Getting people to read your Health & Safety Policy is difficult, but persuading them to put it into practice can be even more problematical. So, in a multi-layered, multi-site and complex organisation like Waitrose how is this achieved?
The first step is to seek clarity. Policy is often seen as rule writing; the ‘what we do’ about this issue. This can often confuse the dividing lines between policy, process and procedure. If we are to achieve manager ‘buy-in’ to the policy we must achieve clarity in its construction i.e.
- Clear leadership statements of intent (policy).
- Clear responsibilities for each level of the organisation (policy).
- Clear arrangements (how different safety issues are dealt with, which departments have an input in the process?).
- A body of safe systems of work to support the policy i.e. procedures.
Clarity in this documentation will help managers to understand what they should do and why. The next problem to confront is that the numbers of policies we have can confuse. Having a separate policy for each safety & health issue produces a huge body of work that no busy manager is honestly going to study the detail of. It’s too much to get your head around. So how do you reduce the number of policies?
The key to compliance with the Health & Safety at Work etc Act 1974 is to implement management systems. The life blood of running these systems comes from our regulations. The tools and techniques of modern safety are risk assessment and management. A risk-based approach is basically about timely problem identification and solution finding. This is basic management, and provides a real way of connecting with a manager – persuade them it is just problem solving by another name. This is the essence of what Lord Robens was promoting in his report in the early 1970s when he proposed that it is the duty of the employer to predict and put preventative measures in place. It’s only later we labelled what we predict as being risk. The philosophy still under-pins our legal approach in this country.
This helps with policy construct. If the health & safety policy is written in a way that supports the problem-solving approach then it is equally applicable to all health & safety issues – so why have multiple policies? Surely one risk-based policy supported by a good arrangements document is sufficient? The arrangements document should make it clear who is involved e.g. if it’s a manual handling problem associated with the use of a machine then retail operations, engineering, safety and occupational health should be involved in finding the solution.
What about assurance that managers are implementing the policy? If they are led to understand that safety is about good problem solving technique and solution implementation; if they can see the business benefit of doing things well, then we have a fighting chance of being able to demonstrate the effective implementation of the policy. Providing the underpinning knowledge through good training is a must. Not training in the letter of the law, but in the spirit, intent and mechanisms of the law. Managers need to be able to argue what is reasonably foreseeable and reasonably practicable. They need to be able to define significant risk, and just as importantly, what is insignificant. What must we manage and what can we ‘get a life about?’
So, what is the role of the safety practitioner in all this? The philosophy of Lau Tzu sets high standards for us to achieve.
The leader is best,
When people are hardly aware of his existence,
Not so good when people praise his government,
Less good when people stand in fear,
Worst, when people are contemptuous.
Fail to honour people, and they will fail to honour you.
But of a good leader, who speaks little
When his work is done, his aim fulfilled,
The people say, ‘We did it ourselves.’
The answer is leadership, service and education.
- Leadership through setting a clear vision that your managers can understand and agree with.
- Service through creating simple pragmatic safety management systems for them to use.
- Education through good quality training and in daily dialogue – when they ask a question, don’t just tell them the answer, educate them.
So how does Waitrose do to implement these ideas? We start with a simple policy structure that provides clarity and reflects the reality of how our business operates. We have a programme of training that is focussed on underpinning knowledge so that instruction and the safety management systems can be more profoundly understood. This training is modified to suit the different perspectives of the different levels of management. We have a system for defining what risk is significant and what is not. We have built a management system that ensures the full integration of health & safety concern into business risk management. This is all sold to management on the basis of the business benefits of an effective, simple approach that utilises their existing management systems where possible. There is still work to be done, but we are making good progress.
By Duncan Spencer, Divisional Safety Manager, Waitrose