So how do we start writing documents for use by an occupational health nurse? Some possible steps are displayed in Figure 2.1 and described below.
STEP 1: Identify Priorities Agree list of policies and procedures (link with risk assessment)
Prioritise
Agree a lead person for each Issue interim guidance notes if necessary
STEP 2: Research Literature search Consultation with multi- disciplinary experts as necessary
STEP 3: Format Agree format Draft
STEP 4: Consultation Send out for comment Redraft/reconsult as necessary
STEP 5:
Documentation Control System Authorise
Implement under documentation control system
Figure 2.1 Framework for Producing Documents
Job-specific fitness standards
Health interview procedure and associated forms, e.g.
r Pre-employment health questionnaire form
r Food handlers’ questionnaire
r Health interview record form
r Request for information from former occupational health department form Sample letter requesting medical report
Consent form for medical report Letter to manager (pending GP reply) Pre-employment health screen report form Occupational health notes record sheet
Occupational health notes record continuation sheet Standard for referral to occupational health physician
Note: There may be other documents that relate to the pre-employment process depend- ing on the industry, e.g. health surveillance and immunisation policies, standards and procedures
Figure 2.2 Sample Section from an Occupational Health Operational Manual Showing Documents Relating to Pre-Employment Health Assessment
Step 1: Identify Priorities
Agree the list of policies, standards and procedures that need to be written, prioritise them and identify who will take the lead for each. A sample section taken from an occupational health operational manual (Figure 2.2) illustrates examples of documents relating to one area of occupational health practice. It may be that the senior nurse or occu- pational health physician takes the lead, or else a member of the team with specialist knowledge or a particular interest in a subject matter. It is important that the person who takes the lead controls the process, even though the work itself may be shared amongst others in the team.
A useful way of prioritising policies in occupational health nursing is to link in with risk assessments. Where a high risk is identified, doc- uments on how to control the risk should follow. Compliance with leg- islation will also help to prioritise the work. Where there are many con- flicting priorities, it may be necessary to produce some brief guidance notes on key subject areas that can be used to help promote consistency of service delivery while the more detailed policies and procedures are being written and authorised.
Step 2: Research
Carry out any necessary research. This may involve a literature review and asking experts in the field or related disciplines for their opin- ion. Examples of those whom you may wish to consult include other members of the occupational health team, health and safety experts,
Examples of external sources of information: Examples of internal sources of information:
The Internet, voluntary body publications, newspaper articles, professional journals, research projects, professional body publications, health service circulars or guidance notes, codes of practice, national guidelines, NICE and SIGN, legislation, case reports, clinical examples, systematic reviews, randomised controlled trials.
Accident statistics, incidents and near misses, complaints, client feedback, sickness absence data, staff turnover rates,
litigation/tribunals, PHI, ill-health retirements, internal projects.
Figure 2.3 Sources of Information in Relation to Step 2
occupational hygienists, environmental health officers, microbiologists, etc. Consulting and involving all concerned takes time but the benefits should not be underestimated, especially the benefit of involving other members of the occupational health team, who will often be able to make a significant contribution and are likely to be more committed to the final document.
The literature review should be broad. There are many sources of information; examples are given in Figure 2.3. Care needs to be taken to ensure that any information used is from a reliable source. The task can appear quite daunting. Clearly not every policy will require extensive research; however, the examples are intended to help the reader think about the sources of information that might, in the wider context, be relevant to their subject matter.
Step 3: Format
Agree the format for the documents (in line with the organisational house style if necessary) and be consistent in applying it. Attention must be paid to the wording of documents; statements should be clear and not open to misinterpretation (Figure 2.4).
We have already established that policies may at times come under scrutiny in industrial tribunals or courts and the wording of the policy may make a considerable difference to the outcome of a case. For ex- ample, the case of Angus Council v Edgely highlights the dangers of an employer’s failure to apply a policy on alcohol abuse to an employee.
Edgely was dismissed through the disciplinary procedure because of a longstanding alcohol problem. He was not given the opportunity to seek diagnosis and specialist help as he was supposed to under the council’s policy. The wording of the policy was crucial. It stated that where a per- son was found to have an alcohol problem he/she would (not may or might) be given the opportunity of assessment and treatment, pending which the disciplinary process would be suspended. The tribunal held that the council’s policy on alcohol abuse lay at the heart of the case and its failure to apply its own policy was a factor that entitled the tribunal
Title: Name of document.
Number: Number.
Policy Statement/Purpose: This is where the policy statement is made or the reason for the procedure is given; it may only need to be one or two lines or may extend to an explanatory paragraph.
Example: ‘This procedure describes the arrangements for managing a case of acute ana- phylaxis following vaccination.’
Example: ‘This policy explains how the organisation will comply with Department of Health Guidelines on protecting health care workers and patients against hepatitis B. It will ensure, so far as possible, that health care workers who may be at risk of acquiring hepatitis B infection during the course of their occupation are protected by immunisation and that as far as possible patients are protected against the risk of acquiring hepatitis B from an infected health care worker.’
Scope: To whom does this procedure apply? Is it just the occupational health nurses, or is it wider than that?
Example: ‘This procedure applies to all occupational health nurses who have demonstrated their competence to give vaccinations and have the appropriate written instructions.’
Example: ‘This policy applies to all health care workers who provide direct patient care.’
