Why having health and safety paperwork isn’t the same as managing health and safety
I walked into a business a while back to meet the owner.
I already knew their health and safety record wasn’t great. In fact, that was exactly why I’d been asked to come in and help.
Before I’d even sat down, the owner said:
“We’re OK here. We have a health & safety folder.”
That was it.
Not: “Here’s how we manage our risks.”
Not: “Here’s what we do to make sure our people go home safe.”
Just:
“We have a folder.”
As if having the folder meant health and safety was taken care of.
After more than 25 years working in health and safety, I’ve heard different versions of that sentence plenty of times.
And the folder normally looks the part.
Health and safety policy. Risk assessments. Method statements. COSHH assessments. Training records. Inspection sheets. Maybe a fire risk assessment. Everything neatly divided into sections.
There’s nothing wrong with having any of those documents. Good health and safety documentation is an important part of managing workplace risk.
But there’s one thing every business needs to understand:
The folder itself isn’t keeping anybody safe.
Health and safety paperwork isn’t the same as managing risk
A risk assessment only has value if it reflects what is actually happening in your workplace or on your site.
The people carrying out the work need to understand the risks.
The control measures identified in the assessment need to be put into practice.
Supervisors and managers need to make sure those controls continue to be followed.
And when the work changes, the risk assessment may need to change too.
A health and safety folder that gets pulled out for an audit, accreditation or client visit and then goes straight back onto the shelf isn’t managing risk.
It’s managing the appearance of managing risk.
And there is a big difference.
Common health and safety paperwork problems we find
As health and safety consultants, we regularly come across businesses that have plenty of documentation but where the paperwork and actual working practices have drifted apart.
We’ve seen risk assessments written for one job being reused years later for completely different work.
We’ve seen COSHH assessments referring to products that are no longer being used.
We’ve seen procedures describing control measures that simply aren’t happening on site.
We’ve seen training records showing that information has been communicated, only to discover that the people carrying out the work don’t really understand what they’ve signed.
And we’ve seen beautifully presented health and safety systems that bear very little resemblance to what actually happens when people start work in the morning.
That doesn’t necessarily mean the business doesn’t care about health and safety.
Often, it happens because somewhere along the way producing the paperwork became the objective.
A client asked for it.
An accreditation body wanted evidence.
An insurer requested documentation.
A tender required certain policies and procedures.
So the documents were produced, uploaded, filed away and considered complete.
But good health and safety management doesn’t work like that.
Is your health and safety documentation actually being used?
Instead of asking:
“Have we got a health & safety folder?”
There’s a much better question:
“Does what’s written in our health and safety documents actually match what we’re doing?”
Take a moment to think about your own business.
- Do employees genuinely understand the risk assessments relevant to their work, or have they simply signed them?
- Are the control measures identified in your risk assessments actually being followed?
- Have your workplace, equipment, substances, processes or people changed since the documents were written?
- Are your COSHH assessments based on the products you currently use?
- Are actions identified during workplace inspections and health and safety audits actually being completed?
- Are your training records current?
- Could a supervisor explain how your significant workplace risks are controlled without immediately reaching for the health and safety folder?
- When was the last time your health and safety arrangements were properly reviewed?
And here’s probably the most important question of all:
If an HSE inspector walked through your workplace today, would what they saw match what your paperwork says?
If the answer is no, you’ve got a gap that needs addressing.
What does good health and safety management actually look like?
Good workplace health and safety isn’t about producing more paperwork.
It’s about having the right documentation and actually using it.
A shorter, accurate risk assessment that’s understood and followed can be far more valuable than a beautifully presented 30-page document that nobody has read.
A good health and safety management system should be alive.
It should be:
- Relevant – documents reflect the work actually being carried out.
- Understood – employees know the risks and the control measures expected of them.
- Implemented – what’s written down is actually happening in the workplace.
- Monitored – managers and supervisors check that controls remain effective.
- Reviewed – documents are revisited when circumstances change or when there is reason to believe they are no longer suitable.
- Improved – accidents, near misses, inspections and employee feedback are used to make things better.
That’s the difference between having health and safety paperwork and actually managing health and safety.
When should risk assessments and health and safety documents be reviewed?
One mistake businesses sometimes make is assuming that once a risk assessment has been completed, the job is done.
It isn’t.
Your health and safety arrangements should reflect your business as it operates today.
A review may be needed when there are significant changes to things such as:
- work activities or processes;
- equipment or machinery;
- hazardous substances;
- employees or working arrangements;
- premises or workplace layouts;
- legislation or industry guidance;
- information following an accident or near miss; or
- evidence that existing control measures are no longer effective.
Your business changes.
Your health and safety arrangements need to keep up with it.
Health and safety compliance should be visible in the workplace
One of the things I look for when visiting a business isn’t simply whether a document exists.
I want to see whether I can see it working.
If a risk assessment says employees should wear certain PPE, is that what they’re actually wearing?
If the procedure says equipment is inspected before use, are those checks happening?
If a COSHH assessment identifies particular controls, are those controls available and being used?
If employees have received training, can they explain what they’re supposed to do?
If an inspection identified an action three months ago, has somebody actually dealt with it?
The workplace should provide evidence that the health and safety system is working.
That’s far more meaningful than simply showing someone a folder.
Beyond the health and safety folder
This is something we spend a lot of time working on with businesses at Prohas Group.
Yes, as a health and safety consultancy we help businesses develop policies, risk assessments, method statements, COSHH assessments and other health and safety documentation.
But producing documents is only part of the job.
We want to understand what’s actually happening.
We visit workplaces and construction sites.
We speak to employees and managers.
We review working practices.
We carry out health and safety inspections and audits.
We identify gaps.
We challenge things when they don’t look right.
And we help businesses make sure that what they say they’re doing on paper is actually happening in practice.
Because ultimately:
The folder isn’t your health and safety system.
Your people, your managers, your behaviours and the controls you put into practice every day are the system.
The paperwork should support all of that.
It shouldn’t replace it.
Try this simple health and safety check today
Before you close this article, try something.
Go to your health and safety folder – whether that’s a physical folder or an online system.
Pick one risk assessment.
Don’t choose the best one.
Just choose one.
Read the control measures.
Then go and look at the work being carried out.
Does what you see match what the risk assessment says should be happening?
If it does, great.
If it doesn’t, you’ve just identified something worth addressing.
And it’s much better to find that gap today than after an accident, enforcement visit or client audit.
Not sure your paperwork matches what’s actually happening?
If you’re not completely confident that your health and safety documentation reflects what’s actually happening in your workplace, we can help.
At Prohas Group, we don’t believe in paperwork for the sake of paperwork.
We take the time to understand your business, look at how health and safety is actually being managed and help identify any gaps.
Whether you need a fresh pair of eyes, a health and safety audit, risk assessments, workplace inspections, competent person support or ongoing health and safety consultancy, we’d be happy to have a conversation.
TELL US ABOUT YOUR HEALTH & SAFETY
Tell us a little about your business and what you need help with, and one of the Prohas Group team will get back to you.
Prohas Group – practical health and safety support for businesses that want to go beyond compliance.
