all employees in the organisation.
They will need to ensure the following:
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u key functions of health and safety management, such as monitoring and audit, accident investigation and training, are included in the organisational structure;
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u adequate resources are available to manage health and safety effectively;
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are set from the boardroom and it is here that the resources for health and safety and the associated standards can be agreed. This is the ‘top-down’
approach.
However, at times directors may be somewhat remote from the workplaces where most
accidents occur. In some world-leading businesses, objectives are set at the workplace by those who are exposed to the significant risks. These are then approved at higher levels and coordinated with other workplaces within the organisation. The overall aims may be set centrally and then the details organised at site or workplace levels. This is the ‘bottom-up’
approach and helps to achieve commitment from people at the workplace.
Whatever approach is used, it is vitally important to ensure that safety representatives and/or
representatives of employee safety are fully involved through consultation when setting the objectives and during their implementation. The objectives should be properly documented and may differ in detail at each functional level.
Health and safety objectives need to be specific, measurable, achievable, agreed with those who deliver them, realistic and set against a suitable timescale (SMART). Both short- and long-term objectives should be set and prioritised against business needs.
Objectives at different levels or within different parts of an organisation should be aligned so they support the overall policy objectives. Personal targets can also be agreed with individuals to secure the attainment of objectives of the organisation and an example of such objectives is given in Box 2.1.
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u they offer evidence during the monitoring, review and audit phases of the management system.
The type of target chosen depends very much on the areas which need the greatest improvement in the organisation. The following list, which is not exhaustive, shows common health and safety performance targets:
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u a specific reduction in the number of accidents, incidents (not involving injury) and cases of work-related ill-health (perhaps to zero);
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u a reduction in the level of sickness absence;
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u a specific increase in the number of employees trained in health and safety;
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u an increase in the reporting of minor accidents and
‘near miss’ incidents;
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u a reduction in the number of civil claims;
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u no enforcement notices from the HSE or Local Authority;
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u a specific improvement in health and safety audit scores;
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u the achievement of a nationally recognised health and safety management standard such as HSG65.
The policy statement of intent should be posted on prominent notice boards throughout the workplace and brought to the attention of all
employees at induction and refresher training sessions.
It can also be communicated to the workforce during team briefing sessions, at ‘toolbox’ talks which are conducted at the workplace or directly by email, intranet, newsletters or booklets. It should be a permanent item on the agenda for health and safety committee meetings where it and its related targets should be reviewed at each meeting.
2.3.2 Setting health and safety objectives
A health and safety plan is necessary to guide the organisation – setting out the objectives for a specified time period. The speed with which the objectives will be achieved will depend on the resources available, the current state of health and safety compliance and the policy aims of the organisation. If the policy is to achieve excellence, the objectives will need to be tougher than those wishing simply to comply with minimum legal standards. It is essential to decide on priorities, with the emphasis on effective and adequate workplace precautions that meet legal requirements. High hazard/
risk activities should receive priority. In some cases short-term measures may be needed quickly to
minimise risks while longer-term solutions are designed and implemented.
There are two basic methods of setting objectives within an organisation – from the top or from the bottom – and either has its merits. Many policies
Figure 2.5 SMART performance standards or objectives
plan and an accident and incident investigation system;
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Z establishing a reliable risk assessment process for COSHH;
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Z involving employees in preparing workplace precautions;
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Z completing all manual handling assessments by the end of the current year;
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Z providing a new guard for a particular machine;
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u specifications for management arrangements, risk control and workplace precautions; and
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u performance standards for implementing the health and safety management system, identifying the contribution of individuals to implementing the system (this is essential to building a positive health and safety culture).
Health and safety targets will need to be set so that the agreed performance standards are approached and met. Since there may well be many standards, it will be necessary to prioritise important standards and associated targets. These prioritised targets are known as Key Performance Indicators (KPIs). The targets must be realistic and a procedure known as