The occupational health & safety policy (clause 5.2 ISO 45001:2018)- A brief introduction

Role of Health & Safety Policy:

(What is the role of Health and Safety Policy ?)

The purpose of setting a health and safety policy is to ensure that:

It Clearly demonstrate management commitments. (the involvement of senior management in H&S issues is evident to all stakeholders.)
It protects the business/organisation from potential Legal Action.
Policy provides a clear framework for the delegation of decision-making towards H&S.
everybody associated with the organisation becomes aware of its H&S aims and objectives and how they are to be achieved;
the performance of the organisation is enhanced in areas other than H&S;
There is effective personal/workforce development of the workforce;
Business efficiency is improved throughout the operation; and
Policy set out the Legal compliance , regulations & OH&SMS requirements .
Policy sets out the organisation’s aims/objectives.
Policy identifies who is responsible for achieving these aims. (It clearly outline Employer and Employee accountability and responsibility for workplace H&S.) (It shows who does what, when, and How.)
Policy states how the aims are to be achieved.

What is policy ? - (it is intentions and direction of an organization , as formally expressed by top management.)

Policy is an important written document.
Policy is the foundation stone for good H&S management in an organisation.
Policy sets out the organisation’s aims.
Policy identifies who is responsible for achieving these aims.
Policy states how the aims are to be achieved.
Policy is specific to each organisation’s requirements and appropriate to its size and the nature of its activities.
Policy should be communicated and readily accessible to all persons at their place of work & to be made available to relevant external interested parties, as appropriate.
Policy should be reviewed for continuing suitability.
A successful and effective H&S policy must be clear and easy to understand, concise, clearly written, dated & made effective by the signature and detail the lines of responsibility for each aspect or arrangement.

What is the scope of H&S policy?

(Scope means Policy applicable to upto what area , business activity, nature of work ,upto where it is relevant or applicable)

The scope of your policy will be individual to your business requirements (Different business may lead to different types of scope).

Policy overseeing the entire group or business, or specifically for each premises or location.
Policy focus how H&S will be implemented and carried out in your business/organisation.
Policies cover extensively health and safety considerations,
It should also be adaptable.
As company/organisation develops or evolves, i.e. any processes or working practices may change, so Organisation must be able to edit /review /update /amend the policy quickly, to reflect business changes or changes to your risk assessment /management .

H&S performance Targets in H&S Policy: What are the targets to be set in H&S Policy?

The H&S policy consists of various aims or objectives to achieve the good performance of the health and safety management system. Health and safety performance targets are an important part of the Health & Safety Policy Statement as they indicate management’s commitment to continually improving health and safety performance, as well as motivate staff to achieve set goals.
The type of health and safety targets chosen will very much depend on the areas which need improving most in your organisation.

Some common H&S performance targets may be included into H&S Policy :

Reduce/To Achieve Zero Accidents
To reduce the incidence rate of fatal and major injury accidents/ill-health, near-miss
Specific reduction in the number of accidents, incidents, First Aid cases and cases of work related ill-health (perhaps to zero);
Zero Prosecutions
Reduction in sickness rate and absenteeism,
Reduction in Staff turnover rate
Reduction in compensation claims
Improve/Increase reporting of near misses, minor accidents, Dangerous occurrences
Increase numbers of workers trained in H&S ( Conduct more awareness programmes, motivational programmes for workers)
More Number of Consultation with workers
Reduction in unsafe act ,
Reduction in unsafe condition
Increase in number of risk assessment
Provide appropriate Welfare provisions,
Provide PPEs for all workers including contractor.
Specific improvement in H&S audit scores;
Reduce the number of working days lost per day
Reduce the number of LTI cases
Reduce the number of Man days lost
Increase in Safety Observation reporting, inspection, safety survey, Safety campaign (more numbers of Safety observations )
Increase in Management Safety walks
Effective Hazard and Risk Management
Conduct HIRA (Hazard Identification and Risk Assessment)
Increase the number of Risk Assessment
Provide the safe working system for high risk activities
Provide the SOP for non-routine activities
Develop more SSW (Safe System of Work)
Develop more PTW (Permit to Work)
Improve the Health Surveillance
More number of Medical Check up .
Increase of frequency of Periodic monitoring
Reduction in the number of civil claims
No Enforcement notices from the Enforcement Authority.
Achievement of a nationally recognised H&S management standard such as HSG65 or ISO 45001.
Reduction in Bullying cases
Reduction in harassment cases,
Reduction in physical and verbal violation cases
Conduct & Complete the investigation in limited time
Continual improvement at site
Review of H&S Performance
Number of mock drills
Benchmark-
Increase in Reporting of unsafe act/condition at site
CAPA implement ( Corrective action and preventive action)

Note 1: Generally, all leading and lagging indicators are considered in the targets.

