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#1 Posted : 24 March 2021 16:44:32(UTC)
Rank: Forum user

Has anyone got any suggestions for how to structure a H&S policy for a UK based company that manages construction projects across Europe?  Simply have subsections written by national H&S experts?

A Kurdziel  
#2 Posted : 25 March 2021 09:32:15(UTC)
Rank: Super forum user
A Kurdziel

How about you start with a declaration of core values: The business accepts its responsibilities for H&S matters under its controls, it works with its employees to promote health and safety etc.

You can also say that as a minimum it expects all of its divisions to comply with local laws. You can mention regulations that apply across the whole of the EU or EEA.

Finally you can make it clear that the local H&S people should create there own policies which embody these core values etc.

thanks 1 user thanked A Kurdziel for this useful post.
CptBeaky on 25/03/2021(UTC)
peter gotch  
#3 Posted : 25 March 2021 14:03:45(UTC)
Rank: Super forum user
peter gotch


You don't say whether "across Europe" extends outside the EU and other nations that adopt EU standards, nor whether you have a policy setting out any minimum standards, e.g. adherence to EU requirements.

Also, "managing construction projects" could mean a whole lot of different things, including:

(a) Client function to procure construction

(b) Design, project management etc, not putting people to work at the sharp end

(c) Contracting

....or a mix.

What your role or roles are is likely to help determine an appropriate approach.

But, I am with AK - start with a short, sharp statement of intent.

Then you decide what processess to support your policy apply across the whole geography and where you want local variations.

#4 Posted : 25 March 2021 15:35:22(UTC)
Rank: Super forum user

We have a H&S policy (one-pager) that works in all our jurisdictions (UK, middle East, Asia).  You should be able to make a policy statement that works for all with only a little careful wording – it’s not going to be your policy in any place to disregard the law and worker safety, I’d have thought.

We are principally UK-based (UK staff is about two-thirds of the total).  We write our procedures for the UK but mindful of the non-UK locations, so for example our procedures refer to PPE being compliant to appropriate standards rather than saying 'BS xyz' and another tier of documents lists out what the 'appropriate standards' are.  You have to have different PPE standards - our people on site in UAE have no need of hi-vis winter coats.

In general, the UK is more onerous and more specific than the other statutory regimes we operate in.  We generally therefore apply UK standards everywhere - things like (for example) only the UK has DSE regs, but our procedures mandate workstation assessment and eye tests and staff do those everywhere. Covid has been a bit different - one of our offices for example is in a place where it is now mandatory to have a weekly Covid test, which needs paying for, and the company is funding those.  Therefore, I can’t honestly say we adopt whatever is most onerous among all the jurisdictions we work in – it is mostly the case of we use UK practice or local practice, whichever is highest, but don’t always carry those higher standards back to the UK.

Some places have laws or practices that just don't makes sense elsewhere – for example some of the hotter climes have mandatory non-working periods at the hottest part of the day for part of the year.  Where it's law it's straightforward - you can put a catchall in procedures that says 'don't break the law where you are'.  Where it's customary practice it's a bit more difficult sometimes, but we then have local documents.

#5 Posted : 26 March 2021 02:01:18(UTC)
Rank: Forum user

Many thanks to you for providing comments.  I am a seasoned H&S professional but the multinational angle on this one with a PC client of mine is proving interesting.

#6 Posted : 26 March 2021 09:31:27(UTC)
Rank: Super forum user

worked in a number at a global level in the past...it depends where the appetite for the change is coming from...I was lucky straight from the board...

You have to adopt a hierarchy in the first instance...global, regional, site etc

Divide the existing up in this way then...start with individual site documentation (the good bits) and see what can become regional documentation, look to where you have best practice or stricktest regulatory regime and see how easy it is to make them Global docs... etc etc..the objective is to eventually get everyone to a level that is generally above the minimum legislative requirements...for instance there was no real vehicle maint standard in Asia so we adopted the European/UK standards there...in general all of the standards were driven primarily from US/Europe...

If a site/region say they can't do that because of legislation... so long as your standard is better than the legislation and encorporate all the bits then you are good...takes some time but it works...if you need anything more then please let me know...it can work out to be utopia but you need to couple this with a good behavioural program roll out...maybe not at the same start but eventually running concurrently...bit of food for thought...enjoy :)

#7 Posted : 07 April 2021 10:54:27(UTC)
Rank: New forum user

I also recommend a simple global statement and then a hierarchy of global, regional, or local procedures. Depending on appetite you could try to adopt the highest standard where local legal requirements differ. I have experience of doing this with DSE, where only EU countries had a legal requirement, but ergonomic workplace assessments were required in all locations.

To avoid confusion about which standard is required where, it's also helpful to have a simple matrix showing which company procedure is relevant in every location (either global or local, listed by subject). This helps local managers to be clear about the required standards, and is also useful when auditing.

thanks 1 user thanked Wedgwood27775 for this useful post.
Wailes900134 on 07/04/2021(UTC)
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