Writing a School or Departmental Safety Policy

Presented by Andrew Knight University Safety Adviser

From experience

• Andrew Knight – University Safety Adviser• Has written or assisted writing policies for:

– University of Brighton Estate and Facilities Management Department

– Honourable Society of the Inner Temple– Ordnance Survey– North East Surrey College of Technology (NESCOT)– Bradford and Bingley Geering and Colyer– South African Airways– INMARSAT– Pets to the Vets– Air Mauritius

• And many more…..

Fire and Emergency

• Alarm sounder

• Assembly point

Other details

• Toilets

• Mobile phones

• Questions

• Confidentiality

Group

• Introduce yourself to the person next to you. Discuss what experience you have in writing policies and what you hope to get out of today.

Course overview

• The course aims are to:– Examine the essential content of a school

safety policy and the process by which the policy is formulated, agreed and issued.

– Enable delegates to draft and implement an effective school safety policy

– Make recommendations on how the policy will be updated and reviewed

Course objectives

• Have knowledge of what information should be documented within a school safety policy

• Be aware of factors that affect whether a policy is ‘Effective’

• Examining why local policies are needed

Introduction

What is a School or Departmental Safety Policy?

• It is a document structured in the same way as the University Safety Policy, but containing arrangements specific to the School.

• It sets out specific responsibilities and makes staff accountable for health and safety

Why have a policy?

• FLIP CHART

• Why do you think it is necessary / important to have a policy?

Why have a policy?

• Who, what, when, how!

• Clear communication of health and safety responsibilities

• Sensible to set out the local arrangements for managing health and safety

• Policy writing is as much about the process, as the end result

Framework of the policy - HSG65

Why have a policy?

• The Management of Health and Safety at Work Regulations 1992 introduced a legislative requirement for Planning, Monitoring, Implementing, Review

• This was translated by UCEA into University sector guidance ‘University Health and Safety Management – Code of Practice’

Why have a policy? 1 of 4

• The Health and Safety at Work Act 1974 requires that businesses employing 5 or more employees must have a written health and safety policy

Why have a policy 2 of 4

Section 2(3) of the H&S at Work Act 1974 states:• "It shall be the duty of every employer to prepare

and as often as may be appropriate revise a written statement of his/her general policy with respect to the health and safety at work”

Why have a policy? 3 of 4

• The policy must state the general policy on health and safety.

• Describe the organisation and arrangements for carrying out the policy

• Be brought to the notice of all employees

Why have a policy? 4 of 4

• Be revised whenever appropriate, and every revision must be brought to the attention of all employees.

• It is a legal requirement under the Act, and has to be complied with.

Business Benefits

Business benefits

• It is important to identify the benefits and reasons for a School Policy. This can be useful for building a business case or influencing members of staff who may need to contribute

Business benefits

• Why bother? We have a University Safety Policy? Do we REALLY need another policy?

• Positive and negative– FLIP CHART

Business benefits

• Enhanced reputation• Specific hazards from School activities • Specific organisational arrangements• Individual responsibilities e.g. Radiation

or Biological Safety Officer• University Safety Policy does not

contain detail on local arrangements• Induction of new staff

Business benefits

• Reduce accidents and ill health• Reduce number of civil claims• May provide defence in civil proceedings• Boost staff morale• Demonstrates management commitment• Ensures consistency in approach to health and

safety• Saves time from duplication of effort• Improves communication

BREAK

Links with the University Health and Safety Policy

• The University Safety Policy requires that Heads of School document a School Safety Policy

• A School policy is sub-ordinate to the University Safety Policy

Planning

Getting started

• Commitment from HOS/HOD – Crucial!!!• Identify resources• Sufficient time• Good knowledge of staff roles and

responsibilities• Good understanding of the working practices

within the school• Able to use a word processor• Able to communicate with all staff• Gather together existing policies and procedures

Formulation process

• Who will you need to involve? E.g. Trade Union Consultation

• Consider whether the policy will need to consolidate and rationalise a previous piecemeal approach to safety policy documentation?

• May need a series of meetings with Senior Managers

Rev

iew

Informal information gathering from discussion with site based teams and site inspections.

