Beginners guide to drafting an Occupational Health and Safety Policy

According to the Occupational Health and Safety Act 85 of 1993, Section 7(1), it is stated that an employer is directed by the chief inspector “to prepare a written policy concerning the protection of the health and safety of his employees at work, including a description of his organisation and the arrangements for carrying out and reviewing that policy.”

Furthermore, it is also stated under Occupational Health and Safety Act 85 of 1993 (OHSA), Section 7(3) that a copy of the signed policy shall be prominently displayed in the workplace. 

It is important to note that having an Occupational Health and Safety (OHS) policy is therefore not optional, and organisations are in fact mandated by law to have a signed policy available and visible in the workplace. 

In a previously published article we discussed the consequences of non compliance with the Occupational Health and Safety Act, in this article we aim to explain the importance of an OHS policy in the workplace together with its objectives. Let's start with an easy definition of a policy.

What is a policy?

A policy is a formal expression of top management’s commitment towards the intentions and direction of the organisation, whether this is related to health and safety, remuneration, growth or any other strategic decision that impacts the organisation.

Policies are, by definition, a signed mandate of commitment from top management.

“Top management” can be defined as the person or group of persons who directs and controls the organisation at its highest level. They have the power to delegate authority and are responsible for the planning and provision of critical resources within the organisation.

Through the planning, implementation and communication of an OHS policy, top management is fulfilling the requirements of law as per OHSA 7.

The Occupational Health and Safety Policy (OHS Policy)

Below are the organisational components to consider prior to drafting an OHS Policy:

• Scope and Context

By defining the scope and context of an organisation, top management is able to determine the parameters within which the organisation will operate.

Examples of parameters include external issues (cultural, social, political, legal, financial, technological, economic and natural surroundings and market competition, whether international, national, regional or local) and internal issues (competency, organisational knowledge, policies, systems, culture, corporate governance).

The scope and context of the organisation will determine the targets and objectives of the organisation. If the organisation, for example, aims to provide a healthy and safe work environment then surely top management will place priority on good hygiene and cleanliness, high quality personal protective equipment and employee health and wellness.

• Top Management Commitment

“Top management commitment” is a phrase that sounds good but what does it really look like?

Since top management sets the bar for compliance, company culture and continual improvement, it is essential for top management to be part of the process when it comes to the design and development of the OHS policy. 

The policies and objectives that top management implement need to be meaningful to the organisation, and not just set because of a legislative requirement but also to drive the business, promote OHS culture and showcase top management commitment.

Without commitment and active participation from top management, it is not possible for an organisation to successfully implement OHS policies and objectives or to grow an OHS focused company culture within the organisation.

• Objectives and Targets

OHS objectives and targets are set by top management, in cooperation with the relevant interested parties, including the employees. It is essential to set OHS objectives and targets, and ensure that they are specific, measurable, achievable, relevant and time-bound.

By setting objectives, an organisation is in effect laying down a “game plan” to achieve success. These objectives are continuously monitored, and where possible, improved upon. Since OHS objectives and targets play such an important role within an organisation’s success, including them in the OHS policy allows an organisation to effectively commit to success.  

Beginners’ Guide to Drafting An OHS Policy

When drafting an Occupational Health and Safety policy, top management should aim to address the following within the OHS policy:

• A commitment to providing a safe and healthy work environment and working conditions, in order to prevent work-related injuries or illnesses;
• The nature, size, purpose and context of the organisation;
• The organisation’s OHS risks and OHS opportunities;
• The organisation’s OHS targets and objectives;
• A commitment to the continual improvement of the OHS Management System;
• A commitment to the consultation and participation of workers, including workers’ representatives;
• Ensuring that the OHS policy is communicated to all employees within the organisation;
• Ensuring that the OHS policy is relevant and appropriate.

In conclusion

Familiarising yourself with the applicable legislation, regulations and by-laws will assist you as employer to understand the demands of the industry better. Key legislation to consider includes the OHSA, Construction Regulations 2014, General Safety Regulations and General Administrative Regulations.

SERR Synergy assists business owners with a comprehensive OHS service which creates and continuously develops a health and safety culture and system within the business that aligns with the business’s internal policies and goals. We have a dedicated and qualified team who implement health and safety legislation which includes drafting of an Occupational Health and Safety policy, and assist with small- to large-scale OHS projects, concerns or aspects.

About the Author: Inge-Marie joined our team in August 2018 and currently holds the title Lead Auditor: OHS. She is registered with the SACPCMP, and qualified in various ISO certificates including ISO 19011, ISO 9001, ISO 14001 and ISO 45001 along with a SAMTRAC certificate and a B.Com Business degree from UNISA. She has more than eight years’ experience in the construction and health and safety industry, specialising in international standards, telecommunications, roof work and working at heights. She is currently responsible for various industry-specific clients, including construction, manufacturing, chemicals and oil, as well as wireless internet service providers. She compiles OHS files, risk assessments and fall protection, emergency and evacuation plans and conducts regular internal audits for clients.