A health and safety policy is a living document that should evolve as your business and the wider world changes. The Health and Safety Executive (HSE) requires that your health and safety policy is kept up to date at all times.
Note: Only companies with 5 or more employees are legally required to have a written Health & Safety Policy, this being stipulated under the Health & Safety at Work Act 1974. However, that stated quite often companies who employ less than 5 employees and are tendering for work or applying for an SSIP will be required to have a written Health & Safety Policy also, this to demonstrates their companies’ aims, objectives, structure and arrangements – please bear this in mind.
The 3 Main Elements of a Health & Safety Policy
As a ‘living’ document, it is worth pointing out that a Health & Safety Policy comprises three main sections, which give purpose to the document and weight as to why the review process is so important, these sections being:
The Health & Safety Statement of Intent
The purpose of a Health & Safety Statement of Intent is to formally declare an employer’s commitment to managing health and safety in the workplace, setting out their aims and responsibilities. It acts as the foundation of the wider health and safety policy, demonstrating leadership and accountability.
The Responsibilities / Organisation Section
This section allocates specific roles and responsibilities and thus ownership, which in turn improves avenues of communication, demonstrating leadership commitment and supports legal compliance.
The Arrangements Section
These Arrangements outline and give structure to how the company will manage business activities in relation to each category and subsequently these are generally linked to the Responsibilities / Organisation Section where responsibilities are allocated to each arrangement.
This section identifies specific arrangements which are related to the company’s scope of business and activities, some examples of which are:
- Risk Management
- Training & Induction
- Safe Systems of Work
- Emergency Procedures
- First Aid
- Welfare Facilities
- CDM
- Communication
- Etc.
Note: These are only given as examples and there may be many more depending on the scope of your business.
How Often Should a Health and Safety Policy be Reviewed?
The Health and Safety Executive recommends that you should conduct a full review of your health and safety policy at least once a year.
Alongside an annual health and safety policy review, it is highly advisable to review your health and safety policy after any relevant changes have been made. A relevant change is any change that affects the way you work – the main points being covered or mentioned below in the next paragraph.
Why Do Health and Safety Policies Need to be Updated?
As the world changes, and your business along with it, your health and safety policy will need to adapt to new hazards, challenges and growth factors.
Health and safety policies should adapt to ‘relevant changes’ in and around your business that could impact health and safety. By adapting to changes in a responsive manner, you make sure to stay in line with the HSE’s recommended policy review guidelines and maintain a proactive health and safety culture.
Common areas of change that trigger a policy review include:
Legislation & Regulatory Changes
Changes to legislation are usually signalled well in advance. Your policy must reflect any legal changes in sufficient time, these may include new laws, regulations, or updates (e.g., Building Safety Act, Worker Protection Act) and changes in industry standards or guidance from the HSE.
Organisational Changes
Which may include:
- Restructuring, mergers, or acquisitions.
- Appointment of new directors, managers, or safety officers.
- Changes to the scope of the business i.e. products and/or services.
- Significant changes in workforce size or composition.
Note: An activity that is perfectly safe for one staff member may not be safe for another. For example, the new staff members may need training and/or different PPE.
Operational Changes
Introduction of new work methods, processes or technologies which may include the use of new equipment, machinery, or substances (COSHH implications).
Changes in Operational Locations
This may include a wide range of operational locations such as urban, rural, offshore, overseas etc which impact the logistics of working safely.
Note: A key point to remember here is that you are still responsible for the health and safety of both remote and mobile employees, also, companies which are registered in the UK but have offices (etc) overseas still have legal responsibility to adhere to the Health & Safety At Work Act 1974, although they may be working overseas.
Incident-Driven Reviews
Following accidents, near misses, or dangerous occurrences.
After enforcement action, inspections, or audits by regulators.
When risk assessments highlight new or increased hazards.
These are all opportunities to learn and prevent. Even small concerns should be treated seriously. In fact, you should actively encourage your staff to report all concerns to you, no matter how minor.