Meetings with Health and Safety Department, Trade Union Safety Representatives

A series of meetings with Senior Managers arranged

Amendments to policy made

Meeting with Senior Management Group to propose Health and Safety programme. Policy need agreed, timescale set.

Draft text prepared for comment by teams and Trade Union Representatives

Policy sent to HOD, approved and signed

Policy launch

2nd draft produced for discussion at SMT

EFM Case Study

Writing the Policy

Competence / Training

Activities Equipment

Health and Safety Policy

Environment Procedures

Achieving its aim

• The policy should be specific to your business, and should be clear about arrangements and organisation for health and safety at work.

• It should influence all your activities, including the selection of people, equipment and materials, the way work is done and how you design goods and services.

Policy structure

• We are now going to examine each of the essential policy sections:– Statement of Intent – Responsibilities– Organisation– Arrangements– Monitoring and review

Step 1 Statement of Intent

Statement of Intent

• Commitment to health and safety

• Show case

• Aspirational, but should be realistic and achievable

Statement of intent 1 of 7

• The statement should outline in broad terms the School’s overall philosophy in relation to the management of health and safety

Statement of Intent 2 of 7

• Commit to operating the business in accordance with the Health and Safety at Work Act 1974 and all applicable regulations made under the Act, 'so far as reasonably practicable';

Statement of Intent 3 of 7

• Specify that health and safety are management responsibilities ranking equally with responsibilities for delivery of services

Statement of Intent 4 of 7

• Indicate that it is the duty of management to see that everything reasonably practicable is done to prevent personal injury in the processes of production, and in the design, construction, and operation of all plant, machinery and equipment

Statement of Intent 5 of 7

• Indicate that it is the duty of all employees to act responsibly, and to do everything they can to prevent injury to themselves and fellow workers.

Statement of Intent 6 of 7

• Identify the main person with prime responsibility for health and safety (e.g. Head of School)

Statement of Intent 7 of 7

• Be dated so as to ensure that it is periodically revised in the light of current conditions

• be signed by the Head of School

Practical exercise

• Handout

Step 2 Responsibilities

Responsibilities

• Roles and responsibilities should set out clearly who is responsible for what.

• Key individual responsibilities e.g. Assessors should be identified.

• It is normal practice for the health and safety reporting and delegation lines to mirror the lines for the School.

Step 3 Organisation

Organisation (people and their duties)

• The organisation section sets out the system of reporting lines and delegation for health and safety within the School

• Committees and planning groups will need to be identified

Organisation (people and their duties)

• Individual job descriptions having a safety content

• Details of specific safety responsibilities • The role and function of safety committee (s) • The role and function of safety

representatives• A management chart clearly showing the lines

of responsibility and accountability in terms of health and safety management.

Documenting Change

Presented by Alan Cowen

Lunch

A cool reception!

• An accident has recently occurred in a University laboratory, at the University of Hardknocks

• A student was badly burned by contact with Liquid Nitrogen whilst extracting samples from a Dewar. The accident was reportable to Health and Safety Executive.

• Principal Lecturer Andrew Knight is responsible for the course involving the use of Liquid Nitrogen.

• HSE Inspector Alan Cowen is tasked with investigating the accident and meets with Andrew Knight.

Step 4 Arrangements

Arrangements

• Generic – e.g. Accidents, First Aid, Access, Accident Investigation

• Specific – COSHH, Manual handling, Portable Appliance Testing

• Sensitive arrangements – e.g. Security, Animals, Toxins, Explosives, Radiation, Money.

Essential arrangements 1 of 2

• Managing risk assessments

• Arrangements for consultation with employees

• Arrangements for maintaining plant and equipment

• Arrangements for safe handling and use of substances

Essential arrangements 2 of 2

• Arrangements for providing information, instruction and supervision

• Arrangements for training• Arrangements for accidents, first aid and ill

health issues• Arrangements for monitoring (e.g.

frequency of inspections)• Emergency procedures (e.g. Fire

Wardens)

Arrangements (systems and procedures)

Other arrangements may include:• Safety training• Safe systems of work • Environmental control • Safe place of work• Machine/area guarding • Housekeeping• Safe plant and equipment

Arrangements (systems and procedures)

• Noise• Radiation safety• Use of toxic materials• Communication and consultation• Medical facilities and welfare; • Maintenance of records • Expectant and nursing mothers• Young persons

Arrangements - performance standards

• Arrangements section can contain references to the associated University Codes of Practice / BS / HSE guidance or legislation for further advice and guidance.

