Last reviewed 21 February 2018
The need to have a written health and safety policy where five or more persons are employed is a well-known legal requirement. But, Mike Sopp points out, clear planning and strategy is key to effective health and safety management. Are policy and strategy actually the same thing?
According to the Health and Safety Executive (HSE) guidance document HSG65 Managing for Health and Safety, a policy that sets out a clear direction will “help to ensure communication of health and safety duties and benefits throughout the organisation”.
The same document also states that “an important part of achieving effective health and safety outcomes is having a strategy and making clear plans”.
For the health and safety practitioner, this raises the question of what comes first, policy or strategy development and what, if any, relationship exists between these two important documents.
A question of purpose
Although a clear legal requirement, the HSE does not provide any definition of a health and safety policy, rather stating that a policy is about “describing how you will manage health and safety in your business” and that it will “let your staff and others know about your commitment to health and safety”.
A more formal definition can be found in standards such as BS OHSAS 18001, BS 18004 and the soon to be published ISO 45001. These define a policy as the “overall intentions and direction of an organisation related to its OH&S performance as formally expressed by top management”.
They further detail that a policy should as a minimum include statements committing the organisation to the prevention of injuries and ill health, legal compliance and continual improvement and performance.
From the above, it can be concluded that the health and safety policy is an aspirational document that provides:
an overall sense of direction from top management
a demonstration of commitment from top management
a framework for action to implement health and safety
a guide for the setting of health and safety objectives.
Although HSG65 refers to strategy development, this document and the standards noted above, focus on planning for health and safety. However, in real world application many organisations now develop health and safety strategies that include the planning element of a formal management system.
Whereas the policy provides the thought-orientated guiding principles that enables an organisation to make logical decisions about health and safety, a strategy is a comprehensive “game plan” aimed at accomplishing the organisational objectives through courses of action chosen to achieve the objectives.
In other words, a strategy is a means to an end that is deployed to mobilise the resources necessary to meet the objectives of the health and safety policy.
In some circumstances, particularly where the maturity of the organisational safety culture is poor, a strategy may have to be developed prior to the health and safety policy. However, in general terms a strategy will be underpinned by the policy, particularly in terms of statements of intent and organisational arrangements.
Although a policy should be subject to review to take account of changes that influence health and safety management, the policy tends to be a more “rigid” or “uniform” document whereas the strategy should be flexible and be capable of being modified to take account of any unforeseen circumstances, changes in priority, set-backs in implementation, etc.
Policy review and development
As the purpose of a policy is to express top management’s guiding principles for health and safety, thought and consideration must be given to how that policy is developed.
Usually, there is already a health and safety policy in place that simply requires a review to ensure best practice is being met.
BS OHSAS 18002 states that to be appropriate the policy should be consistent with the organisation’s future vision and be realistic in terms of the organisation’s risk profile. HSG65 states that the policy should also reflect the organisation’s “values and beliefs”.
In addition to the above points, inputs into the review/development process will include:
influences from other corporate policies (eg quality, risk management, etc)
the extent of outsourcing and use of contractors
the hazards and risk profile of the organisation
compliance obligations including legislative and policy compliance
influences/needs of key stakeholders (internal and external)
historical health and safety performance and current culture maturity
requirements for establishing realistic objectives and continual improvement.
In terms of practicalities, responsibility for writing the policy will most likely rest with the competent person appointed under Regulation 7 of the Management of Health and Safety at Work Regulations 1999. However, ownership should remain with top management.
HSG65 states that the policy “should be written in consultation with the workforce”. This is quite a broad statement and how this can be achieved will be very specific to the particular organisation. In general terms, the process of reviewing/developing a policy will include the:
identification of the key components of the policy (eg statement, responsibilities, arrangements)
identification of regulations, standards and best practice that is applicable
review of current policy to identify gaps
development of a draft/revised policy
circulation of draft/revised policy to identified stakeholders
amendment based upon feedback from the consultation
agreed final draft with stakeholders and obtain feedback.
As with development and review of the policy, it is likely that the competent person will be responsible for developing a strategy document and is likely to take ownership of the document (although it may contain delegated responsibilities in terms of actions).
For those unfamiliar with the need for a health and safety strategy document but who may be asked to approve the strategy (eg top management), it may be advisable to include in the strategy a statement setting out the purpose of the document and how it relates to the health and safety policy.
As discussed above, the strategy aims to ensure that objectives of the organisation are met through ensuring actions necessary are identified and resources allocated to enable the actions to be implemented.
These could be high level objectives, eg improving the culture of the organisation, to more operational matters, eg ensuring that all properties have a suitable and sufficient fire risk assessment in place.
The person responsible for developing the strategy will need to identify the key themes and/or the current position as to health and safety performance when developing the strategy. Inputs into this will include:
outcomes from performance measuring programmes (inspections, audits, investigations)
outcomes from any status review activities including management reviews
outcomes of risk assessments completed particularly for higher-risk activities
current safety culture (eg via climate surveys)
resource availability to ensure the ALARP is met
inputs from international and national strategies (eg from the HSE).
From the above, analysis can be undertaken to determine where an organisation is and where it wants to be. The latter can be described with a “vision statement” of what success will look like if the strategy is successfully implemented.
In practical terms of developing a strategy, there is no one particular format that can be used but in general terms most strategies will consist of a series of objectives (normally based upon the SMART principles), what action is required to meet the objective, delivery timescales, owners and what success will look like including, where necessary, performance indicators.
When developing the strategy, the organisation should guard against setting too many objectives. Instead it should focus on a limited set of key objectives that are capable of being delivered so as to ensure a step-change approach to improvement.
Although the standards noted above do not refer directly to strategy documents, they do suggest the development of a programme for achieving the objectives set. In doing so, the programme/strategy should be reviewed at regular and planned intervals and adjusted as necessary to ensure that the objectives and consequently the policy aspirations are being achieved.
Health and Safety Executive: www.hse.gov.uk
HSG65 Managing for Health and Safety
British Standards Institution: www.bsigroup.com
BS OHSAS 18002 Occupational Health and Safety Management Systems. Guidelines for the Implementation of BS OHSAS 18001
BS 18004 Guide to Achieving Effective Occupational Health and Safety Performance