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Employers have duties to their employees under health and safety legislation. One of these duties requires them to have a policy for managing health and safety.
An effective well-thought-out health and safety policy is an essential part of health and safety management and compliance. If there is no policy, or it is inadequate, this can be a sign of poor health and safety within the workplace.
If there is not an effective management system that enables the policy to be successfully implemented, this can also be an indication of poor health and safety.
Workplaces with poor health and safety can cost individuals, businesses and society as a whole.
According to the Health and Safety Executive (HSE), every year:
- Millions of working days are lost due to work-related illness and injury.
- Thousands of people die from occupational diseases.
- Around a million workers self-report suffering from a work-related illness.
- Several hundred thousand workers are injured at work.
- A worker is fatally injured almost every working day.
The recent HSE statistics highlight these costs in further detail. Most work-related injuries and illnesses can be traced back to poor and ineffective health and safety management.
A robust policy is at the heart of good health and safety, which can bring many benefits to businesses. It can improve health and safety performance, which can reduce the risk of accidents and illnesses.
Fewer accidents and illnesses can reduce costs and can increase productivity and employee morale. It can lead to better standards of health and safety throughout the business. Managers and employees will also be more inclined to cooperate with an employer who is striving to keep them safe and healthy.
This article will cover what a health and safety policy is, who needs one, how to write one and what happens after it has been written.
What is a health and safety policy?
A policy can be described as “a set of ideas or plans that is used as a basis for making decisions, especially in politics, economics, or business” (Collins English Dictionary). Employers will have policies for different areas of the business, such as finance, payroll, human resources and quality. These policies underpin other procedures and systems, and a health and safety policy is no exception.
According to the HSE, a health and safety policy sets out a business’s general approach to health and safety. It explains how an employer will manage health and safety in their business, and should clearly state who does what, when and how. It is an essential document that sets the direction and vision of health and safety and demonstrates a commitment to preventing harm to employees.
A health and safety policy, along with relevant procedures and processes, is a vital part of a business’s health and safety arrangements. In larger businesses, these arrangements are often part of a formal management system. The HSE’s guidance document managing for health and safety HSG65 provides details on how employers can meet their legal obligations. It also includes a section on health and safety policies (part 3: delivering effective arrangements). For smaller businesses with simpler operations, the HSE has a section on preparing a health and safety policy on their website.
Do I need a health and safety policy?
Yes, all employers are legally required to prepare a health and safety policy and revise it where appropriate. The legal requirement for a policy is part of an employer’s general duty towards their employees. It comes under section 2(3) of the Health and Safety at Work, etc. Act (HSWA) 1974.
To summarise, you must:
- State your general policy on health and safety.
- Detail the organisation and arrangements for carrying out the policy.
- Bring the policy to the notice of all of your employees.
- Revise your policy where appropriate. Any revisions must also be brought to your employees’ attention.
Your policy must also be written down if you have five or more employees. If you have fewer than five employees, you can communicate your policy verbally, which is an exception that comes from the Employers Health and Safety Policy Statements (Exception) Regulations 1975.
However, it is always advisable to have a documented policy. That way, you can provide evidence that you have met your legal duty, and it will show your commitment to health and safety management within your business. A written policy can also be useful when making and tracking any changes. You must ensure that your employees and their representatives are made aware of the policy and any revisions.
Even though the requirement for a policy relates to an employer’s general duties to their employees, it can also include others who may be affected by the business’s operations, e.g. contractors, visitors, agency workers and members of the public. Whether these are included, will depend on how your risks could affect others and to what extent.
The Management of Health and Safety at Work Regulations (MHSWR) 1999 (regulation 5) also relates to the health and safety policy. Employers must ensure that they have appropriate arrangements in place to control health and safety risks. A written policy is also part of this duty.
For the health and safety policy to be successfully implemented, an effective management system is necessary. It is at your discretion whether you want to go down the formal management system route. There should at least be a health and safety manual containing the policy and associated procedures, rules and processes. You may even choose to integrate your policy and systems with other areas, such as environmental and quality.
If enforcement authorities, such as the HSE or Local Authority, visit your premises, they will likely ask to see your health and safety policy. If you do not have a policy, or if it is inadequate for your business, you could face enforcement action and prosecution. Why not learn more about health and safety legal requirements and enforcement by taking our Health & Safety Level 2 Course? You can also access our article that provides further insight into occupational health and safety.
How do I write a health and safety policy?
Writing a health and safety policy may seem like a daunting task, but it is not too difficult once you know the structure and the content that is required. It does not have to be complicated, overly lengthy or time-consuming.
The important thing is to make your policy specific to your business and its operations. Some employers have been known to copy and paste their policy from other sources, which is unacceptable and is likely to be non-compliant with the law. Your policy must reflect what you do.
It is also vital that leadership is involved with the policy. There have been many instances of health and safety practitioners or consultants writing the policy, and then it is just signed by the person at the top without any involvement whatsoever.
Enforcement authorities are putting more emphasis on health and safety leadership from the top of the business. Therefore, senior staff and board members, along with other employees, should be involved in some aspects of the policy’s creation.
There is no specific requirement for the policy to be of a certain size, and there are no rules for how it should be set out, but it should be proportionate to the nature of your business and its risks.
Most policies will have the following three main sections:
- Part 1: Statement of intent.
- Part 2: Responsibilities for health and safety.
- Part 3: Arrangements for health and safety.
Part 1: Statement of intent
A health and safety policy should start with a statement of intent, which is also known as the health and safety policy statement.
