INTEGRATING HEALTH & SAFETY INTO ORGANISATIONS By Kwame Ofori-Tutu PhD DIC

Module III Design of HSE Policy

As formally expressed by top management, an HSE policy establishes an overall sense of direction and is the driver for implementing and improving an organization’s HSE management system so that it can maintain and potentially improve its HSE performance. The HSE Policy provides framework for action and for setting of HSE objectives (HSE objective is HSE goal, in terms of HSE performance that an organisation sets itself to achieve.) It should enable persons under the control of the organization(staff and contractors) to understand the overall commitment of the organization and how this can affect their individual responsibilities.

Top management shall define and authorize the organization’s HSE policy and ensure that within the defined scope of its HSE management system it: a)is appropriate to the nature and scale of the organization’s identified risks b) includes a commitment to prevention of injury, ill health and pollution, and continual improvement in HSE management and performance; c)includes a commitment to comply with applicable legal requirements and with other requirements to which the organization subscribes. d)provides framework for setting and reviewing HSE objectives e)is documented, implemented and maintained d) is communicated to all persons working under the control of the organization with the intent that they are made aware of their individual HSE obligations; e) is available to interested parties; and f)is reviewed periodically to ensure that it remains relevant and appropriate to the organization.

In order to be appropriate, the HSE policy should: -be consistent with the mission, vision, core values and beliefs of the organisation, -be realistic, neither overstating the nature of the risks the organisation faces nor trivializing them As a minimum, to include statements about the organisation’s commitment to: the prevention of injury, ill health and pollution Continual improvement of HSE management and performance Compliance with applicable legal requirements and other requirements to which the organisation subscribes. It may also include other commitments to: Minimize significant adverse HSE impacts of new developments Design products taking into account HSE aspects Set example of leadership in HSE management

Examples of HSE Policies

Shell Group Commitment to Health, Safety and The Environment In the Group we are all committed to: pursue the goal of no harm to people protect the environment use material and energy efficiently to provide our products and services develop energy resources, products and services consistent with these aims publicly report on our performance play a leading role in promoting best practice in our industries manage HSSE matters as any other critical business activity promote a culture in which all Shell employees share this commitment. In this way we aim to have an HSSE performance we can be proud of, to earn the confidence of customers, shareholders and society at large, to be a good neighbour and to contribute to sustainable development.

Shell Group Health Safety and Environmental Policy has a systematic approach to HSSE management designed to ensure compliance with the law and to achieve continuous performance improvement sets targets for improvement and measures, appraises and reports performance requires contractors to manage HSSE in line with this policy requires joint ventures under its operational control to apply this policy, and uses its influence to promote it in its other ventures includes HSSE performance in the appraisal of all staff and rewards accordingly.

Daughter Policies( country level) can be developed to support main policy Examples Road Safety policy Security Policy No Smoking Policy HIV Policy Drug and Alcohol Policy Occupational Health Policy Accident Investigation Policy Product Stewardship Policy Etc etc

HSE Policy of a local company in Ghana Our goal is to protect our people, the public, our property and the environment in which they work and live. It is a commitment that is in the best interests of our customers, our employees and all other stakeholders. We shall Ensure environmental protection and enhancement through best operating procedures and practices Set objectives, targets, implemented through appropriate programs, thus ensuring the continual improvement in overall HSE performance Freely comply with all HSE laws and regulations regardless of the degree of enforcement Initiate and maintain an open dialog with all stakeholders on safety, health and environmental matters and respond appropriately to stakeholder concerns Prudently manage emissions and discharges and minimize waste generation Be prepared to respond to any emergency and mitigate incidents quickly and effectively We are committed to integrating HSE into every aspect of its business activities through comprehensive management systems and processes; thereby reduce risk and enhance the value of our services Signed by the Chief Executive Officer

Environmental Policy Statement of a local company in Ghana The management, conscious that mining and associated activities will affect the environment to a greater or lesser degree undertakes: To ensure that within economic limits and the need to be internationally competitive the Company’s activities are carried out with due regard to ecological and environmental factors through the implementation of international practice; To operate in compliance with the spirit and letter of the Government of Ghana’s environmental legislation; Employ the highest occupational health and safety standards; To maintain good communication with persons and communities affected by company operations; and To make employees aware of the need to protect the environment and motivate them in taking proper care of it. Signed Chief Executive Officer 1994

How is it communicated throughout the organisation?

Communication of Policy The communication of the policy will assist in: Demonstrating the commitment of top management and the organisation to HSE Increasing awareness of the commitments made in the policy statement Guiding individuals in understanding their HSE responsibilities In communicating the policy, consideration should be given to: How to create and maintain awareness in both new and existing staff and contractors Issues such as diversity in the workplace, literacy levels, language etc How to make the policy available to interested parties eg through a publication on a website, or by providing printed copies on request.

Example from a company The HSE policy, approved by the Chief Executive Officer or by all management team members, is to be communicated by line management in a structured manner to all staff and contracted employees. An HSE Policy Guidance Note may be prepared and used to facilitate the understanding of the HSE policy by Staff and Contractors. The policy is prominently displayed at all locations. Also as a good practice, the company will centrally include a copy of the policy in the briefing pack to new employees and visitors to the facility. The HSE policy is published in the HSE annual report. Hardcopies may be sent yearly to all identified interested parties. The HSE annual report may also be available to the general public via the website of the organisation. The Management Team will periodically review the HSE policy against Company HSE performance and determine the need, if any, for change or modification

An example of a communication from the CEO On March 27th 2006, I issued the newly signed HSE policy and communication document to you. In addition to fulfilling a Group requirement, I wanted to demonstrate to you that our HSE policy is a public document, and clearly articulates our business intents and principles. Although we achieved almost all of our HSE targets in 2006, we recorded many accidents, all of which could have been prevented. For 2007, my desire is that no company staff or contractor is hurt by our activities and that we continue to preserve our environments. The HSE policy (attached) is not just another paper. Together with the HSE Golden rules it should justify our actions and empower you to say NO when delegated to do unsafe business activities. ''We have a duty to intervene in unsafe conditions to prevent incidents''. Let this be your watch word in Best wishes Signature

Assignment 1 Draft an HSE Policy for your company. Explain how you would cascade it throughout your organization and the communities in your catchment area.