Health and safety may often be seen as bureaucratic, red tape and stops business from carrying out tasks.

One of the challenges within managing health and safety is paperwork, what needs to be in place, the HSE have stated businesses should not be burdened by paperwork in regards to health and safety

The challenge with health and safety legislation in effect assumed guilty until proven innocent. The onus is on the employer to prove they are innocent and have complied with legislation.

If the HSE have any reason to investigate, their starting point will likely be what documented policies and procedures are in place, along with interviewing employees to see if they are aware of policies, procedure and control measures, is the climate towards health and safety in-line with the board and senior managements desired culture.

Apart from where specific legislation exists for example The Lifting Operations and Lifting Equipment Regulations 1998 which one of the requirements is for equipment used for lifting people or accessories used in lifting operations, such as slings to be thoroughly examined every 6 months.

The main two pieces of health and safety legislation don’t limit any task or activity being carried out, the emphasis is for employers to ensure, so far as is reasonably practicable, the health, safety and welfare at work of all their employees. Along with making a suitable and sufficient risk assessment as to the risks to health and safety to their employees whilst at work.

What does need to be in place:

Any employer with 5 or more employees must have a documented health and safety policy, including arrangements and procedures for managing significant hazards and risks.

Along with a health and safety policy, any employer with 5 or more employees must document suitable and sufficient risk assessment of the risks to health and safety to their employees to which they are exposed to whilst at work, along with risk to health and safety of persons not in their employment arising out of or in connection with the employers undertakings.

Though employers with fewer than 5 employees do not need to document a health and safety policy or risk assessments, they’re still required to comply with other requirements of the legislation by ensuring the health, safety and welfare of their employees.

Is managing health and safety any different than other business functions

HR – Most companies will have documented policies and procedures for how human resources related topics will be managed, in some cases will overlap with health and safety such as absence management, stress, eyesight test policy, training and development matrix, lone working and may already be achieving compliance with health and safety requirements. The policies and procedures will either likely sit in a folder or on a company intranet site, probably looked at when someone has a question or query, if don’t already incorporate any requirements for health and safety can probably easily be amended to incorporate any requirements, far better to keep current policies and procedures if everyone knows where to find information.

From a HR perspective probably conducting return to work interviews, reviewing absence statistics on a periodic basis, if there are any trends to manage in terms of disciplinary management, information is likely to be in place to allow to look from a different perspective, what are the largest trends for absence from work, what improvements can be made to aid reducing any absence trends.

Finance – With finance depending on the legal structure and size of the business will be requirements for accounts to be audited, documentation to be retained for set period of time. Likely periodic reviews will take place of profit and loss along with balance sheet to monitor the ongoing financial health and safety of the business.

Quality Management – Depending on the industry operating within may operate a quality management system, which may be certified to a recognised standard such as ISO 9001. This will require a business to have documented policies and procedures in place as to how operations within the business will be managed and audited against set standards

The basis of a quality management system is to do what you say you do, document what you do, monitor, review and audit against your documented system. Health and safety in principle is no different identify hazard, put sufficient controls in place, document what you do (risk assessment, procedure), monitor, review and audit against to ensure what you have documented, is actually taking place. If already have documented procedures in place it is likely these can be developed to include any health and safety requirements, likely they will be used and in language employees understand, rather than creating specific health and safety documentation.

SWOT Analysis – As a business may naturally be undertaking risk assessments for how the business operates, identifying strengths, weaknesses, opportunities and threats. In reality assessing health and safety is no different, identifying the hazard (threat), weaknesses (risk), strengths (current controls in place) and opportunities (areas for improvement). There is no prescribed method for how a risk assessment should be carried out, if already using a tool within a business which people understand, no reason that can’t be developed to incorporate health and safety.

Lean, Six Sigma, 5S, Continuous Improvement – Especially within a manufacturing environment tools and techniques may be used to review and develop processes, documenting working procedures, similar to SWOT analysis above if as a business already operating a system to review work processes and activities, they may naturally be reviewing health and safety or with development to techniques or tools used, health and safety could likely be easily incorporated.

