Anyone else come across this?

Risk assessments that state under 'Existing Controls' that a policy is in place regarding the particular issue.

I couldn't disagree more. A policy is just a communication tool that summarises the risk and types of systems/controls that are available to be utilised locally.

Leaves me apoplectic (try that one, Phil) when I try and explain this to the manager. They seem to think that policies are a onestop shop for their risk management needs.

Safetyamateur.

Do they mean a policy or a “safe system of work”?

If some one had a documented comprehensive safe system of work for something I would not expect them to reproduce all the steps etc in that in a risk assessment as I could ask to look at the safe system.

Brian

Pro-points taken but the policy itself (yes, they mean the corporate policy) is not a control in my book. It may contain information on controls but it's unlikely to reflect what happens locally.

Kate's bang right, a policy is a written control, and if you think HSG65, to demonstrate compliance a policy is needed,

John

I think I know what you mean though.

If an organisation has a policy of "not sticking fingers in unguarded machines" but hasn't actually guarded their unsafe machines, then IMO they are more guilty than an organisation that has genuinely omitted to guard their machines through ignorance.

Would you agree with the above?

Hmmm, looks like I'm in the minority here too. Nevertheless.

A corporate policy on, say, COSHH would include reference to the fact that assessments must be done, waste must be collected, PPE is available from....blah, blah, whatever.

My point is: why on earth would that document appear in a local/departmental risk assessment? Its purpose is to inform local controls and decisions. It's not a control in itself.

My understanding of HSG65 is that risk assessment and risk control is very much part of the Planning & Implementation element of the system; not Policy.

Of course a local policy would encapsulate local controls into one docuent that could be used for all sorts of things (e.g. local induction) - it would be a weak control as noted above - but a corporate document? Expecting staff to read it and work out what they should do from there? Nah.

OK, look, there's controls and controls. There's physical controls, such as guards, trips, locks and so on. There's procedural controls such as SSOWs and risk assessments. Then there's written controls. Which is most imoprtant depends on where you are standing and what you are trying to achieve. They are all important, and as I said above, if we are talking about safety management systems then without the first P in POPIMAR, HSG65 would imply that you can't manage H&S at all.

So if you wany to stop somebody sticking their fingers into a press, write a policy that says 'thou shalt not stick thy fingers through this ere ole'; develop a SSOW based on RA that says 'don't try and fiddle the guard, we've seen it all before and we know what you're doing'; and comply with PUWER by buying a press with an interlock guard. Oh, and then monitor, audit and review. The first three are all necessary parts of the prevention regime, and all types of control.

BTW, I've always felt that Schedule 1 to the management regs was odd in respect of the coherent overall prevention policy coming last in the hierarchy; that flies in the face of HSG65 and every other risk assessment based management system,

John

Thanks for the comments, John, but I can't get with the importance of the paper.

I want the controls in first and I'll worry about the paper after. I do appreciate the HASAWA legal requirements but if I ain't got workplace controls, I'll take the risk on not having a policy.


However, when we're talking about management systems and leadership and standards, agreed, it's crucial.

A policy is a statement of intent - it is not in-of-itself a control measure. Below the policy there must be procedures that turn the statement of intent into something that can be implemented, and finally the measures in the procedures must be put into practice. This requires leadership, management, provision of resources, as well as people, at all levels from workers to board level. with the knowledge, skills and who practice the required behaviours to safeguard themselves and others.

One of the fundamental flaws of the health and safety at work act was to require health and safety policies. This was based on the finding by the accident investigation unit that good organisations have health and safety policies; policies do not produce good organisations - good organisations produce policies as part of active leadership.

Regards

I'd disagree with that. In my mind the Statement of Intent is only a small part of the overall policy that only specifies a companies general aims in respect of health and safety and puts down on paper the level of commitment that the company is prepared to make. However, I agree that differing use of the words policy and procedure can lead to misunderstanding. As an example, a company decides to ban the use of bleach as a cleaning agent to prevent the accidental mixing of incompatible products. In my mind not using bleach is company policy as opposed to a procedure. The minutia of what cleaning chemicals to use should not be detailed in the statement of intent but should be included in the policy or a sub-policy depending on the nature of the business.

Isnt a 'policy' just a statement of intent. It doesnt do anything else apart from connect 'focus' areas that the company wishes to follow. But, a control would be a site rule, procedure (yes, the one lying in the cupboard) or even signage (excl those who become sign-blind).

Just a thought

PS
Last few words above should read "that which it needs to comply"