Should We Conduct a Review Even After Small Changes?
It is recommended that any change at all in any of these areas should potentially prompt a review of your health and safety policies. The key point to remember here is that small changes can have a big impact on a business and thus may prompt a re-write of your company’s Health & Safety Policy.
Note: Small changes often have a ripple effect. This ripple effect can create new health and safety hazards as well as new opportunities for the business. These hazards can become significant if they are not managed properly. This is exactly why it’s so important to make a point of reviewing your Health and Safety Policy whenever any changes are made or occur.
How to Conduct a Health and Safety Policy Review
One practical approach to conducting reviews of your health and safety policy is to undertake a full review annually and partial reviews as necessary. Both types of review will cover the same basic points. They will, however, differ significantly in scope.
Full reviews will cover the whole document – this means that all three sections of the Health and Safety Policy, the Statement of Intent, Responsibilities / Organisation and Arrangements Sections will be reviewed.
Partial reviews will be prompted by any changes since the last annual / full review and may focus specifically on the Responsibilities / Organisation and Arrangements Sections of the Health & Safety Policy. Therefore, a partial review will only cover the effects of those changes. This means that they will only look at where the change affects existing processes.
Typically, this will include the following points:
- What, exactly, is the nature and scope of the change?
- Does the change have any legal implications?
- Who is or could be impacted by the change (directly or indirectly)?
- Will the change require the business to use new locations? If so, what are the implications of this?
- Will the change require staff to use new equipment or processes? If so, what are the implications of this?
- Has anyone raised any concerns about the change? Have there been any near-misses or accidents that could be relevant to the change?
- Are the goals outlined in the health and safety policy still being met after the change?
- Do the roles and responsibilities need to be expanded upon or changed?
- Etc.
Communicating Your Health and Safety Policy
Annually / On Review
The Statement of Intent should be displayed on a prominent (Health & Safety) noticeboard within the workplace, and as per best practice this section is then also normally briefed out to the employees as it underpins the company’s aims and overall commitment to Health & Safety.
The Company Organogram (which as per best practice normally forms part of the Responsibilities / Organisation Section of the full Policy), should also be displayed on a prominent (Health & Safety) noticeboard within the workplace, this then demonstrates avenues of responsibilities and communication to the workforce.
With regard to the Responsibilities / Organisation & The Arrangements Sections (main body of text), these need to be communicated slightly differently due to their potential complexity / size and the changes that are being implemented.
Therefore it is recommended that you potentially consider the intended audience and the changes to the Policy and then further consider providing some staff-specific training on the changes – this could be through one-to-one meetings/training, a meeting with Department Management / Teams, video-training or real-world training. This ensures that the changes are fully adopted at all levels and thus deliver the expected results.
However, this approach may be the exception rather than the rule and formal general briefings, emails may also be suitable – this depending on the proposed changes to the Policy.
Note: You are free to choose the best method of communication for your needs. For example, if the impact of the change is very minor, it may be enough just to send an email to make employees aware of it.
That said, robust records of Policy communications and subsequent training etc should be maintained, as the Health & Safety Policy is the foundation of your health and safety systems and culture.
Importance of Keeping Your Health & Safety Policy Up to Date
Your Health and Safety Policy is the foundation of your Health and Safety Systems and Culture which demonstrates management commitment, allocated responsibilities and guidance to your systems – as such, it is / should be a living document that evolves as your business scope, circumstances and legislation changes.
Note: Remember also, the Health and Safety at Work Act 1974 states that businesses who employ 5 or more employees must have a Health & Safety Policy which is reviewed annually / or sooner if/as changes occur.
That said, it should be noted that many companies struggle to establish a robust Health & Safety Policy or even keep their Policy current and here we can help.
Need Expert Support with Your Health & Safety Policy?
Watson & Watson Health and Safety Consultants can guide you through the creation and regular reviews of your Health & Safety Policy, which will help keep your workplace compliant with the Health and Safety at Work Act 1974.
Get in touch with us today to arrange a service tailored to your business.