How can health and safety be managed?

Initially review what is already taking place within the business, HR policies and procedures, quality management, swot analysis, continuous improvement techniques, what is already in place, can they be developed to incorporate health and safety, if there is an existing documented work process for how to build a product, there is no reason can’t incorporate a risk assessment and safe system of work into existing procedures.

The aim of health and safety is about continuous improvement, HSE guidance document HSG65 Managing for Health and Safety works on the plan, do, check act model, which may be recognisable to those operating a quality management system will likely use a similar process.

Plan – Identify significant hazard, are there controls in place

Do – Implement controls to protect from significant hazard

Check – Are the controls working, actively monitor trends and what is actually happening

Act– Review monitoring, are further improvements, education, training, development required.

If within a business have policies, procedures, process which may cover documentation requirements, only elements which remain have all significant hazards been identified and are employees following control measures. The only way this will be known is for activities to be actively monitored, discussing with employees any areas of concerns they may have or thoughts they have to improve safety.

It can be easy to become oblivious to hazards and risks which exist within the workplace, when was the last time you walked around the workplace?

What significant hazards did you spot? What improvements were required?

Most companies have a level of vehicle movements taking place, delivery vehicles, forklifts operating, what hazards exist within your workplace and how do you control the risks?

Do you operate a tidy desk policy, do desks look cluttered, do employees have enough room, could it highlight an employee is potentially overworked, suffering from stress?

If you manufacture do employees carry out repetitive tasks, assemble and pack products on a production line, have significant health hazards been identified?

What is housekeeping like, not just on visible surface within open plan offices, but within stock rooms, single offices, cupboards containing electrical distribution boards, is everything stored in a tidy manner, could items fall from height, are combustible items stored near electrical distribution boards?

What is more important than any paperwork being in place is the culture and climate within the business.

Culture – What the board/senior management of a business perceive is taking place

Climate – What is actually taking place in the business.

Board or senior management may have a perception something is taking place through existing policies, procedures or their expectations, is the perception actually happening, how do the board or senior management satisfy themselves that their perceptions and expectations are actually happening.

An example:

Culture could be an expectation the business is complying with the Control of Substances Hazardous to Health Regulations 2002 (COSHH)

Climate in reality some COSHH assessments were carried out a few years a go for items used at the time, have not been maintained, cleaning chemicals are purchased from local supermarket when someone pops out for lunch, no safety data sheet exist for current chemicals used and COSHH assessment have not been carried out, different cleaning chemicals may be purchased depending on what is on special offer at the time.

It may be a policy or procedure was put in place within the business for how COSHH should be managed, policy or procedure will only ever be any good if monitoring takes place to ensure is being followed.


Yes, Legislation requires a level of paperwork to be in place if employing over 5 employees, but the emphasis should not be to bog the business down in paperwork.

Review existing policies, procedures, update where required.

Before worrying about creating additional policies or procedures, consider the culture the business wants to develop, how the business will ensure climate is achieving desired culture.

Priority should be given to ensuring significant hazards have been identified and controls are in place to protect employees health.

Though legislation requires employers with over 5 employees to have documented risk assessments which are suitable and sufficient, question should be asked how will anyone know if a risk assessment is in place or if it is suitable and sufficient?

The HSE are like all other government departments, budgets have been cut, so unless in specific industries which are high risk, construction, waste, agriculture, unlikely they will just turn up, unless something has happened.

Far better to concentrate on ensure an accident or incident does not occur and health is protected, than worrying about if documented risk assessment is suitable and sufficient.

Effort better put into identifying hazards, making sure controls are in place, ensuring the climate is in-line with expected culture to prevent the likelihood of any accident or incident occurring which would require the HSE to visit.


As a business do you know where the hazards to health exist within your business and are they being suitably and sufficiently controlled.

If you need help and assistance in identifying hazards which may exist, ensuring suitable controls are in place and developing the climate towards health and safety: Call Sky Blue Safety Ltd 01933 812234