Rank: Forum user
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Hello there,
Could anybody please tell me whether there is a piece of legislation that states we should have formalised document review/version control procedures? If there is, could you please let me know what it is? I have been blind-searching for days.
Thanks very much,
Sheila
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Rank: Super forum user
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Sheila: You've been looking for something that doesn't exist (in the UK). You can be as informal as you want provided you are not trying to supply goods or services to one of the clients or client groups that insist on everyone being totally retentive about bureaucracy.
Steve
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Rank: Forum user
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Thanks Steve, that's really helpful. Have written a brief doc control procedure, and wondered what legislation needed referencing (it's actually ISO 9001, but we don't follow that anyway). thanks again!
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Rank: Super forum user
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I believe Regulation 5 of the Management Regs applies. The withdrawn L21 and HSG65 make this more or less explicit?
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Rank: Super forum user
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Not every aspect of health & safety or in this particular case, Health & Safety Management System be based on explicit/prescribed legal basis.
If you do not have formalised document review/version control of procedures, how do you determine which is the current version etc etc? It is simply good practice, but explicitly required for ISO 9001, ISO 14001 and OHSAS 18001
For OHSAS 18001, clauses 4.4.5 a to g refers to "Control of documents":-
It requires organization to establish, implement and maintain procedure(s) to:
a) approve documents for adequacy prior to issue
b) review and update as necessary and re-approve documents
c) ensure that changes and the current revision status of documents are identified
d) ensure that relevant versions of applicable documents are available at points of use
e) ensure that documents remain legible and readily identifiable
f) ensure that documents of external origin determined by the organization to be necessary for the planning and operation of the OH&S management system are identified and their distribution controlled; and
g) prevent the unintended use of obsolete documents and apply suitable identification to them if they are retained for any purpose.
Regulation 5 of the Management Regulations requires that every employer shall make and give effect to health and safety arrangements as appropriate, having regard to the nature of his activities and the size of his undertaking, for the effective planning, organisation, control, monitoring and review of the preventive and protective measures and where the employer employs five or more employees, he shall record the arrangements . I very much doubt that the term "Control" is used in the same context in regulation 5 as the one for "Document Review/version control of procedures
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Rank: Super forum user
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the management regs are a good reference to make as they require that a management system is put in place and by implication documentation management must be part of that management system
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Rank: Super forum user
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But MHSWR DOES NOT explicitly require a document review procedure.............
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Rank: Forum user
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The Management of Health and Safety at Work Regulations 1999 states:
Health and safety arrangements
5. (1) Every employer shall make and give effect to such arrangements as are appropriate, having regard to the nature of his activities and the size of his undertaking, for the effective planning, organisation, control, monitoring and review of the preventive and protective measures.
Answers the question methinks
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Rank: Super forum user
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In what way does quoting the Management regs answer the question? At what size of an undertaking, in which nature of activities and when is it appropriate for a business to have formal document control procedures?
Far too often, the answer seems to be 'document it formally' when in fact a simple bit of pre-employment screening and appointment of suitably competent employees and managers will be all that is required - and this can be (I would argue it SHOULD be) informal....
Steve
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Rank: Forum user
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I prefer the audit trial, informal generally means no evidence.
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Rank: Super forum user
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the size of a business has no bearing on the requirement to hold appropraite documentation e.g. try arguing to the tax man, national insurance man or a court ertc. that you are 2 small to have appropriate documents!!
Its interesting to note that its only when H&S is quoted that people argue the need or otherwise for documents!!
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Rank: Super forum user
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There is no legal requirement to have a formal document control system and there is nothing in MHSWR that says there has to be. The closest that L21 (before it was withdrawn) came to even touching on that was by referencing HSG65 which of course is full of "shoulds" and "mays". So as I said there is no prescriptive requirement.
HSG65 talks about PDCA as a way to manage health and safety and basically says that the more resources that are available to an organisation, the more in depth the management system should be, but that of course is completely subjective. Nowhere does it specify specific procedures.
As to the comment "2 small to have appropriate documents" there is a world of difference between keeping tax records and having a formal document control system.
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Rank: Super forum user
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PL53 - Thank you! I was beginning to think I was the only one who understood this...
Bob - you write : "the size of a business has no bearing on the requirement to hold appropraite documentation"... Really??? So why does Reg5 include the expressly specific phrase "... and the size of his undertaking"???
The original question asked 'is there a piece of legislation...'? The answer is 'no'. In many scenarios it may be appropriate to hold such documents as part of a systematic way of managing significant risks - but it is not essential. And it is NOT a legal requirement. Too many QMS evangelists for too long have been saying their way is the only way - and in my opinion far too many people have begun to think they are right.
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Rank: Super forum user
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Now, if we can just build up a sufficient groundswell of opinion that good health and safety is about keeping people healthy and safe we may just start to change broader opinions of our profession.
When did a stack of paper or megabytes of data ever save a life?
BS9001 and the lawyers have a lot to answer for, in my opinion.
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Rank: Forum user
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For the relatively small amount of time and effort it takes to implement a document control system it is certainly worth doing.
A piece of paper has never saved a life but using an out of date version of an emergency response plan for example, with incorrect contact numbers or location details etc, could be the cause of a delayed rescue and contribute towards the loss of life.
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Rank: Forum user
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Hi everybody,
Thank you all for your considered replies, esp. Steve ashton. responses are all helpful and have answered my original question (although I am sorry to caused an on-online argument). what this all reminds me of is the perceived 'need' to pat test every year.... This document control/review issue seems to have the same misconceptions. Truly appreciate all your input.
Sheila (Me)
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Rank: Super forum user
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Oh dear.
The Management Regs require the employer's arrangements for managing H&S to be subject to appropriate monitor and review.
IF the employer's developed arrangements extend to formal documentation THEN the requirements of MHSWR will apply.
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