Rank: Forum user 
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I am struggling with an organisational policy format change at the minute because whilst I can make the required sections of the H&S policy fit (under the new imposed titles which I am not sure about) there is also a requested change to overall focus as in instead of focusing on the leadership commitment to health and safety please can we change it to make it clear what employees must do. Hmmmmm I don't think they get it and I need to make my case. Anyone have any experience with this sort of thing or can give me any bullets to fire here or weight to my case. I have been looking through case law and any areas where failures under section 2(3) have weekend an argument or led to any prosecution directly although I am think this might be more improvement notice ground.
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Rank: Super forum user 
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Isn't the actual policy on the page the least important thing in HSWA? I don't expect that that any organisation ever has thought about doing something and then taken a step back and said "but no, our H&S policy nailed here on the wall says we shall not do that".
Or are you lumping process and procedures under the heading of policy?
If it's just 200 words in a frame on the wall that is under discussion, it's not a battle I'd invest much time in, personally. I'd save energy for something that affects what people actually do. If it's expunge any management obligations from all processes and procedures, then you do have to fight, but I'd tackle each topic in turn, with specifics (and I observe that procedures shoudl make it clear what employees must do - I'm not sure what your concern is there - I think that's a good thing).
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Rank: Super forum user 
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KM - if your organisation is accredited to e.g. ISO 45001 the auditor will probably comment if the policy does not focus on leadership. HSE are a bit more ambigous e.g. at Prepare a health and safety policy: How to write your policy - HSE You can check but there are very few prosecutions under HSWA Section 2(3) and if you find them on the HSE current and history prosecutions databases there probably won't be much helpful text. An Improvement Notice would be a much more likely method of enforcement but would probably sit alongside enforcement for specific risks. I think that in 12 years working for HSE I only once included a charge in a prosecution report relating to the policy (there was one, but it hadn't been communicated to all employees) - in that case it seemed to me that the policy was central to what else was being done wrong. The Sheriff proceeded to rip the policy statement into pieces in Court. Far too long to be useful. He was spot on.
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 1 user thanked peter gotch for this useful post.
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Rank: Super forum user
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Are we talking about the whole policy (including Roles & Responsibilities and Arrangements) or just the Policy Statement?
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Rank: Super forum user
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Holliday - therein lies the rub. Any attempt to cover all three elements demanded by Section 2(3) means that for all but the smallest, low risk organisation the document will become unwieldy. So, a "statement of policy" - short, sharp and to the point - setting out focus and, presumably, leadership intent. Possibly some mention that everyone has duties. Maximum two pages. Which then takes you to the subsidiary documentation setting out the systems including the detailed responsiblities. The office junior doesn't need to know about what arrangements are in place for thorough examinations etc. They might need to learn as they rise through the ranks.
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