Note 2: In the annual review of H&S performance, all these targets to be reviewed by the management.

Note 3: Any specific targets can be considered as per the nature and characteristics of the organization.

Why have a written H&S policy?

Meet Legal compliance (ILO) - ( As per HSWA 1974 -If you have 5 or more employees you must have a written H&S policy statement, setting out how you manage H&S in organisation.)
Demonstrate that your business is addressing its H&S obligations.
Show that your business is committed to working within a set of H&S principles.
Meet management-systems standards (ILO-OSH 2001 ,ISO 45001);
Clear communication;
Continual improvement;
Ensures that employers are consistent in their decisions.
A clear framework for the delegation of decision-making;

Key Elements of a H&S Policy:

Health and safety policy is found in three parts:

Part1: General Statement of Intent -What is going to be done.
Part2: Responsibility section- Who is going to do it.
Part3: Arrangements -How they're going to do it.

Part1: Statement of Intent (General statement of intent) (Focus on-what to be done and achieved )

A health and safety policy statement sets out how you manage health and safety within your workplace.

The statement of intent should show the organisation’s stance and commitment to the health and safety of its workers.
It should be signed by the managing director and placed at the front of the policy, as well as being displayed where employees work.
Organisations with different workplace locations find it easier to express their management philosophy in an overall statement.
A more detailed Statement of Intent and Health & Safety Policy can then be written and issued at local level.

What should be cover in statement of intent?

The most effective statements of intent contain short, easily readable and positive statements. These should state:

The organisation’s risk management aims and objectives
The personal responsibility of the employees
A pledge to maintain health and safety, in line with the Health & Safety At Work Act
The creation of emergency procedures
A commitment to undertaking risk assessments
The frequency at which the policy and statement will be reviewed (at least annually)

Identify the principal hazards to employees and others affected by your work, and control the associated risks adequately.
Meet the basic Legal requirements of the Health and Safety at Work etc Act – namely to maintain, so far as is “reasonably practicable“, healthy and safe working conditions. For example, ensuring a safe plant, safe access and egress, safe equipment, safe systems of work, etc.
Meet the additional health and safety requirements of the Management of Health and Safety at Work Regulations (MHSWR) 1999, including conducting risk assessments, developing emergency procedures and providing health surveillance.
Regularly review – and, if required, revise Health & Safety Policy.
Meet specific immediate and long-term health and safety performance targets.
Resources to achieve the objectives outlined in the Health & Safety Policy Statement.

Who will sign the policy, and why?

Policy to be signed by top management (MD, CEO, etc.) because they are ultimately responsible & accountable for all commitments towards H&S.

Why is a date required on the H&S policy?

H&S Policy has the date, so it tells us when the current statement was prepared and provides a reference point for review.

What are factors to be considered while setting the H&S Policy?

(What are the factors to be considered while setting the policy objectives?)

The following Consideration or Factors to be seen while setting H&S Policy / Policy objectives:

Who is going to set the policy - mostly senior management (MD/CEO etc.)
How the objective is set at different functional level - giving personal targets,
Legal requirement – Legal standards (Regulations/Rules /Acts)to be followed,
Technological option - availability of technology available to meet the goals,
Financial operation - there should be no conflict between business requirement and financial cost ( e.g. Safety Budget),
Hazard and Risk - it would be relevant for the organization significant hazard & risk, issues are considered in the H&S policy , should not address trivial(insignificance) matters only,
Views of the interested party - consultation is very important and should be discuss with functional units.

Unfortunately, Health & Safety Policy Statements that make vague, sweeping promises and pledge to achieve the impossible (such as “We will use every means possible to prevent accidents”) can still be found by the money hunger businesses. Instead, your employer’s statement should make specific, realistic commitments.

What do you mean by SMART objectives?

It is an acronym formed by combining the five letters:

Specific - clearly defined, precise.
Measurable- towards a target, quantified.
Achievable - it can be done.
Realistic - within timescale, and resources,
Time-bound - deadline, timescale.