• It is not necessary to duplicate a university Code of Practice if it accords with the School approach.

Arrangements Example WAHR

• Register of equipment

• Planning and organising

• Hierarchy of control for WAH

• Inspection and tagging

• Competence standards and training need

• Monitoring of works

• Weather restrictions

Arrangements Example COSHH

• COSHH requires statutory testing of LEV

• Personal protective equipment requirements (could link to University CoP)

• Health surveillance

• Hazardous waste disposal

• Specialists e.g. Biological Safety Officer

Practical exercise

• HANDOUT – Arrangements sections

Step 5 Monitoring and Review

Monitoring and review

• Frequency for review will depend upon activities– minimum every 2 years

• Auditing of the policy should be undertaken to determine if the arrangements are being adhered to

• Inspections• Staff SDR• Accident investigations, trends

Health and Safety Executive Model Policy

• HANDOUT

BREAK

Implementation

Challenge generic content

• Don’t fall into the trap of copying a policy from a Google search

• When writing or revising a policy challenge each section. There have been instances where Fairground Rides have been found in a School policy!

What is an “Effective” policy?

• The policy needs to be implemented!

What is an ’Effective' policy?

• Applicable / specific• Contains 4 key headings• Accurate details• User friendly – well laid out, easy to navigate• Clear and unambiguous• Concise – no padding• Up-to-date• Accessible – website, bulletin• Easily to update

The good, the bad and the ugly!

• Practical Exercise - Working in pairs critically analyse these real life policies. Decide whether the policy is well written and likely to be effective? Does it have all the sections?

Layout, style and document control

• Page number e.g. Page 1 of 1

• Document control showing revision and version history

• Clear, easy to read font and font size

Living document or dead in the water?

• Continuously updated to reflect changes in legislation, used daily, different people, new staff and frequencies

Policy approval

• Who will need to approve the policy? Most instances this will be the Head of School and Senior Management Team

• Consider specialists committees or forums? E.g. Biological Safety Committee

Communicating the policy

• The policy should be communicated to all staff and possibly contractors

• Question - Why would you need to communicate the policy to contractors?

Communicating the policy

• The statutory health and safety law poster requires that health and safety information is communicated. A written policy achieves this.

Policy distribution 1 of 2

• An introductory letter, signed by the Head of School should be appended to the policy explaining the reasons for the policy and what staff need to do

• Issue electronically via e-mail to individual staff, or use paper copies for workers without PC access e.g. Cleaners

Policy distribution 2 of 2

• Issue a summary copy or signpost in the form of a leaflet

• Give a copy to all new employees as an integrated part of the induction programme

• Affix the policy statement to notice boards

• Ensure that any superseded policies are destroyed

Sustainability

• Health and safety poster campaign

• Tool box talks

• Web pages

• Notice boards

• Policy launch photo opportunities

Making it happen

• Agree a target date for completion

• Send a draft to the University Safety Advisor

• Block out time in your calendar to write the policy

Implementation

• Has the policy been signed and dated?

Common problems

• Unable to locate policy• Policy too generic / none specific• Policy not issued to all staff• Use of jargon or acronyms• Insufficient detail• Out of date - in a format that is difficult to revise• Missing essential sections (e.g. Organisation)

Proof reading

• Ask a colleague to read the policy

• Check spelling, punctuation and grammar

• Does the policy flow well

• Is the font size suitable

• Are colours reproducible

Model Policy

• HANDOUT – This is a model policy that can be used as a basis for your own policy.

Action Planning

• HANDOUT

Key messages

• Every health and safety policy must be a unique document

• Framework

• Process – look beyond the document

• Manager buy-in

• Sustaining

• Help and support