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John Wheeler
Member - 4 posts
Our recent H&S risk assessment resulted in a suggestion by the Assessor that the Company's H&S Policy Statement should be prominently displayed on site. At the moment it is easily accessible electronically on our IT network in an unrestricted folder containing a range of company personnel documents. Is physical display of a hard copy a legal requirement, or is accessibility the key point here?
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Kevin Brown
Member - 73 posts
Is it 100% accessible to all employees? Do you employ any non-DSE users? How would you demonstrate to a regulatory body that you have such a policy?
Regulation 5 of the Management of Health & Safety at Work Regulations 1999 requires employers to establish a positive approach to health and safety which is visible and clear. Are you wholly convinced tht it is?
It comes down to effective communication. Saving a file to a shared folder isn't the same as circulating a hard copy, or getting assurance that every employee has read it (even the technophobes). You might even have to consider Dragon, Jaws or Braille versions if you have employees with disabilities.
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Pasc Ruggiero, CFIOSH, FRSH
Member - 39 posts
There is absolutely no need to display the “statement” to the general policy produced pursuant to s2(3) of the HSWA 74 (usually the first page of the document signed by the MD or equivalent). This normally says that ‘we will comply with the law …….. reduce risks ……. etc. The presence or otherwise of this statement makes no difference other than it may show the ‘first shoots’ of management commitment. What really matters is the “arrangements” and DETAILED responsibilities contained in the remainder of the document; and management demonstrate by ACTION that they are committed to the policy(s).
Far better to display a current index of policies as a REMINDER.
Employers are required to train employees in each of their policies and check their UNDERSTANDING. A certified record of this helps. Appropriate documents (whatever medium) must be available to those employees who need to know.
Did the Assessor indicate whether or not the document(s) were adequate!
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Kate Gardner - Workplace Law Network
Online advisor - 19 posts
John
It is a legal obligation to make the health and safety policy readily accessible to anyone that it concerns, however as a competent policy is typically a long document it may not be appropriate to display a hard copy. In this case it would be appropriate to display the statement of intent on the company notice board and to make the whole policy available on the company intranet. The key is to ensure that it is brought to people’s attention and they are provided with information on how and where to access the policy.
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