Part 2: Responsibilities for H&S : (earlier used be known as Organization section) (now known as Responsibility Section) (Focus on- who will do what for implementation of H&S-means Roles and Responsibilities are defined /written in this section)

A diagram of the organisation’s hierarchy in relation to decisions made about health and safety and policy amends should be included.
This may differ from the usual management structure. For example, if a member of middle management has the appropriate training to properly identify risk and provide advice on technical aspects of safety management, they may appear on the health and safety hierarchy above a member of senior management. If a committee board is used make decisions about risk and safety, they should appear on the structure also.
All employees should have a competent person above them, to offer health and safety advice and management, and the person who makes the final decision on risk management issues should appear at the top. This person should also be the one to sign the statement of intent.

Part3 of policy - Arrangements for H&S

(Practical Arrangement for making Policy to work)

(Arrangement Section focus - How the policy will be implemented?)

Give details of the practical arrangements organisation have in place, showing how organisation will achieve its H&S policy aims.

For Example:

How do you assess the Risk at workplace?
How do you manage the Manual Handling activity?- Implement control measure etc.

This could include, for example, doing a risk assessment, training employees and using safety signs or equipment.

Arrangement section describes how things are done.
Arrangement section provide the detailed description of policies &procedures.
It is usually a long document.
It is often separate from the policy document.
it is unique to each organisation.
For Example - HSE Plan

The arrangements section of the H&S policy gives details of the specific systems and procedures used to assist in the implementation of the policy statement.

This will include H&S rules & procedures and the provision of facilities such as a first-aid room and washrooms.
It is common for risk assessments ( E.g. including those for hazardous substances, manual handling and PPE assessments etc.) to be included in the arrangements section, particularly for those hazards referred to in the policy statement.
It is important that arrangements for fire & other emergencies and for IITS are also covered.
Local codes of practice (e.g. for fork-lift truck drivers) should be included.

Following list covers the more common items normally included in the arrangements section of the H&S policy:

Employee H&S code of practice;
accident and illness reporting and investigation procedures;
emergency procedures,
first-aid arrangement & procedures;
fire drill procedure;
procedures for undertaking risk assessments; control of exposure to specific hazards (Examples- noise, vibration, radiation, manual handling, hazardous substances, etc.);
machinery safety (including safe systems of work lifting and pressure equipment);
electrical equipment (maintenance and testing);
maintenance procedures;
PTW procedures;
Use of PPE & special PPEs ;
monitoring procedures including H&S inspections and audits
Procedures for the control and safety of contractors & visitors
provision of welfare facilities;
training procedures and arrangements;
catering and food hygiene procedures;
arrangements for consultation with employees;
terms of reference and constitution of the safety committee
Procedures and arrangement for waste disposal.

Why should you update your health and safety policy?

What are the reasons to be considered to reviewing the H&S Policy ?

What are the factors to be considered to review the H&S Policy?

What are the circumstances to be considered to review the H&S Policy ?

Example of Health and Safety Policy ( Reference : www.hse.gov.uk)

Various reasons for review the H&S Policy :

Significant Changes in: Key personnel, and the roles of the person.- - - -- - ( new MD/CEO etc.)
Significant Changes in: Management/organisational structure.- - - - - - - - Manager are promoted - - - - - - - - Managers are transferred- - - - - - - - Manager are retired- - - - - - - - New managers are recruited
Significant Legal Argument
Changes in: Legislation.- introduction of new legislation
Changes to H&S standards
Changes to H&S Guidance
Changes to H&S Rules & Regulation
H&S legislation mandates to review the policy
Modifications to the existing site
Significant Changes in: Ownership.
Significant Changes in Technology.
- - - - -introduction of new plants and machinery in the workplace.
- - - - - -(e.g. purchasing of new Industrial vehicles like cranes etc.)
Significant Changes in: Processes
Significant Changes in Method/ Methods statement
Changes to the workforces
- - - - - - - - ( New Recruitment has taken place)
- - - - - - - - Staff Turnover increased suddenly due to H&S issues
Changes in Working Patterns
Changing in working Practices
Significant Changes in Safe System of Work / SOP/ Methods Statement
Health & Safety representative request
Risk Control measure methodology has been revised.
- - - - - - - - - (New Hazards/Risk developed )
- - - - - - - - - Risk Assessment indicate the policy is no longer effective
Result from Accident/Incident investigations indicates that policy is no longer effective.
Due to : Major Incident/Accident occured
Due to - Notifiable incident/Accident occurd;
Due to : Enforcement action(order) received / On advice by enforcement bodies,(Results of enforcement action)
Due to – Formal Order received by the organisation
- - - - - Prohibition Order received
- - - - -- -Formal Warning received
Labour inspector told to review the policy
After: an audit ,where policy becomes ineffective ( Auditor recommendation)
Audit indicates a deficiency in a risk control measure.
After : worker consultation output
After : worker complaints.
After : Passage of time, e.g. annually.
- - -- - - - - ( sufficient time has elapsed since the previous review, e.g Last time policy was updated in 2015)
Any (Geographic )Location changes ( which have impact on H&S )
H&S Performance has fallen below the occupational group’s benchmark or Targeted H& S performance
Existing policy has become outdated
- - - - Policy was Prepared in 2015

