ISO45001 and The Occupational Health & Safety Policy - stop doing it wrong!

We have all seen them, pinned to noticeboards inside the company handbooks and, if you're lucky, as part of a presentation at your induction. 

What is in your OH&S Policy, and what shouldn't be there!

ISO thinks the Occupational Health & Safety Policy is pretty important, in fact it is the most important document of your entire system. For that reason, they have set some very clear requirements about what should be included in it and what it should do.

Like all documents it needs to be appropriate to the purpose, size and context of your organisation, in other words, don't write something for a multinational when you are 10 people. That said even a multinational's policy doesn't need to be more than half a page of A4… yep, that's your target size for your entire policy!

It must include a commitment to provide safe and healthy working conditions for the prevention of work related injury and ill health. As always when people think about health and safety they always default to safety, however the health part is critical and so it needs to be part of your thinking and your policy. Afterall, looking after the long-term health of your employees just makes sense, doesn't it?

It needs to provide a framework for setting your OH&S objectives, now what it means here is that it should define the how you will decide on the objectives, for example if you had major issues with machine guarding or ergonomics (which you'd know because they would be high up on your risk register) then you would say that your objectives are going to be linked or driven by to the key challenges of your organisation such as ergonomics, machine guarding, psychosocial issues such as workload, fatigue and so on. You would then start developing objectives based about these things.

It seems obvious but is often forgotten, you need to have a written commitment to fulfilling your legal requirements and any other requirements you have either agreed to or had imposed on you as an organisation, either by customers, government agencies or court decisions for example. That means later we're going to be looking for a register listing all those things as well.

It needs to have a commitment to eliminate hazards and reduce OH&S risks, which really shouldn't be a surprise, yet many companies miss that eliminate part and go for reduce only, that's not allowed!

It must have a commitment to continuous improvement of your entire Occupational Health & Safety Management System. While not implicitly stated It even needs to be considered when you have a rethink of your strategic direction, or way of operation.

All that is easy to do, the thing that is hard and probably the most important requirement of the occupational Health &S safety policy is that is needs to include a commitment to consultation and participation of workers, and, where they exist, workers' representatives. Come audit time, you better believe the auditor is looking for this and importantly evidence that you did this. For clarity, you need to do it before you finalise the policy, they need to be able to genuinely input into the document, to help shape it and choose the words that are in it, it's not a rubber-stamping exercise.

The way to do this is to start with a draft you have created with your health & safety committee and then get them to circulate it to their areas, collect feedback, have town hall meetings if needed and then collate that feedback and do the updates. There may be several rounds of this and it may feel slow but it's important and it builds buy in to the system.

Remember the key rule of creating a brilliant Occupational Health & Safety Policy is, Keep It Simple. Don't create something that team of lawyers or English professors are needed to explain it. This must be accessible and credible to everyone at every level in the organisation and they may not have you at their side to explain it to them so, keep it simple. 

So that's what's in the policy, what's not:

Ever see a OH&S policy where is starts defining all the roles and responsibilities, who will do what, when and so on. At no point does ISO (or anything else) need that in your policy. It belongs in only one place, your job descriptions – that makes it a legal requirement your employees follow through. Adding it anywhere else is just noise, confusing and makes the document way more complicated than it needs to be. Adding it to your OH&S policy makes the document unwieldy and unreadable. Your policy needs to be simple clear and to the point. As a leader, you should be able to repeat it in the corridor or at a meeting without having read it, that's how brief it should be, and it should be heart felt verging on inspiring, after all it's your call to arms for Occupational Health & Safety in your organisation!

Make your policy available

 Your Occupational Health & Safety Policy is one of the few things in your ISO system that must be documented. How you document the policy is largely up to you and what makes sense for your organisation. It can be a bit of laminated paper pinned to the wall or a large A1 poster or if you have a fully-fledged integrated Occupational Health & Safety Management System like Mango maybe it's in the cloud for everyone to access as required, the choice is yours.

The standard requires you to ensure that the Policy is available to anyone who is interested in seeing it which includes both internal & external parties, many companies now have it on their website for example.

Since you had your team help you develop it most will know the policy, but it is important that you do formally communicate it inside your organisation. Spend the time and talk about what it means and why it's important, how it fits with your organisation and how you are going to live this policy. Record that training for everyone as well!

Don't forget to maintain it!

Like all system OHSMS and policies, it needs to have a maintenance schedule of its own, you need to plan to review it. This should be at a frequency that makes sense to you, it could be annually, it could be when you are changing your strategic direction, you need to decide what makes sense, but you do have to do it. Again there are easy ways & hard ways of doing it, you can hope that someone remembers, you can put into someone's email calendar & hope they are not off that week to remember or you can put it into your Mango System and it will remember for you (and of course send everyone emails to remind them).

A final hint when reviewing the Policy to check if it still makes sense, include some of the staff that helped design it and if possible, some that didn't. Really challenge it and if it still stands up, sign it off and move on, if it doesn't fix it, communicate it then carry on.