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Locoperro2023  
#1 Posted : 29 July 2024 13:29:56(UTC)
Rank: New forum user
Locoperro2023

Good afternoon,

I hope you are all enjoying the fabulous weather and the Olympics (excluding the opening ceremony). I am currently working on creating a comprehensive Health and Safety policy that covers the UK and our sites in Austria, Belgium, The Netherlands, and Switzerland. While we already have a policy in place for the UK, I am facing difficulties in finding a definitive set of requirements that can be applied to all four countries mentioned.

Each country has its own internal set of standards, making it challenging to find a one-size-fits-all solution. I have looked into the European Agency for Safety and Health at Work, but they only offer recommendations and not specific requirements. For example Austria are not required to have fire alarms fitted or even have annual testing on fire equipment.

I would greatly appreciate any assistance or guidance on how to navigate this issue effectively. Thank you for your support.

peter gotch  
#2 Posted : 29 July 2024 16:15:50(UTC)
Rank: Super forum user
peter gotch

Hi Loco

This is one of those situations where one size is very unlikely to fit all......

OK, let's start with the GB legal requirement in Section 2(3) of HSWA (with a parallel to extend that to the NI, thence incorporating all of the UK).

Statement of "general policy" and of the "organisation and arrangements" for its implementation.

Nothing in Section 2(3) says that this all has to be in a single document and, in my opinion, the sensible organisations of any size don't attempt to cram it all into a single document.

So, why not an all embracing short document setting out the organisation's overall position that will apply globally.

Then work out what bits of the "organisation and arrangements" will work:

(a) globally

(b) across a whole region e.g Europe

(c) what needs to be bespoke to a country or even part of a country?

+ within (a), (b) and (c) what will be appropriate whatever the work, and what needs to be bespoke to people doing certain things. I'll come back to this at the end.

Nobody is going to read a health and safety policy statement if it sets out the minutiae of when fire alarms need to be tested.

When I worked for the HSE, on a single occasion I wrote a prosecution report with just a single charge relating to the H&S policy.

....and it didn't say that the organisation (a construction contractor) didn't have one but rather that it hadn't brought it to the attention of all its employees.

So, it got to Court and the company pleaded guilty but the Defence solicitor asked the Sheriff if he would like to see the policy statement in force at the time of the incident (and noted that it had been amended in the meantime).

The document was 30 pages long.

The Sheriff asked the Defence solicitor whether he was expected to read this.

"No, My Lord, I was just trying to demonstrate that my client did have the relevant document."

"It's 30 pages long."

"Yes, My Lord."

"Do you expect a joiner to use this as bedtime reading on a Thursday night?"

"No, My Lord."

"Do you expect that perhaps a bricklayer will take it down to the pub on a Friday night to discuss it with their workmates?"

"No, My Lord".

"Well it's far too long, isn't it? It should be one or two pages long so that it can be easily read and assimilated."

Spot on.

A few years later, I started a job as my employer's very first in-house OSH professional.

To help me the company had commissioned a consultant to draft a health and safety policy statement.

It was 300 pages long!!

To be fair the consultant had obviously done their homework, so it covered everything that our staff might be expected to regularly encounter.

But my comment to the architect of my job on my very first morning in said job was that how one safeguarded a circular saw on a construction site was of absolutely no relevance to our admin staff in head office.

I did promise to recycle some of the work done by the consultant (though I am not sure that I did as I am just as capable of cutting and pasting from HSE guidance on circular saws etc etc etc as the consultant).

But we got out a statement of general policy that ran to less than two pages.

Then systems, then guidance.

A few years later, we decided we should get into railways.

Now railway have their own rules. We could have taken those rules on board and applied them to ALL our operations but to do that would have had huge repercussions.

So, instead we put in place rail specific procedures to supplement our company wide systems. 

thanks 2 users thanked peter gotch for this useful post.
MikeKelly on 30/07/2024(UTC), Locoperro2023 on 31/07/2024(UTC)
A Kurdziel  
#3 Posted : 30 July 2024 08:30:40(UTC)
Rank: Super forum user
A Kurdziel

If you are going to do a European wide policy, you could do worse than start  with the EU OSH "Framework Directive". This which was drafted in 1989 sets out what all countries should be doing as far as OSH is concerned. It is very basic but sets out the following:

  • A definition of work
  • It takes into account technical safety and the  general prevention of ill-health.
  • It establishes the principle that all works are entitled to an equal level of health and safety protection.
  • It places the duty on  employers to take appropriate preventive measures to make work safer and healthier.
  • It establishes  risk assessment as the means to manage  health and safety issues.
  • It defines the  main elements  of risk assessment as hazard identification, worker participation, introduction of adequate measures with the priority of eliminating risk at source, documentation and periodical re-assessment of workplace hazards.

 The policy statement ( one or two  page document) should refer this and then tell local units that they need to incorporate these principles into their local rules.

I hope that you are not trying to create a single H&S manual for the whole European wide  business because that just will not work.

thanks 2 users thanked A Kurdziel for this useful post.
peter gotch on 30/07/2024(UTC), Locoperro2023 on 31/07/2024(UTC)
Locoperro2023  
#4 Posted : 31 July 2024 08:11:48(UTC)
Rank: New forum user
Locoperro2023

Good morning, 

Thank you for your advice, 100% agree a single document for the whole group is a non starter.  

Ciaran Delaney  
#5 Posted : 17 August 2024 07:44:20(UTC)
Rank: Super forum user
Ciaran Delaney

Look at the Irish Health and Safety Authority website - www.hsa.ie They are very good at transposing EU legislation into Irish law and the guidance is excellent
thanks 1 user thanked Ciaran Delaney for this useful post.
Locoperro2023 on 09/09/2024(UTC)
peter gotch  
#6 Posted : 17 August 2024 09:34:51(UTC)
Rank: Super forum user
peter gotch

Hi Ciaran

Welcome back!

P

thanks 2 users thanked peter gotch for this useful post.
Kate on 17/08/2024(UTC), Ciaran Delaney on 18/08/2024(UTC)
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