Policy & Procedure
First, let us define these terms:
What is a Policy?
Policies are, simply, documents that capture your intentions for dealing with an activity within your business. It may, or may not, include a brief on how you intend to carry it out.
What is a Procedure?
The procedure is the detailed plan on how you, actually, carry it out: the instructions for how you will achieve it.
Policy vs Procedure
- Policy = intentions: the “what”.
- Procedure = instructions: the “how”
What You Stand For!
Between the pair, they become the instruction manuals for your business, and thus guide your company, and your decisions, in the way it, and you, behave.
You need to have an aim – the policy itself with clearly defined goals – for what you want to achieve, so as to ensure a consistent and fair approach to your pursuits.
Your objectives should be precisely defined so that the results of your chosen actions match those intentions.
It is by forming a policy – an expression of what you stand for; what you believe in; what you want to achieve – and implementing procedures – instructions on how you will achieve those beliefs and intentions – that you shape behaviour and create a culture throughout your company.
Writing it is the easy bit. By far, the hardest part of policy is ensuring that you, your employees, and the business, acts in harmony with it!
Essentially, a good policy will be:
- Written in language that is easy to understand and practical to apply with clear instructions.
- Highlight the benefits of the purpose to the company and the employee.
- Be fair and reasonable in its intention and effect.
The Policy Library
Why do you need them?
Well, for some policies at least, it is a legal requirement. Not all policies are equal though, as not all are required legally.
Those that are include the H&S policy, the GDPR (data protection), Terms of Employment-Grievance & Disciplinary, for example.
Many others are just complimentary and are often requested by accreditations and tender packages. These include: Sickness & Absence, Quality, Business Continuation, and even a “Bring your own device to work” policy, to name a few.
You can literally have a policy for any activity that your business undertakes: using equipment, safety on site, travelling to and from work; how you turn up to work, how to behave at work; anything.
There are a few common ones, though, that get requested time and time again: Health & Safety, Environmental, Quality, Equality & Diversity, Modern Slavery, and, for most of us, these should be given due focus.
Depending on your company size (+/- 5), activity, and association, for most policies (other than the legally required ones – such as the HASP – of course) you will only need a short prepared “Statement” (see column across) rather than a full policy and, as we said above, not always necessary to have it in written form (4 or less employees).
State Your Purpose
Policies should not be confused “Statements”.
The company policy (on anything) is not the same as the company “Mission Statement” and the HAS Policy is not the same as the “HAS Statement.”
Sometimes you are asked to submit the “HAS Policy, while other times, you are just asked for the “H&S Statement”.
A policy is the detailed document described to the left (usually taking a few pages).
The “Statement”, however, is a short summary of that policy, often captured on a single page (as is the case for the HAS Statement) or even in a solitary paragraph (for all other polices). It captures the intention but leaves out the instruction.
It Starts With You!
Once again, SLAM starts with the one at the top – the owner.
As said above, a policy is an expression of what you stand for; what you believe in. It is what you want, and how you intend to do it. So be careful about what you write.
As a leader, you have to remember that example is everything. So, whatever you write in a policy, you should be willing to hold to and be prepared to do.
Don’t write anything that sounds good, but you have no intention of following.
This is often the short-fall of copy-&-pasting stuff from the internet or pilfering from others’ policies. I have, on many occasions, read a company’s policy only to read stuff that not only were not following, but literally could not follow, as it just was not relevant to their scope of works.
Clearly, some just download ones – or copy a good-looking version from some other source – but do not read them through to check; but are quite happy sending them out to all who ask, evidently oblivious that they often propose procedures and sanctions on services that they do not even provide!
This is, sadly, quite a common practice.
By all means, copy, pilfer, plunder or purloin as much from the net or your peers as you like: there is some pretty good stuff out there, in the “free domain” but you must read it carefully and prune it to your convictions and services.
The STRAW-SACK Plan
Most policies follow the same process and format. So, if you have a style and layout for one, you can use it for all.