Definitions: Explain the terms used in the document and any abbreviations that you may wish to use.
Accountabilities: Explain who is responsible for what, e.g. the occupational health nurse/doctor’s responsibilities, the manager’s responsibilities, the employees’ respon- sibilities.
Policy or Procedure Detail: This is where the body of the policy or procedure is included and explains how the purpose will be achieved. It does not have to be lengthy and may refer to other documents.
Example: ‘All clinical staff will have their hepatitis B status checked on employment and will be offered vaccination as appropriate. See procedure no. X for details on safe admin- istration of vaccines.’
References: Give details of all references used. Include references to other in-house doc- uments as necessary.
Appendices: Attach any related documents or flow charts as appendices.
Name of Author: All policies should have the author identified; this may be by depart- ment, named individual or both.
Date: It is important to include the date and the revision number.
Authorised By: Include the name of the person who has approved the policy/procedure with signature and date.
Review Date Due: Most policies are reviewed annually, unless there is a specific reason to do so sooner.
Figure 2.4 Suggested Format for Writing a Policy or Procedure
to conclude that the dismissal was unfair. This case demonstrates not only the importance of the wording of the policy, but also the problems that can occur when a policy is not followed.
Step 4: Consultation
The documents should be sent out in draft form for consultation and comment, with a cut-off date for return of written comments. This is much better than telephone comments as the contributions can all be
kept and compiled for future reference. Consider the validity of com- ments received, take further advice if necessary and amend the doc- ument. Send the second draft out for comment, with a new deadline.
When the document is finalised it must be authorised and distributed.
All policies and related documents should be dated, and a version num- ber and the author’s name added.
Before becoming operational, policies will need to be authorised.
Some organisations may also want to authorise the related procedures but this will depend on local arrangements. Authorisation may be a simple matter of agreeing internally an implementation date. However, in many cases where the policy impacts on others in the organisation or where there are financial implications, ratification may be required by someone at a senior level such as a director, or by a committee with responsibility for an area of work, for example a health and safety committee.
All documents should be reviewed on a regular basis; annual reviews are standard unless circumstances necessitate a change sooner, for ex- ample the publication of new national guidelines that affect practice.
When documents are reviewed, even if no change to the text has been made, the date of the review should be added.
Step 5: Documentation Control System
It is important to ensure that there is a robust system in place for docu- ment control. There may already be established systems in place within an organisation. If there are no such company-wide initiatives, the oc- cupational health service must develop a local procedure. This applies regardless of the size of the occupational health service, but is especially important where nurses are working in a peripatetic environment or where there are multiple sites.
The system must ensure that when new policies, standards or proce- dures are properly issued, all superseded documents are withdrawn.
There should be nominated people responsible for reviewing docu- ments (usually the author) and distributing them. Within one national occupational health service, for example, the senior nurse required the nurses at each site to sign and return a simple document acknowl- edgement form stating that they had received an updated document and destroyed the old one. A master copy was retained at head of- fice for possible future reference, together with the distribution lists and signed acknowledgement forms. There are a number of computer- based systems now available to help with document control. These sys- tems usually incorporate a system for logging that documents have been received and also ensure that old versions of documents are re- moved and archived. It is useful to have whatever system is used ex- plained in the foreword in an occupational health operational manual (Figure 2.5).
1. Introduction
This manual has been produced by ... All policies and procedures have been approved by the team of occupational health nurses. The aim is to provide guidance to occupational health nurses and a consistent approach across the service.
2. Forms and Checklists
Forms and checklists have been provided where appropriate and may be copied and used on all sites. The pre-employment health questionnaire forms are available from ...
3. Issue, Revision and Control
Controlled copies of the manual are numbered and a register of the holders is retained by ... Revisions and re-issues to the manual are distributed by ... All regis- tered holders of the manual are responsible for updating the manual assigned to them and for destroying obsolete copies.
4. Transmittal Note
All amendments will be forwarded to each registered holder under the control of a transmittal note system. The holder will be responsible for returning the transmittal note to ..., confirming safe receipt and that the amendments have been made to the manual.
5. Review
The Occupational Health Policy and Procedure Manual will be reviewed on a quarterly basis by ... to ensure that the information it contains is relevant and up to date.
6. Improvements/Suggestions
Please contact ... if you have any suggestions for improvement of this manual or if there is a subject that has not been covered.
Figure 2.5 Sample Foreword from an Occupational Health Policy and Procedure Manual
It is important that master copies of old policies, standards and pro- cedures are kept, although they need to be clearly dated to show when they have been taken out of use to ensure that they cannot accidentally be confused with the current document. Evidence of old documents may be required in tribunals or courts. Staff who make claims against their employer may do so several years after an injury, and the occupational health service may be required to produce evidence of practice at the time. For example, a manual handling policy which precedes the Man- ual Handling Operations Regulations 1992 may be very different from the type of policy in place today, but may have been acceptable practice with the knowledge available at the time. The court, however, will be able to make that judgement only by seeing the evidence of the working arrangements at the time of the injury.
IT systems are used to distribute documents, either through access to shared drives or through e-mail. While this is a quick and effective way of distributing information and enables updates to be incorporated easily, it is important to ensure that every member of the workforce who needs a document has computer access and the necessary computer skills to enable them to read it. It is also important to make such policies read- only, so that only authorised individuals can change the text. Computer policies must also be stored for possible future reference.