These articles aim to help small and medium-sized enterprises (SMEs) manage the bare essentials of health and safety at work, drawing on the requirements of laws that set the standard for all businesses: the Health and Safety at Work Act (HSW Act) and the Management of Health and Safety at Work Regulations.

This month, we focus on how to lay the foundation for managing heath and safety by creating a policy. Section 2(3) of the HSW Act requires employers with five or more employees to have a written policy statement on health and safety, including the organisation and arrangements for carrying out the policy.

But even micro-businesses are increasingly being asked by clients to show their policies, so since you have to have a policy and arrangements, why not make them work for you?

Your policy should include:

• a policy statement: giving your basic approach to health and safety, including fire safety
• organisation: saying who is responsible for making sure everyone follows the policy
• arrangements: describing how you will put the policy into practice.

This month we will deal with the first two points. The general policy statement should outline your management approach to health and safety. It must be supported by a clear, workable description of responsibilities for health and safety. These responsibilities don't have to be elaborate, they just have to work in practice.

Opposite is a sample statement, adapted from the HSE's guidance booklet INDG 259, An Introduction to Health and Safety - Health and Safety in Small Businesses (see Look further below). Remember that for any policy statement, you should be doing what you say you're doing.

Fully engaged

Effective health and safety management requires active engagement from both top management and employees. Your policy should also make it clear that employees must exercise personal responsibility for their own health and safety and that of others (Section 7 of the HSW Act says they must).

If you feel it helps to remind employees that you have a disciplinary procedure to deal with wilful disregard for safety or similar problems, the policy is one place you can mention it. That said, some managers feel that mentioning disciplinary action in the policy can set the wrong tone. Either way, you can also be more constructive by adding that you encourage employee comments.
Employee engagement with health and safety is a very valuable commodity. Suggestions are often best put to the person with day-to-day safety responsibilities (see below). Finally, have the statement signed and dated by the most senior person in the business and set a review date to ensure top management look at the policy at least once a year and that this review is recorded.

Called to account

Unfortunately, some SMEs think that the policy statement is all they need. It certainly is not. The next steps - setting out how you are organised and your practical arrangements - are of more practical use and, increasingly, clients want to see how you aim to manage things. So, the next thing is to show who's responsible for health and safety management (otherwise known as your "organisation").

The top name listed should be the same person whose signature appears at the bottom of your health and safety policy, normally the managing director or business owner. This shows csommitment by senior management. Even if a third party has produced the policy, top management must understand, sign up to and implement what they have committed themselves to.

In most SMEs, company directors are ultimately responsible for health and safety, but many day-to-day tasks can be delegated. This is the second person in your organisation hierarchy, who has general, everyday responsibility for health and safety management.

When delegating, ensure that people are competent for their health and safety responsibilities and that they have the resources to enable them to do the job properly.

Specific roles, such as who carries out risk assessments or training or who is the first-aider or fire warden, can be covered in the accompanying arrangements or in your statutory health and safety poster, which must be displayed in the workplace.

The third name in your list shows who is going to help you to meet the legal requirement under the Management of Health and Safety at Work Regulations 1999 (and similar provisions in the Fire Safety Order 2005) to have access to "competent advice".

Ideally, you will have a suitably trained and competent manager or supervisor (sometimes supported by a trade association or other source of advice) or, if this is not possible, an external consultant.

The issue of competence and what it looks like is vitally important to effective health and safety management - so much so that we will be looking at it specifically later in the series. But competence requires suitable knowledge, training, experience and sometimes even attitude. It is more than just "going on a course".

For an SME involved in low-risk activities, suitable experience, supported by basic knowledge and good judgement can still render someone competent for various roles. A good indicator of competence is when a person knows their limits. 

Let them know

Lastly, think about how best to communicate your policy to managers and other employees. Sending it around with the pay-slip can get attention; another way to increase contact with it is to put up a copy in the tea room.

The intranet is fine for keeping it on record, but staff don't usually make a beeline for it on their computer - it needs to be seen. Whatever you decide, make sure top managers and employees are aware of it.

Having a policy is a good start and stating clearly who has basic responsibilities is even better. But the biggest practical benefits are likely to come from having an effective set of health and safety arrangements, saying who does what and how. We will look at these in our next article.

Look further

Three useful sources of advice for smaller organisations:

• The HSE. Single copies of its "INDG" leaflets are free (and free to download from the HSE website). Two essential documents are INDG 259, An Introduction to Health and Safety - Health and Safety in Small Businesses  and INDG 244, Workplace Health, Safety and Welfare - A Guide for Managers. General HSE advice for SMEs is at www.hse.gov.uk/business while the HSE's excellent Essentials of Health and Safety at Work is available from www.hsebooks.com at £10.95.
• Businesslink's free guidance at www.businesslink.gov.uk provides a range of basic health and safety information. Click the "health, safety, premises" tab on the homepage.
• Regulatory Reform (Fire Safety) Order 2005 - A Short Guide to Making Your Premises Safe from Fire provides simple and practical advice to those responsible for fire safety in SMEs.