This part of the policy should contain a statement of your commitment to meeting legal requirements and health and safety management. It should detail the business’s aims and objectives regarding health and safety.
You must be able to achieve the aims of the policy, and your objectives should be SMART:
This section must not be confused with the health and safety policy. It is part of the policy, but it is not the policy by itself. Unfortunately, some businesses produce a statement of intent and think that it is complete. Although the statement is of vital importance, there is much more to a health and safety policy.
The statement of intent must be signed and dated by the most senior person in the business. In smaller businesses, it is usually the managing director (MD), and in larger ones, it is often the chief executive officer (CEO). Having the most senior person sign the policy will demonstrate your commitment and will give authority to the document.
Part 2: Responsibilities for health and safety
This part of the policy should detail the names, positions and duties of those who have specific responsibilities for health and safety within the business.
It could include those responsible for:
- Policy setting, e.g. directors and senior managers.
- Day-to-day operations and policy compliance, e.g. middle managers and supervisors.
- Advice, accident investigation and inspections, e.g. health and safety advisers and officers. It may include an external health and safety consultant if one is used by the business.
- Representing employees in health and safety matters, e.g. trade union safety representatives or representatives of employee safety.
- Specialist services, e.g. occupational health.
- First aid and fire safety, e.g. first aiders and fire marshals.
The above are examples and are not exhaustive. Employees also have responsibilities under health and safety legislation, such as the HSWA and MHSWR. Therefore, their responsibilities should be included in this section.
Some smaller businesses may only have one or a few people with health and safety responsibilities, which can be detailed in the policy as a simple list. Larger organisations may use an organisation chart to demonstrate responsibilities, hierarchies and reporting lines. It is up to you on how you demonstrate who has what responsibilities.
It is vital that all those who have duties are made aware of what is expected of them. They must also agree to their responsibilities and have the necessary resources to be able to fulfil their duties.
Part 3: Arrangements for health and safety
The last part of the policy should detail the practical arrangements you have in place for managing health and safety risks within the business.
These arrangements should show how you will meet the aims of your health and safety policy from your statement of intent. It is, therefore, crucial that your arrangements can meet your policy aims and that your aims are achievable.
The arrangements section should be larger than the rest of the policy and should cover relevant health and safety topics under different headings.
Some examples of the topics that are covered in this section include:
- Specific hazards and risks, e.g. manual handling and hazardous substances. COVID-19 should be included.
- Risk assessments.
- Safe systems of work.
- Accident, incident, near miss and illness reporting.
- Occupational health.
- Plant and equipment.
- Personal protective equipment (PPE).
- Information, instruction and supervision.
- Training and competence.
- Consultation with employees and their representatives.
- Welfare facilities.
- Emergency procedures, such as fire evacuations and first aid.
The topics that will need to be included will depend on the nature of your business and its complexity, size and risks. You will also need to think about applicable health and safety legislation and how your arrangements will meet your legal obligations.
Larger businesses with higher risks are likely to have a longer arrangements section, which will often be in a formal management system format. Smaller businesses may have specific procedures, systems and processes together in a manual.
It is at your discretion on which format you use. If you decide on a more formal management system, you could look at getting it certified, which could enhance your reputation. ISO45001 is a recognised international standard for occupational health and safety management systems, which many companies are certified against.
It is better if the health and safety policy is written by a person who works within the business rather than someone external. Although, you can use a competent health and safety consultant to assist you if there is insufficient expertise within the business, you should still ensure that you involve those internally in the creation of your policy.
What should I do once I have written it?
Once the health and safety policy has been completed, it should be signed and dated by the most senior person in the business. It should be the person that is ultimately responsible for the policy and health and safety.
A health and safety policy is a ‘live document’ and must be visible within the business. There have been many instances where a policy has been written and then it is not seen again until the next review. If the policy is treated in such a manner, then this is an indication that there is a poor health and safety culture, which will negatively impact the business at some point.
A health and safety policy should be regularly:
- Reviewed – There is no specified period for a policy review. However, it is recommended that it is reviewed at least annually. It will require a more frequent review if there are any significant changes within the business.
- Monitored – The policy should be monitored so that it remains effective. Monitoring can include audits, inspections, review of accidents and near misses and spot checks. If there are any issues with the policy’s effectiveness, and you are not meeting your objectives, it should be reviewed.
The policy needs to be brought to the attention of your employees and their representatives. You may also need to make visitors, contractors and temporary workers aware where this is relevant.
It is advisable to display your policy in a prominent position, e.g. on a staff noticeboard or shared computer programs so that it can be referred to by relevant persons.
If it is a shorter document, you can give employees a copy. It is also good practice to go through the main points of the policy in inductions and training. If there are any changes to the policy, this should also be communicated.
A robust health and safety policy that is implemented successfully will promote good health and safety, which will bring many benefits to the business. Not only will it improve health and safety performance, but it will also keep your business on the right side of the law.
It is a legal requirement for every employer to have a health and safety policy. Therefore, as a minimum, you must cover the legal requirements when developing and implementing your policy and arrangements. It is always best to go above the minimum legal requirements, as this will demonstrate your business’s commitment to health and safety.
You should always consider whether you can achieve the aims of your policy. If you have said that you will do something, then you must be able to carry it out. Otherwise, it will bring about questions regarding the validity of your health and safety policy and management. Your policy should be specific, and your aims achievable.
You can use our template to assist you in creating or reviewing your health and safety policy. If you use this template, you must ensure that you make it specific to your business.