Welcome Guest! The IOSH forums are a free resource to both members and non-members. Login or register to use them

Postings made by forum users are personal opinions. IOSH is not responsible for the content or accuracy of any of the information contained in forum postings. Please carefully consider any advice you receive.

Notification

Icon
Error

Options
Go to last post Go to first unread
SamJen1973  
#1 Posted : 28 March 2013 10:43:23(UTC)
Rank: Forum user
SamJen1973

Hi I'd like your opinions and experiences on the benefits (or not) of using prescriptive H&S Procedures to support H&S Policy statements. As a bit of background to my question... In my organisation (social care sector) we have an ISO 9001 accredited quality management system and H&S P&Ps sit within the QMS. We have developed, over the 8 years I've been with the organisation, some quite prescriptive H&S procedures which set out exactly what and how certain things need to be carried out, including specified templates for recording outcomes of different types of risk assessment. This approach was felt necessary due to the lack of consistency across our service sites in the standards of H&S, the quality of records and lack of evidence to back up H&S decisions and actions (no clear auditable trail). However, we're now in a much better place - our QMS is embedded, awareness levels are up, and managers (I believe) have a real understanding of what needs to be done, to what standard and the need to maintain good records. Generlaly we have a positive H&S Culture (most likely due to the sector we work in which is focussed on providing care and support to people with disabilities). I feel that now, we perhaps no longer need to be quite so prescriptive and can allow managers to decide their own routes to safety. It's getting to the stage that some of the prescriptive procedures may actually end up being a hinderence rather than a help to our staff, and by extension the people we support. Ultimately, what I would like to do is remove some of our prescriptive H&S procedures and replace with Policy Statements - setting out what needs to be done, but not being prescriptive about how. I'd appreciate your views or experiences in this. Many thanks Sam
Palmer20061  
#2 Posted : 28 March 2013 11:48:33(UTC)
Rank: Forum user
Palmer20061

Generally, within system speak, you have a policy statement that sets out the overall aims of the organisation – this is supported by procedures for specific activities and we then have guidance notes which have more detail behind them If necessary the procedures could be worded sufficiently widely to allow some degree of freedom – e.g. the procedure could state ‘All employees receive Induction training relevant to their role’, rather than specifying what has to be detailed in the induction, a guidance note on ‘Induction’ could then give a variety of options. You obviously then have to audit to make sure sufficient controls are still in place!
Ron Hunter  
#3 Posted : 28 March 2013 12:20:28(UTC)
Rank: Super forum user
Ron Hunter

A middle-path of moderating the procedure might be preferable. Throwing the baby out with the bath water etc. If nothing else, procedure serves to inform and instruct new people. From a QA p.o.v. of course, you can't readily audit "policies" - but you can procedures.
andybz  
#4 Posted : 28 March 2013 13:51:58(UTC)
Rank: Super forum user
andybz

The one size fits all approach that many companies try to follow with procedures just doesn't work in practice. Tasks vary in their complexity, risk and frequency. This means the end users have different needs for procedures, from requiring full detail through to nothing. It has been recognised in the process industry that there needs to be some focus on 'safety critical tasks' which inevitably means other tasks receive less attention. We have developed simple methods of assigning task criticality by considering hazard and the attributes of the task that make it more susceptible to human failure. Having assigned criticality it is then necessary to determine the best approach for managing the risks. The following is a general guide: * High criticality tasks - A fully detailed procedure is required that must be used every time the task is performed. * Medium criticality - A full reference procedure is required but people have proven competence in the task may perform it without using the procedure. * Low criticality - Specific procedure is not required. Will be covered by general procedures, policies or guidelines; and normally learnt on-the-job. As a rule of thumb, approximately 20% of tasks will be High, 30% medium and 50% low. So you can see the number of procedures required is reduced significantly. Also, the most frequently performed tasks are usually the low criticality, so the times when procedures need to be used is reduced even more. Interestingly, when I have carried out task criticality ranking exercises with clients we have often identified high criticality tasks where a procedure has not been written; whilst lots of full-blown procedures have been written for low criticality tasks.
bob youel  
#5 Posted : 28 March 2013 14:39:39(UTC)
Rank: Super forum user
bob youel

it sounds like that you have done great I congratulate you - My advices is to stick with it as in my experience the moment you let others think for themselves standards drop off and its then you have an accident and its then you end up in court where you need as much paperwork as you can have
RayRapp  
#6 Posted : 28 March 2013 16:59:30(UTC)
Rank: Super forum user
RayRapp

