We’ve been tortured by this puzzle for years: how can you check that you’ve taken the right actions to comply, not with H&S law this time, but with your own adopted H&S Policies (which usually contain a mix of legal and ‘best practice’ content).
Many organisations commission an inside expert or outside consultant to draft suitable policies. But after the initial read-through and signing of the ‘Statement’, often very little reference is made to what’s written over the years.
It’s very laborious to go through what can be 40-50 pages of policy arrangements and considering whether anything requires an action, so Client feedback after the first draft has been produced is normally fairly limited.
Initially, we adopted the stance that if we were working with a client then it wasn’t really an issue as we would be able to keep checking back what was in the policies.
However, in truth, this doesn’t happen very often. I can never remember a time over the last 20 years that a client has ever suggested that maybe we should read their own policies or look to them for guidance.
Of course, there is great value in setting up the policy arrangements in the first place because the process forces you to examine the various compliance issues.
But even here, some clouding of the issues can creep in.
When writing new policies, no-one ever says: ‘We’re aware of our responsibilities under XYZ regulations, and currently we’re simply not complying with them’.
Instead the last bit usually says something vague like: ‘…and we will put in place the necessary procedures to ensure compliance’.
The fear is that there’s some commitment in the policy arrangements that is just waiting to embarrass you after an accident. It doesn’t take a very smart lawyer to notice that you already had a policy that – had it been actioned – would have prevented the accident in the first place.
Our clients can relax from now, because we’ve found a way to solve the puzzle that hadn’t been troubling them (phew!).
For those of you who have tested out our sample risk assessment form we’re adopting the same technique to take new clients through their own newly-minted H&S policies and develop an Action Plan.
In the recent past, this would be done fairly loosely by going through the policies page-by-page with the client.
The weakness with this approach is that it’s difficult to think ‘on-the-spot’ of many potential actions that would help embed the policy into the organisation. There’s just too little time and too many words!
The answer is for us to present the client with a selection of action ‘prompts’ alongside each policy and agree those that are most suitable.
We’ve done all the hard work and can suggest actions that the client might like to consider against each policy section.
Some of these will be ‘general management’ actions – nominating staff, briefing managers, instigating site checklists etc. Other actions may be to organise risk assessments – and these will take priority alongside the overall ‘General Risk Assessment’ exercise which is carried out with each new Client.
Using our new format, the chosen actions can easily be aggregated at the bottom to make a neat ‘Policy Action Plan’ document for the client to work through – preferably with our help 🙂