When the HSE comes across serious breaches of health and safety legislation it will look to see where the buck stops. What type of evidence will persuade it that directors and senior managers are fulfilling their responsibilities?
Whilst most senior personnel don’t deliberately act irresponsibly, they’ll often struggle to prove they’ve done the right thing when a health and safety inspector is in front of them asking difficult questions. This is therefore an area which is worth some forward planning. You should begin by considering the contents of your health and safety policy. It should have three parts: (1) a statement of intent; (2) details of roles and responsibilities, known as your “organisation”; and (3) a description of your arrangements for implementing the policy. Your organisation statement should show how the board will oversee health and safety and allocate responsibilities to each level of management and staffing.
- It’s good practice to nominate a director with responsibility for health and safety. However, ensure that there’s a proper understanding that this individual is simply overseeing the work of the board, not taking away from its collective responsibility.
- Include health and safety as a standing item on meeting agendas, including those for the board and senior management team.
To fulfil their health and safety duties, directors need a reasonable level of understanding of the issues.
- Having a briefing for directors on health and safety responsibilities is a good way of boosting competency and recording that they’ve been trained. You could pick from one of the off-the-peg training courses or ask a health and safety trainer to update the board on the topic.
- One aspect of the briefing should be a reminder of the rules to be followed on site such as restricted areas, personal protective equipment, signing in and out, hygiene measures, etc. Directors must lead by example, being aware of the damage caused to safety culture if they are not seen to be following the rules themselves.
- Arrange for regular updates to the board on the latest external developments of interest such as legislative changes and key cases.
It’s too easy for senior personnel to make incorrect assumptions about what’s happening on the ground. Directors should therefore receive regular reports as well as take steps to get direct and truthful feedback from staff.
- Ensure that your accident reporting procedure includes the need to escalate reports of serious incidents very quickly to a high level. The same should happen where bad publicity is likely, even if there were no serious injuries.
- By ensuring that staff are consulted on health and safety matters, such as during team meetings or in a dedicated health and safety committee meeting, you’ll have a better chance of understanding what the real problems are. Directors should receive reports from these meetings.
- It’s good practice to have a regular audit undertaken to understand whether the commitments contained in the health and safety policy are being delivered.
Your health and safety policy should include clear responsibilities for directors and they should be briefed to ensure they understand them. Health and safety should be a regular agenda item and include reports of accidents, audits, staff consultations and changes to legislation.