Policies and Procedures

Written policies and procedures are required by users, enforcement agencies and standards bodies like the LCA.

 

They all have in common the basic need to document how you do things and ensure you do them that way.

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Sounds simple but on audits we come across many Service Providers and Dutyholders with policies any procedures that either don't reflect what they do, or don't represent good sound practice.

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If an enforcement agency finds a breach of HSWA and finds that policies and procedures are lacking, or not being followed and that this has caused or contributed to the breach - they are likely to take enforcement action.  

 

In recent months and in planned intervention campaigns to come, HSE have and will prosecute and serve notices of contravention on Dutyholders and Service Providers. These now come with a fee for intervention in addition to the direct cost, legal cost and potential fines.

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Having robust policies and procedures will make the possibility of an incident less likely but will also mean your position is defensible should the worst happen.  

In the 2013/14 HSE led an intervention programme for evaporative cooling systems. The general finding of the process was a number of shortcomings in managing one of the highest risk systems for legionella.

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of 1906 sites inspected one third had a material breach of HSWA.  There were 409 improvement notices and 12 prohibition notices served. There are also some prosecutions ongoing as a result of the programme.  

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Implementation of the written scheme was identified as the largest single failing.  

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We can help with writing written schemes of control, policies and procedures.