So, whether you are starting from scratch, or weeding an old one, here is a seven-step plan for policy production:
ST is for Statement
This is the What!
As you will notice, the “Statement” is part of the policy, not the policy.
The “Statement” is often extracted and presented as a separate one-page document, and sometimes (in the case for the ‘H&S Statement’) a legal requirement to have it displayed within offices or sent to accreditations, and the like.
I stress again, however (and only because it is so common that the two are thought as one – they are not: there is no Spice Girl moment here! If you are asked for the ‘Policy’, don’t send just the Statement. If they ask for the ‘Statement’ then by all means, send the one-page wonder on its own.
A crucial element of the H&S Policy, and thus the Statement, is that it should outline the aims of your company and its commitment to the management of health and safety (or whatever subject you need a policy for; but from here I will focus on the HASP: the same guidance will still apply for all policies).
The H&S Policy Statement will set out how you intend to manage health and safety within your workplace. It demonstrates your businesses attitude towards health and safety and the steps, arrangements and management systems that you have in place to ensue you comply with current health and safety legislation.
As the employer, or the most senior person in the company, you should sign the Statement of intent, as well as the full Policy, and review them regularly.
- ST – Statement of intent
- R – Responsibilities
- A – Arrangements
- W –Who Affected
- SA – Safety Advise
- C – Communications
- K – Keep it up to date
R is for Responsibilities
This is the Who?
From here, we evolve past the “Statement” into the body of the “Policy”.
Who does what is an essential aspect of the actual policy.
Now, this is easy if it is just you, as you will be doing everything, probably, but there might be elements of the business that you sub-out or delegate to a third-party (for example, see Advice, below)
Your policy will need to include a responsibilities section. This section should include details of those people within the organisation who have specific, assigned, responsibility for the management of Health & Safety, and all related duties.
The policy should set out how your business will approach and discharge its duties in relation to the Management of Occupational Health, Safety and Welfare – ultimately affirming its commitment to preventing accidents, injuries and ill health.
It should identify who holds the accountability for Health & Safety management, and who has the responsibility to ensure those arrangements are followed. For example, the Managing Director of the company may hold the overall accountability.
Example: The policy will need to set out who has ultimate responsibility for health and safety, for example the Managing Director of the company (the buck stops here principle), but responsibility for implementation of those measures might be given to a subordinate manager.
Then identify any nominated employees who have been assigned duties, such as a Health and Safety Manager, or Co-coordinator, or if any specific responsibilities for health and safety matters have been assigned to line-managers, such as who will be responsible for documenting, monitoring, and reviewing risk assessments.
A is for Arrangements
This is the How!
The Health & Safety Policy (HASP) will need to include an arrangements section. This is likely to be the longest section of the policy.
The arrangements section of your HASP should clearly outline the way in which you will meet the commitments that you have made in your Statement.
The arrangements section should include information on what you are going to do to remove – wherever practical – or reduce – wherever reasonable – risks and control hazards in your workplace or from within your work activity.
This section should cover all relevant categories of activity that you plan to undertake and can include detailed information regarding risk assessments, control measures, safety training, safety monitoring, accident reporting and investigation, etc. These measures will go on to form your detailed Safe Systems Of Work (SSOW – to be covered in another article).
Example: If you are a Window Cleaner, your arrangements should highlight controls for Working At Height (WAHR, 2005); for use of hazardous substances (COSHH, 1992); use of equipment (PUWER, 1998) Manual Handling (MHO, 1992), etc. It would also include your provisions for providing suitable and sufficient risk assessments, training, supervision, and providing relevant information & instruction.
Categories of Activity
A good, structured approach for going about this coverage (which is common for many H&S Polies) is to run through the current H&S Regulations and select the ones relevant to your company’s chosen activity.
W is for Who Affected & How?
What’s the Worst that can happen…?
This “who” is distinctly different form the first “who”. Previously we needed to know who does what, but now we need to know who may be affected by what.
