Management system guidance
5.0 Leadership and Worker Participation
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5.2 OH&S policy
Clause 5.2 requires top management to establish, implement and maintain an OH&S policy. The policy is a set of principles, stated as commitments, that sets the long-term direction for supporting and continually improving OH&S performance. It also gives the framework within which OH&S objectives are set and actions are taken.
What the policy must contain
Your OH&S policy must include:
- A commitment to provide safe and healthy working conditions to prevent work-related injury and ill health, suited to your organization’s purpose, size and context and to the particular OH&S risks and OH&S opportunities it faces;
- A framework for setting OH&S objectives;
- A commitment to fulfil legal requirements and other requirements (see 6.1.3);
- A commitment to eliminate hazards and reduce OH&S risks, which is delivered through the hierarchy of controls in 8.1.2;
- A commitment to continual improvement of the OH&S management system;
- A commitment to consult workers, and workers’ representatives where there are any, and to enable their participation (see 5.4).
A generic, off-the-shelf statement will rarely be “appropriate to the specific nature” of your OH&S risks. Refer to the hazards that matter most in your organization, such as work at height, driving, manual handling or psychosocial risks, and to the outcome of your context review. If you have determined that climate change is a relevant issue (for example, heat stress for outdoor workers), the policy should be consistent with that context.
How the policy must be managed
The OH&S policy must:
- Be kept as documented information, usually a dated, signed and controlled policy statement (see 7.5);
- Be communicated within the organization;
- Be available to interested parties, as appropriate, such as contractors, visitors and clients;
- Be relevant and appropriate.
When developing the policy, consider how it fits and coordinates with other organizational policies, such as quality, environmental, HR, wellbeing and driving policies, so that they do not contradict each other.
Consult workers on the policy
Clause 5.4 requires the organization to emphasize the consultation of non-managerial workers when establishing the OH&S policy. Share the draft with workers or their representatives, or through the health and safety committee, give them time to comment, and consider their feedback before top management approves the policy. Keep a record of the consultation.
Communicating the policy
You should check whether the policy has been communicated and understood throughout your organization. Clause 7.3 requires workers to be aware of the OH&S policy (see 7.3 Awareness). Auditors will wish to determine whether the policy is understood by interviewing personnel at all levels. Interviewees do not need to recite it, but they should know where to find it and be able to explain, in their own words, what it means for their work and how their job affects the OH&S objectives.
If personnel interviewed do not know the OH&S objectives that their work directly affects, the auditor is likely to look further at how top management has communicated the policy and objectives. Inferred awareness through knowledge of procedures alone is not considered sufficient.
A quick and convenient way to promote the policy is to create a shortened version; try condensing it to five key words or a couple of short sentences. This can be posted on noticeboards in each department, shown on screens, included in induction for workers and contractors, or added to the reverse of security passes or ID badges. If an auditor asks a worker about the policy, they can point to the noticeboard or their badge and explain what it means to them and how it influences their work.
Reviewing the policy
Review the policy whenever the organization’s context, activities, hazards or legal requirements change significantly, and at least as part of management review. A policy that still describes last year’s operations is no longer relevant and appropriate. Our health and safety management system templates include an editable OH&S policy.
You should seek and record evidence that the OH&S policy contains each of the six required commitments, reflects the organization’s actual OH&S risks and context, is approved and maintained by top management, was developed in consultation with non-managerial workers, has been communicated to workers at all levels and is available to relevant interested parties. Interview workers and contractors to confirm they know where the policy is and what it means for their work.
More information on PDCA
Planning
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Planning
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