Objectives of the Policy not been met-SMART objective are not met

Communicating the H&S Policy:

( using Verbal + written+ Graphic methods for effective communication of H&S Policy )

Employers must bring the policy to all employees attention. This can be done by various ways :

Displaying it on Notice Boards
Display in Break rooms
Introducing it on induction and training session - - - - - - (During the Regular Training session - - - - - - ( During Induction and refresher trainings)( And maintain the training record to ensure that all workers have received the awareness training about the Health and safety policy. )
During the team briefings
During tool box talks (TBT)
By Using newsletters
By Posters
Build into safe systems
Mentioned into the Codes of practice (CoP)
Managers to discuss with workforce about H&S Policy
Health and Safety Committees
Company Website/ intranet (Displaying Policy)
During Safety talk,
During Departmental Safety meetings - - - - - - (e.g. One to One meetings, Staff meetings )
Emails ,
Safety Booklets,
Hand out distribution of Hardcopies of new policies
etc.

Ineffectiveness of Health & Safety Policy

( Ineffectiveness means Policy exist/drafted/prepared by the organisation but not followed /implemented and policy acts as a piece of Paper)

A health and safety policy statement must be more than simply a piece of paper in a file.

A company health and safety policy must be a living, breathing document that is dynamic and can be constantly adapted to changes in the workplace and/or changes in legislation.

It becomes ineffective when:

Not able to prevent the injuries, accidents, ill-health.
No management commitment or lack of leadership (lack of senior management involvement in H&S)
No annual objectives (if available , but no SMART target considered)
H&S not given enough priority
Insufficient resources provided (No resources provided)
- - - - - - - - - Minimal resources are made available for the implementation of the policy(e.g. Inadequate PPEs)
Lack of communication
- -- - Personnel (Workforce, Managers , Supervisors )
- - - - - They do not understand aims/objectives
-- - - - - - - The statements in the policy and the H&S priorities are not understood by, or properly communicated to, the workforce;
Too much emphasis on employee/worker responsibility
No consultation arrangement
No measurement & no review of H&S performance,
No monitoring provision,
- - - - - - - ( lack of H&S monitoring procedures)
No review & updating mechanism of Policy.
Lack of Ownership
- - - - - -- Management unaware of their role & responsibilities
No training of management in their responsibilities.
Not able to reduce loss costs and accident related liabilities
Not considered the legal requirements
- - - - - - ( Not able to comply legal requirements)
Not able to identify the significant hazards & risk and Safe working condition
Not able to contribute to business H&S performance by preserving the human & physical resources
There is no connection between Work quality and H&S Policy.
Too much emphasis on rules for employees and too little on management policy.
- - - - - - - - (Disregard for workers H&S Concerns)
Not developed any Safety procedures , rules , guidelines /SSW/SOP/SWP/ Risk Assessment ,

Effectiveness of H&S Policy ( Effective approach of H&S Policy) ( Effective implementation of H&S Policy) :

Effective H&SMS demands comprehensive H&S policies which are effectively implemented and which are considered in all business practice and decision making.

Organizations achieving high standards of H&S develop policies that recognize:

Able to prevent the injuries, accidents, ill-health, loss prevention
Commitment or effective leadership
Annual objectives ( SMART target considered)
H&S given enough priority
Sufficient resources provided
Personnel (workforce, managers , supervisors ) understand aims
Employer responsibility & consultation arrangement
Measurement of performance, monitoring provision, review mechanism of policy.
Management aware of their role & responsibilities
Training of management in their responsibilities.
Considered & fulfilling the legal requirements
Considered the significant & systematic identification of hazards & risk and safe working condition and risk control Make sure that employees have the necessary competency to carry out the tasks expected of them and provide appropriate and adequate health and safety training.Consult employees on health and safety issues, possibly using a safety committee, and provide them with the necessary information, instructions training and supervision (SIIT) to carry out their role without putting themselves or others at risk.