How could your service adversely affect others?
Although a Health & Safety Policy is primarily concerned with the health and safety of its employees, it should also identify who is likely to be affected by the work or service you are providing?
This should include considerations for the safety of other persons, such as sub-contractors, members of the public, visitors or anyone else who may be affected by any work activities carried out by your business, or on your behalf.
In each policy section, once you identify who is affected by the subject matter you will need to explain how this will be addressed.
Example: If your company uses sub-contractors on a regular basis, your policy should have a dedicated section that clearly details the way in which those sub-contractors will be managed and the safety procedures they will be expected to follow.
If your work is performed within the proximity of third-parties or members of the public, likewise, you will need to detail how you will segregate the works from them or control the risks of contacting them.
SA is for Safety Advice
Who you gonna’ call?
Who will give you competent safety advice? It is expected that you appoint someone – if not yourself – to be responsible for your safety management.
Whoever this may be, they need to be competent. Again, if it is just you, then you will be the primary candidate for this job, but you need not keep this to yourself. It is perfectly acceptable, and often advisable, to seek external support for this one.
As an employer you are expected to appoint someone who is competent to assist you in meeting your health and safety responsibilities.
Example: Who is your nominated competent person? You could appoint (one or a combination of):
- Yourself
- An employees
- Someone from outside of your business (a consultant).
If you’re not confident in your ability to manage health and safety in-house, you will need to seek the help and advice from an external source, for example a qualified health and safety consultant.
For what constitutes competence, see my article on “What MAKES Competency”.
C is for Communications
It’s good to talk!
Successful Health & Safety Management is anchored on effective communication.
The Policy must be brought to the attention of your employees and be revised whenever appropriate.
Any information you are planning to communicate, regarding health and safety should consider:
- Has sufficient time been made available?
- Think about what needs to be communicated and to whom.
- When and how will the training be delivered etc.?
Example: A company with multiple sites will need to ensure that all employees are fully aware of the policy and any updates. This could be communicated through a team meeting at each site or delivered via line managers.
For a smaller company with only one site, this could be delivered directly through established lines of internal communication, e.g. team meeting, safety briefings etc.
Don’t forget to share all health and safety related information with any new employees, who join the business.
K is for Keep It Up to Date
Review, Revise, Renew
As with all H&S documents, it should not be a one-time done deal. It should live; grow; adjust and be amended as your company develops.
You will need to review it every year, revise where necessary, and re-date and sign it afresh.
If your services expand, you will need to add a note to the policy, making sure you assess each expansion with each of the guidelines above. For example, if you are a window cleaning company and decide to offer some floor-buffing, you will need to consider, and add, the use of electrical equipment to the “Arrangements” section. New equipment, new training, new risk assessments for example.
Perhaps your expansion is through manpower? Then you might have to add to the Responsibilities section any additional levels of supervision or management processes.
You do not need to write a biography on the company, just an outline of its existence and a map of its services. It must, however, cover all the bases. I often notice some pretty basic elements get missed out, such as the safe arrangements for using chemicals (under COSHH), or the driving of vehicles (under PUWER), so be thorough.
Be aware, however, that as you grow, the expectations of the policy inclusion will also grow. Many industry accreditations have very strict expectations for what they want included within a policy. So be prepared to have to add its every now and then, but never put in what you can’t put out! Don’t make promises you won’t or can’t keep, don’t make claims you are not prepared to provide. That will only get you into trouble and is not the SLAM way!
Finally, the STRAW SACK method will work equally well with any type of policy you need to write -not just H&S. If you need to prepare a HR policy, a GDPR policy, or an Environmental policy, regardless, the key elements will generally be the same, so just follow the outline and tailor the details to the new subject.
It all starts with the policy. Everything else will flow from here. So, now the intention has been set, we can now focus on the implementation.
So then, there you have it: the STRAW SACK introduction to preparing your H&S policy (or any policy, for that matter). As long as you include these basic elements, you will have the backbone of a solid policy.
