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Stern  
#1 Posted : 07 February 2017 16:55:39(UTC)
Rank: Super forum user
Stern

I'm currently overhauling the H&S Policy of my new company and it has took me back to a disagreement i had a couple of years back at a previous employer with an external auditor who was vetting us for membership of an association.

The auditor in quesrion felt that our xompany H&S policy wasn't "big enough", even though it covered all the necessary bases and satisifed CHAS, SMAS, Achilles and a numerous large UK contractors.

He felt that in order for a policy to be "compliant" it had to include actual document templates (templates of everything from DSE assessments to toolbox talks, inspection sheets, procedures, safe systems of work etc). I strongly disagreed, and still do to this day.

In my opninion, so long as my policy states something along the lines of "a risk assessment must be completed before starting using form HS001" or "fuel on site must be stored in accordance with company guidance note HS002" then as far as i am concerned it does what it needs to do wihtout becoming a huge lumbering document full of cut and paste copies of other documents.

What are everybody else's thoughts/approaches towards this...?

Edited by user 07 February 2017 16:56:54(UTC)  | Reason: Not specified

Striker84  
#2 Posted : 07 February 2017 19:56:26(UTC)
Rank: Forum user
Striker84

Hi.

I have seen both short (12 page collated) and long (100+ single paged) policies however in my opinion, as long as you have covered the statement of intent, responsibilities and arrangements........ I fell that the shorter and more aesthetic, the better. It is a requirement that you communicate the policy throughout the workforce and I feel that it's imperative that it's readable and clear.

I would not expect such an auditor to state that "the policy is not big enough" but to explain what areas are requiring expansion or inclusion within the policy to meet the expected standards.



I would be interested in others opinions but I think that where the policy is thorough, covering the areas required that the smaller and more communicable, the better.

Regards
RayRapp  
#3 Posted : 08 February 2017 09:55:17(UTC)
Rank: Super forum user
RayRapp

I can see both sides of the argument. Personally I have a preference for concise documents as opposed to War and Peace which nobody bothers to read - but then I'm not an auditor or a consultant. I would have thought that unless there is a clear breach of standards or legislation the content of company documents such as H&S Policy should be at the discretion of the author.

chris42  
#4 Posted : 08 February 2017 10:09:52(UTC)
Rank: Super forum user
chris42

Hard for us to comment without seeing what exactly you have or the rules to the association. However, if you consider ISO standards for 9001 or 140001 or OHSAS18001. Then some of what you list should really be in there. Certainly, procedures required for the standards.

 

But your post is confusing me a little. If you have a form HS001 in a system for everyone to get to and in parts of your arrangements / procedures / instructions etc you refer to the document reference, then that is fine. They “Are part of your arrangements” if controlled. Why do they not think they are part of the whole system? 

“include actual document templates (templates of everything from DSE assessments to toolbox talks, inspection sheets, procedures, safe systems of work etc”

 

gerrysharpe  
#5 Posted : 08 February 2017 10:12:21(UTC)
Rank: Super forum user
gerrysharpe

I have written a whole raft of safety policies and find it acceptable to either have policies with no templates as well as including templates in the appendix of policies.

I'm guessing you need to think of the intended recipritant, are they someone who just needs a copy of your policy, or is it for practical use by your company showing the accepted methods and templates used.

You could complete a seperate file with all your templates included in that and simply refer back.

Invictus  
#6 Posted : 08 February 2017 10:12:49(UTC)
Rank: Super forum user
Invictus

Where I work now we have 1 over reaching policy and then all other subjects have there own policy.

Stern  
#7 Posted : 08 February 2017 11:47:00(UTC)
Rank: Super forum user
Stern

Morning all,

Thanks for taking the time to reply. It's interesting to get some views on this and good see that i wasn't completely out of order for standing my ground!

From memory, our policy was around 60+ pages and had clear, concise and easily understandable policies & procedures in place for all of the usual construction related H&S topics. He felt however that a "good" policy should be 2 or 3 times the size of this (he stated this without even opening it!) He felt that it wasn't good enough to just refer to a document and that the document had to be in there.

Stern  
#8 Posted : 08 February 2017 11:50:37(UTC)
Rank: Super forum user
Stern

Originally Posted by: Invictus Go to Quoted Post

Where I work now we have 1 over reaching policy and then all other subjects have there own policy.


Hi Invictus,

That has always been my approach and experience. I am in the process of putting together one overall H&S Policy which then contains individual policies and procedures for a range of topics (work at height, equipment, PPE, training etc etc...)

A great way of doing this which i've seen a few times in the past is to lay it out almost like an ACOP document; The individual policies (what) take the place of the regulations and then the procedures for implementing those policies (how) replace the aprroved code of practice/guidance notes. There's not many people do it like this but done right it can be very effective

A Kurdziel  
#9 Posted : 08 February 2017 11:50:37(UTC)
Rank: Super forum user
A Kurdziel

Who was this auditor- I can imagine a policy being criticised for being not detailed enough or not relevant, for not referencing legal requirements, or difficult to read and understand? The idea that policy is wrong because it is not ‘big enough’ is ridiculous. What size should it be? How many paragraphs for each employee?  Or should it relate to turn over?

Stern  
#10 Posted : 08 February 2017 11:58:22(UTC)
Rank: Super forum user
Stern

Originally Posted by: A Kurdziel Go to Quoted Post

Who was this auditor- I can imagine a policy being criticised for being not detailed enough or not relevant, for not referencing legal requirements, or difficult to read and understand? The idea that policy is wrong because it is not ‘big enough’ is ridiculous. What size should it be? How many paragraphs for each employee?  Or should it relate to turn over?


