Writing a School or Departmental Safety Policy

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Writing a School or Departmental Safety Policy

• Presented by Andrew Knight University Safety
  Adviser

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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..

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Fire and Emergency

• Alarm sounder
• Assembly point

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Other details

• Toilets
• Mobile phones
• Questions
• Confidentiality

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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.

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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

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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

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Introduction
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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

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Why have a policy?

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

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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

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Framework of the policy - HSG65
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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

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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

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Why have a policy 2 of 4

• Section 2(3) of the HS 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

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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

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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.

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Business Benefits
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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

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Business benefits

• Why bother? We have a University Safety Policy?
  Do we REALLY need another policy?
• Positive and negative
• FLIP CHART

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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

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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

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BREAK
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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

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Planning
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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

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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

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EFM Case Study
Policy launch
Policy sent to HOD, approved and signed
Amendments to policy made
2nd draft produced for discussion at SMT
Review
Draft text prepared for comment by teams and
Trade Union Representatives
A series of meetings with Senior Managers arranged
Meetings with Health and Safety Department, Trade
Union Safety Representatives
Informal information gathering from discussion
with site based teams and site inspections.
Meeting with Senior Management Group to propose
Health and Safety programme. Policy need agreed,
timescale set.
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Writing the Policy
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Competence / Training
Procedures
Environment
Health and Safety Policy
Activities
Equipment
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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.

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Policy structure

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

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Step 1 Statement of Intent
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Statement of Intent

• Commitment to health and safety
• Show case
• Aspirational, but should be realistic and
  achievable

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Statement of intent 1 of 7

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

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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'

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Statement of Intent 3 of 7

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

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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

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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.

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Statement of Intent 6 of 7

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

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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

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Practical exercise

• Handout

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Step 2 Responsibilities
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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.

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Step 3 Organisation
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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

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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.

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Documenting Change

• Presented by Alan Cowen

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Lunch
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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.

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Step 4 Arrangements
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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.

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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

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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)

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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

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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

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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.

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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

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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

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Practical exercise

• HANDOUT
• Arrangements sections

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Step 5 Monitoring and Review
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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

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Health and Safety Executive Model Policy

• HANDOUT

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BREAK
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Implementation
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Challenge generic content

• Dont 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!

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What is an Effective policy?

• The policy needs to be implemented!

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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

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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?

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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

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Living document or dead in the water?

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

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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

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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?

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Communicating the policy

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

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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

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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

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Sustainability

• Health and safety poster campaign
• Tool box talks
• Web pages
• Notice boards
• Policy launch photo opportunities

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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

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Implementation

• Has the policy been signed and dated?

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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)

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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

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Model Policy

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

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Action Planning

• HANDOUT

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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

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