Posted By Jack I tend to agree with you. Too much emphasis on legislation can hinder effective communication of the procedure. (And increase administatrive time updating etc). There may be some benefit in a simple hyperlink to the background legislation.

Posted By Jack Yes ok a 'procedure' for 'identifying and accessing the legal and other OH&S requirements that are applicable to it' is one thing. But including details of legislation in every procedure is another. Couldn't it be argued that the former obviates the need for the latter?

Posted By Jamie Teresa, Personally I try to avoid referencing legislation in procedures as I feel that the people who have to follow them want details on what, where and when to do something. Written in simple easy to follow guidance. In my experience people do not care that they have to do it due to xyz Regulations but we do it because it is a normal part of the job.

Posted By Teresa Green Thank you for the feedback so far. Peter, we already have a procedure to identify legal & other requirements together with a legal register (not an actual requirement of 18001 or 14001 but heavily implied) within which we reference our applicable procedure(s). We also have a documented communication procedure which covers both internal and external parties. My preferrred option would have been to make a generic comment that details of applicable legislation is available in the legal register. I suppose the acid test will be the attitude of the auditor on the day as unfortunatly if that is the only thing they have an issue with (hopeful thinking!) then we will have to comply. I believe Lawrence Waterman when serving as President of IOSH expressed an opinion on the subject which I believe questioned the value of it. My concern is that if we are forced down this line the users of the procedures will start demanding hard copies of all the legislation referenced which will become both a time-consuming and financial burden. Thank you for your thoughts. Regards Teresa

Posted By Alexander Falconer Addendum, to above posting Its not all about auditors being lazy, its all about giving someone a procedure to conduct a process and them able to carry the same task to an almost similar standard as you could. After all, a previous mentor said, no one knows what will happen to yo tomorrow! A

Posted By Jerry Lucey Hi Teresa, I can see both sides of the arguement, I however would include references to legislation in your procedures as it not only adds credence to the procedure but also demonstrates that it is current and is regularly reviewed. I would introduce some sort of reference system though, whereby you could trace references easily e.g. a glossery that would tell you that reference is made to the Working at Height Regulations in Section 2 paragraph 1 so that if these regulations were updated or amended you could quickly review your procedures to ensure they comply. With the introduction/ amendment of legislation your procedures should be reviewed and a reference system as outlined above could be a useful tool in this process. I would also be very wary of using procedures in different jurisdictions, e.g. Ireland. Again you could look at your reference and where there is a reference to UK legislation e.g. Workplace Regulations, that these are reviewed to ensure that the procedure fulfils the requirement of the Safety, Health & Welfare (General Application) Regulations 1993 which although enacted as a result of the same European Directive may vary in their content.In this way you would not only change the references to the specific piece of legislation but review the context in which it was used.

Posted By Jonathan Sandler CMIOSH If they wish to be aware of the exact legislation, then it might be best to have an annex stateing page number, para number legislation, that way when legislation changes all you have to chage is one page, and everybody will be happy.

Posted By Smiff I have prepared documents for use by engineers that reference law, ACOP, guidance (including internal) and industry practice and found them to work well, but the target audience is highly responsible people planning complex tasks. More "operative" type instructions would not benefit in my view.