I'm not gonig to go as far as naming the auditor or the industry body he represented but yes, it was ridiculous. I asked him the same questions. I even asked him what size font he felt it should be and whether he would have still been so critical had it not been printed double sided!

Amusingly, i had access to the policies of one or two of their members and whilst the page count of them was admitedly 2-3 that of ours, the actual word count wasn't all that different. I guess that's what happens when you use a huge font, massive spacings and deep margins!

We made a complaint to their chairman and were told quite bluntly that all of their auditors are NEBOSH certified and that their professional opinions aren't to be challenged! 

Roundtuit  
#11 Posted : 08 February 2017 12:01:56(UTC)
Rank: Super forum user
Roundtuit

Throwback to when BSI launched BS 5750 and the tiered manuals Policy, Procedures, Instructions with all the horrendous cross referencing.

Templates were often included as we are talking the days before computers were wide spread - how does the employee know they are using the correct form? Here Mr Auditor this page in the manual shows them, and here is the same form at their work station - it was the golden age for paper shuffler employment.

Personally I now work much leaner and have a controlled document register which lists the current revision of a particular template with hyperlink so that any one needing the latest version clicks to open. Even this register is only referenced as a hyperlink within the Document Control policy as are all template references throughout the management system documentation.

Roundtuit  
#12 Posted : 08 February 2017 12:01:56(UTC)
Rank: Super forum user
Roundtuit

Throwback to when BSI launched BS 5750 and the tiered manuals Policy, Procedures, Instructions with all the horrendous cross referencing.

Templates were often included as we are talking the days before computers were wide spread - how does the employee know they are using the correct form? Here Mr Auditor this page in the manual shows them, and here is the same form at their work station - it was the golden age for paper shuffler employment.

Personally I now work much leaner and have a controlled document register which lists the current revision of a particular template with hyperlink so that any one needing the latest version clicks to open. Even this register is only referenced as a hyperlink within the Document Control policy as are all template references throughout the management system documentation.

chris42  
#13 Posted : 08 February 2017 12:27:42(UTC)
Rank: Super forum user
chris42

Originally Posted by: Roundtuit Go to Quoted Post

Throwback to when BSI launched BS 5750 and the tiered manuals Policy, Procedures, Instructions with all the horrendous cross referencing.

Templates were often included as we are talking the days before computers were wide spread - how does the employee know they are using the correct form? Here Mr Auditor this page in the manual shows them, and here is the same form at their work station - it was the golden age for paper shuffler employment.

Personally I now work much leaner and have a controlled document register which lists the current revision of a particular template with hyperlink so that any one needing the latest version clicks to open. Even this register is only referenced as a hyperlink within the Document Control policy as are all template references throughout the management system documentation.

I do the same where I am currently. You split your system into individual documents that way when one changes only people that need to know about that specific part need to be informed.  

Previous employment similar, but I created a database to control all electronic documents ( so still hyperlink), which also controlled rev level and details of changes, anything printed was considered uncontrolled. NEBOSH has very little to do with management systems (It did cover them a little). NB the database ( not access) stopped people asking (unnecessarily) for full copies of our system :o)

How about a cryptic clue to whom?

Brian Campbell  
#14 Posted : 08 February 2017 14:41:21(UTC)
Rank: Forum user
Brian Campbell

Hi, I would suggest your auditor is refering more to OHSAS 18001 but if your not currently following this management system then they can only suggest these changes or reccomendations.  At the end of the day its your system and challenge them on everything if you feel it doesnt work for you!  Auditors have a tendancy to over-complicate management systems when there is no need...

BC 

Stuart Smiles  
#15 Posted : 14 February 2017 00:23:27(UTC)
Rank: Forum user
Stuart Smiles

Page and a bit - 2 pages absolute max, otherwise you'd never get people to have read and understood it,

That said it should form an extract from your manual on how we do things round here, as a controlled document, in accordance with the requirements of hse for communication, responsibilities, how, who, when etc.

Good luck.
peter gotch  
#16 Posted : 14 February 2017 13:05:09(UTC)
Rank: Super forum user
peter gotch

Our UK and Ireland Health & Safety Policy is on a single page, with not that many words on it. Ditto the Environment Policy.

It doesn't stop us having 9001, 14001 and 18001 accreditions along with CHAS and many others.

Mr Curious  
#17 Posted : 15 February 2017 10:04:17(UTC)
Rank: Forum user
Mr Curious

I agree with Peter above. I have never seen a policy 60+ pages long! Maybe a 2-3pp in very rare cases. It makes me wonder about the size of your H&S Manual, who drafted it and how many...years it took!

We use a single page as well for all our systems and the details are included in our Manuals. Which lead to our detailed processes and procedures.

4.2 of the OHSAS18001 lists a few requirements. No need to over extend it to crazy levels, no need to include all the details. My personal opinion is to keep is short and succinct. As said before, we have the Manuals to include all the rest. 

Ian Bell2  
#18 Posted : 15 February 2017 10:31:45(UTC)
Rank: Super forum user
Ian Bell2

Looks like there is confusion between 'policy' and 'arrangements' documents.

As indicated a safety policy can/should be only a few pages at most.

Arrangements are the detail of how a policy is put into place for a particular topic - which can be extensive documents.

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