Monitoring and Review the Health and Safety Policy :

Once H&S policy is agreed, written and distributed to all your stakeholders , it is important to monitor and review the Policy to ensure/achieve the desired H&S Performance.

Benefits of Monitoring and Review the Health and Safety Policy

By monitoring and reviewing the efficacy of health and safety policy statement , organisation can reduce the risk of being in breach of health and safety law.
Regular monitor and reviews of a health and safety policy statement ensure that effective health and safety rules, procedures, SOP, SSW, PTW , control measures are being implemented in the workplace.
It leads to enhanced communication within an organisation
Effective worker consultation and involvement
Regularly review improve the productivity , safety culture, effective of OH&SMS
It lead to significant cost savings as reduction of Accident/ill-health

Reference for below topic : https://humanfocus.co.uk/blog/making-your-health-and-safety-policy-statement-effective/

Various Safety Policies are used at workplace

Incident reporting policy
Drug and alcohol policy
Safe driving policies
Personal protective equipment (PPE) policy
Lockout/tagout policy and procedures
Transitional duty policy.
etc.

The Benefits of Using a HSE Policy Audit Checklist :

An HSE checklist can help illuminate and rectify issues and shortfalls in your health and safety policy statement.

Ultimately H&S policy will protect the workers from significant hazards and dangers at workplaces.

Sample checklist points for an Health and Safety Policy :

While the below list is not exhaustive, in general, you should consider the following points when reviewing a health and safety policy statement:

Is there a clear statement of commitment to health and safety? ( Yes / No/ Comments)
Are there clear roles and responsibilities with named individuals at all levels? ( Yes / No/ Comments)
Does the health and safety policy statement say how it will be implemented, reviewed and on what timescale? ( Yes / No/ Comments)
Does the health and safety policy statement have the appropriate signature and is it dated? ( Yes / No/ Comments)
Have all the ideas, concerns, and issues of managers, supervisors, committee members, and employees been addressed? ( Yes / No/ Comments)
Has the policy been effectively communicated to all concerned? ( Yes / No/ Comments)
Does it have the cooperation and involvement of the workforce as a central theme? ( Yes / No/ Comments)
Are there named individuals with responsibilities for the following essential systems:Fire safety arrangementsFirst aidSafety inspectionsRisk assessmentsHealth monitoringHealth and safety trainingMandatory systems such as inspection of equipmentAccident reporting and investigation ( Yes / No/ Comments)
Are there suitable arrangements for dealing with all foreseeable hazards? ( Yes / No/ Comments)
Does the health and safety policy statement explain how risk assessments will be carried out? ( Yes / No/ Comments)
Does the health and safety policy statement explain how plant and equipment will be used? ( Yes / No/ Comments)
Are there arrangements for the maintenance and upkeep of plant and equipment? ( Yes / No/ Comments)
Are emergency procedures detailed? ( Yes / No/ Comments)
Are there arrangements for communicating health and safety information within the organisation?( Yes / No/ Comments)
Is health and safety training covered? ( Yes / No/ Comments)
Does the health and safety policy statement explain how health and safety matters are to be supervised?( Yes / No/ Comments)
If maximum checklist points are in YES , then it shows organisation's commitment for effective implementation of Health and Safety Policy otherwise management need to strengthen its Safety policy to avoid any accident/incident .

Reference for this topic : https://humanfocus.co.uk/blog/making-your-health-and-safety-policy-statement-effective/

General Scenario at workplace:

Auditor Question : Where are your safety policy right now :

Management : The Management representative bring the policy from the record room where it was lying from several years and dust also collected on policy .

Auditor checked the policy , it was developed and approved by MD in 2015.

Auditor Next Question : When did you last review of Health and safety Policy ?

Management : The Management representative replied that all workers are working safely so there was no need to review the Health and safety policy .

Auditor realized that policy is not reviewed by the Management .

Auditor given the Non -conformity that Policy is not reviewed since its inception.

Disclaimer : This Article is written for educational purpose only . The Various sources have been utilised to compile this article. And all credit goes to the respective agency/owner /organisation,

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