Every business should have a health and safety policy. It sets out your health and safety arrangements and provides important information to your staff. Putting your health and safety in place isn't the end of the matter though, it should be regularly reviewed and kept up to date.
A health and safety policy is a legal requirement. If you employ 5 or more people, legally, you must have a written health and safety policy. Less than 5 people and you can get away with a health and safety policy statement, but if you work in a high-risk environment you really should consider a full policy regardless.
If you have health and safety policy in place, great. Bonus points if you make sure all your employees know about it (they should!).
Your health and safety policy is one of the key health and safety documents within your organisation. It is usually the first health and safety document people will look to when joining your business, and it is also a document that is regularly requested by potential clients, investors, stakeholders and insurance companies.
But when was the last time you reviewed your policy? When was it last updated? Last week, last month, last year? Has your business grown since then, or changed the way it works? Has the law changed?
Before we look at how frequently you need to review your health and safety policy, we need to know why. Why should you review your policy? Why might it need updating?
The Management of Health and Safety at Work Regulations require that where an employer employs 5 or more employees, there is a written health and safety policy document produced. It is also a requirement that the health and safety policy is kept up to date.
5.—(1) Every employer shall make and give effect to such arrangements as are appropriate, having regard to the nature of his activities and the size of his undertaking, for the effective planning, organisation, control, monitoring and review of the preventive and protective measures.
If your health and safety policy was fine when you wrote it, then what makes it go out of date? There are two key things that happen over time that will affect your health and safety policy:
Health and safety regulations get updated from time to time, and new laws get introduced. Your business may need to alter the procedures and arrangements in place to comply with these changes. Your policy should be updated to reflect that.
A policy will only be effective if you and your staff follow it and review it regularly.
Your business will also evolve over time. You might add new products and services. New technologies and procedures may get introduced. Your team might grow or shrink. You might outsource or insource certain requirements. Your policy will need to cover these changes.
Now we know why we need to update our policy, you should regularly review it to see if and when it needs to be updated. It's very important that your health and safety policy is:
If your policy is out of date because it refers to old regulations, then it's not likely to comply with current legal requirements. If it's not relevant to your business, then it's not much use for the activities you actually carry out.
So, when should you review and update your health and safety policy?
We say at least annually because there are times when you may need to update your policy sooner.
Changes to health and safety regulations usually happen twice a year, in April and October. Don't panic, changes don't happen to every regulation twice a year. But each year, a few pieces of health and safety law are amended, revised or new ones introduced.
With the law changing regularly, you should check frequently (at least twice a year) if any of the changes might affect you. If there are changes to regulations that do, then review your policy to make sure it complies with the changes. Update it if it doesn't.
What about other changes to your business? For example, if there are changes to your work procedures. As your business changes, develops and grows – so should your health and safety policy to address changing risks and safety issues.
If your policy is out of date it won’t comply with legal requirements. Keep it up to date with changes in your business as well as changes in the law.
You should also review your health and safety policy if it is found that any health and safety management procedures are failing, and adapt your procedures as needed to keep your workforce safe.
You identify failings through accident or near miss statistics. Or, you might notice through monitoring that procedures are not being followed or have been altered because they are unsuitable. Review the policy and check if it needs updating and improving.
You should review your health and safety policy at least annually. We recommend reviewing your health and safety policy twice a year just before April and October. These are the times of year when changes to health and safety law come into effect, and if any of these changes are relevant to your business, you should update your policy.
During these scheduled reviews, you can consider any other changes that are happening in the way you work, and any impact on your policy and procedures. If you know there are major changes planned ahead, in your work procedures or activities, you can also review your policy to check it covers these.
And when should you update your health and safety policy? The purpose of these periodic reviews is to check if your policy needs updating. If you find it does, then you should make the necessary changes and communicate these with your team.