Making Your Health and Safety Policy Statement Effective

The HSE divides a health and safety policy into three parts:

• Statement of intent: The organisation’s overall approach, commitments and aims for health and safety. It should be signed and dated by the employer or the most senior person in the organisation and reviewed regularly.
• Responsibilities: The names, positions and roles of those with specific health and safety responsibilities, including overall and day-to-day responsibility.
• Arrangements: The practical measures used to put the policy into effect, such as risk assessment, employee training, consultation and emergency procedures.

Together, these sections explain what the organisation intends to achieve, who is responsible for each area and how its commitments will be carried out in practice.

Performance benchmarking compares an organisation’s results and working practices with its previous performance, internal targets or similar organisations. It can help identify areas for improvement, but it should be used alongside direct monitoring of whether risk controls are working.

Useful measures can include:

• Accident, injury and work-related ill-health trends
• Near misses and dangerous occurrences
• Findings from workplace inspections and audits
• Completion of corrective actions and planned maintenance
• Training, competence and supervision checks
• Completion of required health surveillance and any necessary follow-up

Trade associations and other professional organisations can provide useful external data and examples of good practice. The Health and Safety Executive also provides guidance on monitoring health and safety performance. However, external comparisons should supplement, rather than replace, assessment against the organisation’s own risks and control measures.

Once the policy has been written, the employer must bring it and any subsequent revisions to employees’ attention. Effective communication should go beyond simply distributing or displaying the document. Employees should understand the responsibilities and arrangements relevant to their work. The organisation should then monitor whether the policy is being implemented effectively and remains appropriate for its activities and risks.

There are many factors that justify regular review, including changes to:

• Workforce changes, such as employees joining, leaving or changing roles
• Organisational changes, such as restructuring or acquisitions
• Changes to work activities, processes, equipment or substances
• Changes to relevant legislation or HSE guidance
• Findings from monitoring, consultation, accidents or near misses

By monitoring and reviewing the efficacy of your health and safety policy statement, you can reduce the risk of being in breach of health and safety law. A prosecution or improvement notice should prompt the organisation to review its policy and arrangements and examine whether they are being implemented effectively.

Regular reviews can help an organisation assess whether its health and safety arrangements are being implemented effectively and identify areas for improvement.

Reviewing the policy with employees can improve communication and highlight problems that managers may not see. Employers are also legally required to consult their workforce on health and safety matters. Depending on workplace arrangements, this may involve recognised trade union safety representatives, direct consultation with employees or elected representatives. Consultation should continue throughout the planning, implementation, monitoring and review of health and safety measures.

Policy reviews can improve communication, clarify supervisory responsibilities and identify training or development needs. Effective health and safety management may also reduce costs associated with accidents and work-related ill health and support the organisation’s reputation.

Risk assessments must be suitable and sufficient and reviewed if there is reason to suspect they are no longer valid or following a significant change to the work or circumstances they cover. A review may identify problems that need to be addressed by updating control measures, existing health and safety arrangements and, where appropriate, the policy.

The health and safety policy should be reviewed regularly and whenever significant changes, monitoring findings, worker feedback or lessons from accidents and near misses indicate that it may need updating.

Unfortunately, health and safety policies are not always effective. Some of the pitfalls that employers can fall into when implementing a health and safety policy include:

• Insufficient resources – A lack of time or funds can make implementing a company health and safety policy difficult
• Lack of communication – Often, employees don’t know what is in a health and safety policy statement due to poor communication
• Lack of commitment – In some cases, senior management does not commit to implementing the policy adequately, for example, when placing profits above health and safety
• Low involvement – Senior management may be committed and provide resources, but they must also be involved to provide leadership
• Disregard for employee health and safety concerns – If employees raise problems but they’re ignored, the implementation process can quickly break down
• Lack of ownership – A tendency in the policy to shift all responsibility onto the employee and away from management
• Insufficient maintenance of equipment – Maintenance arrangements that fail to keep equipment in safe working order
• Inadequate health and safety procedures – Poor implementation of safe systems of work and other arrangements
• Inadequate performance monitoring – Without appropriate performance measurement, it is harder to identify where controls and systems need improvement

HSE’s policy template can provide a useful starting point for identifying gaps. However, the policy and its arrangements should reflect the organisation’s size, structure, activities and risks, so not every item below will apply to every workplace. Responsibilities must be clear, but one person may be responsible for more than one area.

• Is there a clear statement of commitment to health and safety?
• Are health and safety roles clearly allocated to named individuals or positions at the appropriate levels?
• Does the health and safety policy statement say how it will be implemented, reviewed and on what timescale?
• Is the statement of intent signed and dated by the employer or the most senior person in the organisation?
• Have employees or their representatives been consulted in good time and given an opportunity to raise concerns and contribute?
• Have the policy and any revisions been brought to employees’ attention, and do employees understand the responsibilities and arrangements relevant to their work?
• Does the policy explain how employees or their representatives will be consulted during the planning, implementation, monitoring and review of health and safety measures?
• Where relevant to the organisation’s activities and risks, are responsibilities clearly allocated for areas such as:
  • Fire safety arrangements
  • First aid
  • Safety inspections
  • Risk assessments
  • Health surveillance
  • Health and safety training
  • Inspection and maintenance of work equipment
  • Accident reporting and investigation
• Are there suitable arrangements for managing the significant risks identified through risk assessment?
• Does the health and safety policy statement explain how risk assessments will be carried out?
• Where plant or work equipment is used, does the policy cover the arrangements for its safe use, inspection and maintenance?
• Are emergency procedures detailed?
• Are there arrangements for communicating health and safety information within the organisation?
• Is health and safety training covered?
• Does the health and safety policy statement explain how health and safety matters are to be supervised?

To remain effective, a health and safety policy should be clearly communicated, implemented, monitored and reviewed so that it can be updated when required.

When supported by suitable risk controls and effective implementation, a health and safety policy can help prevent harm and support efficiency and quality. Managers and supervisors can undertake the IOSH-approved Managing Safely e-Learning course to strengthen their knowledge of risk assessment, risk control, incident investigation and performance measurement.