As others have commented, Policies should underpin all that you do, whereas Procedures should provide the methodology. Hence it is not one or the other, but both.
BigRab  
#7 Posted : 28 March 2013 20:39:35(UTC)
Rank: Forum user
BigRab

RayRapp wrote:
As others have commented, Policies should underpin all that you do, whereas Procedures should provide the methodology. Hence it is not one or the other, but both.
I would go with this general approach. My experience with a client base mainly in the Motor Vehicle Retail Sector is that the policy sets out aims and objectives (the what do we intend to do) and the procedures set out when, how and by whom it is to be done. For example you might have a policy that says "All contractors working on our premises must have, and adhere to, a safe system of work" The procedure will say "Contractors who do work for us must be approved..." and the procedure would go on to spell out the detail of how they become approved and what measures they must take to convince you that they have a safe system of work. You could also spell out activities related to specific premises, e.g. "The fire alarm at X is an automatic addressable system monitored by (Alarm Company) and will be tested by (post name) at 10:00 AM every Monday" As commented by Palmer61 the idea of guidance notes is also good practice in my opinion. The route I would take would be to involve those at the sharp end in writing the guidance notes (or at least consulting them on what it is in them) and then you will get some degree of buy-in from them.
SamJen1973  
#8 Posted : 29 March 2013 13:40:55(UTC)
Rank: Forum user
SamJen1973

Thanks everyone for your responses, good to hear others' viewpoints. My thoughts were to keep a detailed procedures and methodology for the high risk and/or more highly regulated areas, while switching to general principles with supporting guidelines for lower risk issues. Sam
JohnW  
#9 Posted : 03 April 2013 11:17:16(UTC)
Rank: Super forum user
JohnW

Interesting thread. I spend a good amount of time reviewing clients' policies and procedures, and I often provide them with the 'guidance notes' which are usuaully detailed reminders of why procedures are needed, why certain precautions are taken, why certain checks or tests are done, why certain records are kept etc. and I'll usually try and involve a supervisor when preparing these notes - these notes are not usually displayed anywhere they are aimed at supervisors/managers so they can refer to them or use them in training/refreshers/toolboxtalks. Posters above refer to having most detailed documentation for high risk/critical operations. That makes sense, presumably these are operations which can cause severe injury if things went wrong - like operator by-passing controls or not wearing PPE, machines needing strict maintenance schedule etc. Low risk operations tend to be less documented, the chance or severe injury is very low - however, in my experience it's those 'low risk' operations that cause most accidents, maybe minor, but I'm often reviewing accident books and seeing things like: walked into sharp object, tripped lifting awkward sized box, spring flicked face during maintenance, banged hand while pushing trolley. Usually a review of the work practices doesn't immediately come up with corrective actions/solutions, and there's a reluctance to have prescriptive procedures for 'trivial' activities as the 'general principles' or working safely should be dealing with such things, but the accident book says it all !?!
JohnW  
#10 Posted : 03 April 2013 13:26:12(UTC)
Rank: Super forum user
JohnW

Last bit should have said: "the 'general principles' OF working safely...."
jontyjohnston  
#11 Posted : 03 April 2013 13:28:52(UTC)
Rank: Super forum user
jontyjohnston

Sam A lot of very good advice already on the thread. I used to work for a very large multi-national and their approach was very good. Corporate set policy, aims and objectives and issued management procedures which were very general, i.e. that each locations should identify and assess risks associated with its (site specific) activities, it contained the principles to be adopted but left the methodology with the location. The total number of corporate "level 1" procedures was 12! At a local site level we then developed operational control documents derived from the risk assessment process, a bit like method statements. Corporate then audited each site against the management requirements allowing for different (within reason) methodologies. In the 3 roles I have had since leaving that organisation I have used exactly the same process to set up management systems to OHSAS18001 which has proved to be very effective. PM me with your email if you a bit more info. Jonty
Users browsing this topic
Guest
You cannot post new topics in this forum.
You cannot reply to topics in this forum.
You cannot delete your posts in this forum.
You cannot edit your posts in this forum.
You cannot create polls in this forum.
You cannot vote in polls in this forum.