It is important to have a good HSE policy for an organization, because following a good policy leads to good HSE performance. It will always happen. Firstly, good actions always bring good results, and secondly because of the universal principle of reciprocity (social norm of responding to a positive action with another positive action). Hence if organization cares for its people, then they in-turn care for the organization.
- Purpose of HSE Policy
Through policy top management communicates to all within the organization:
- intent of the organization regarding level of performance it wants
- commitments it has made for achieving planned performance
- management direction for achieving intended performance
- When good written HSE policy fails
When company does not live the policy, that it has written and displayed, then good results do not come; in fact, cannot come. It is obvious.
There can be more than one reasons for not living the displayed policy; but lack of management conviction is one cause. They merely picked up good words, grammatically correct, wrote down that sounded good.
Our beliefs and convictions must go with policy.
- How do we formulate a good HSE policy
We know that an effect is related to the causative actions. In other words, we have knowledge of, what causes what. Within the organization this experience and information relating to it is abundantly available. So, we first write down what HSE performance, we wish to achieve for our organization. Then reflect on actions which will generate that kind of HSE performance.
For example, if at one manufacturing site fatalities had been happening and the management intention now is not to have any fatality, then policy may include words like – ‘no work shall proceed until the risk of fatality is eliminated.’
If management intention is – Prevention of serious injuries. Then policy may include words – ‘we are committed to reduce and control hazards such that serious injuries do not happen.’
If work activities are associated with occupational health issues, and management does not like these health issues to exist, then policy may include words like – ‘we shall pay attention to reorganise work methods in order to reduce adverse effect on human health.’
If there have been environmental incidents and possibility of happening exists, merely writing that company is committed to environment protection will not work. The commitment or direction within policy may come through words like – ‘environmental risks from operations of the company shall be predicted and proactively acted upon to protect the environment.’
- Management intention expressed in HSE policy
When employees look at the company policy, they should understand clearly, what the company’s intended outcome is, what are the commitments and general direction from top. Lack of clarity creates difficulty in implementation.
- Management direction expressed in HSE policy
Direction from top management will depend upon company’s situation and its internal context, hence would vary accordingly. Absence of clear direction creates confusion. Individual managers may decide to move in different directions, that will not be wise.
A good example for a company is, where policy stated – ‘achieving high performance on HSE requires changed mindset, which we shall have through awareness and trainings.’ In this case management direction is clear.
- Commitments on HSE within the policy
If we refer to ISO standards 45001:2018 and 14001:2015 then we get requirements under clause 5.1, regarding commitments. Look at the word ‘commitment’ and that is it. These must appear in written policy.
In all standards commitment to comply with legal and other requirements is always there; this is because these relates or come from society.
- What is the best way to formulate HSE policy
Before discussing the subject with anyone else, top management should do some deep thinking and then scribble his thoughts. Then he may ask his next level of managers to discover needs and expectations of interested parties. This would require consultations to take place.
Organise a meeting with managers and everyone shares needs and expectations; and the top management share his vision on what the HSE performances, company wants.
In the interim period everyone works on draft and then discuss together in a meeting, to arrive at most important contents, and commitments. Draft is subsequently refined and finalized.
Important point to mention is that process of consultation is must. It is with interested parties and then senior management team.
- Effective implementation of HSE policy
Prior to HSE policy being finalised, employees (though may not be individually) have been consulted in determining appropriateness of the HSE policy. So, they would know something about it.
Display of policy, or issue as card may help but is far from being sufficient for being considered ‘communicated.’ It can be taken as communicated, only when the understanding of policy is brought about in employees, in relation to their job activities.
One good practice is to have discussions in multiple groups wherein all interpretations are covered. Employees should be made to make notes on actions that they need to do – to demonstrate compliance with the policy in their job responsibilities.
HSE manager would be the right person, in case of clarifications sought, at any time. He would also be responsible to make a list of actions, by which it can be demonstrated that policy is being followed at site; and not just existing as an inert document.
Review, revise or make new procedures in HSE management system, such that by following them, policy shall get complied.
- How to know that that HSE policy is being followed
Actions taken against the points listed, in reference to III & IV above should suffice to know, the extent to which policy is being followed.
- How often the HSE policy be revised
Annual review of HSE policy is a good practice. It shall be judged against the criteria of suitability.
If HSE performance of any business site, did not come out well, in some element of performance but nothing in policy is violated; then it is an indication that policy needs to be improved i.e., HSE functioning in new projects or R&D activities that was not covered by the policy. Another reason could be poor implementation.
If the policy has been found to be complied and proportionate HSE performance also has been achieved; then firstly it is sign of satisfaction. Next, top management can (and should) consider revising the policy in a manner, that it will enable achieving higher performance.