Firstly, apologies for recent lack of blogging. My father died unexpectedly a couple of weeks ago. I am now back in action, and with plenty to blog about.
We finally said goodbye to SafeContractor in August. They were still trying to get us to use an overly wordy, repetitive and therefore ineffective Health and Safety Policy document. Plus a whole load of other issues, very similar to those we first came up against when this whole fuss started. The H&S policy was just the first thing on their list, and when we failed to persuade them that ours was much better (being clear, concise, not repetitive, and still covering all the key points) I decided enough was enough and we simply wouldn't ever convince them that their materials are (in our opinion) less safe than our own.
Here, if you are interested, is their super-long Health & Safety Policy sample. And here is our version (in draft form - the one we actually issue to staff is much prettier).
Despite being far, far longer, I really don't think there is anything substantive in theirs which is not in ours. Or at least, nothing sufficiently important to warrant the inevitable loss of clarity that would result from extending the length of the document.
Plus their sample is horribly let down by what I can only assume is a drafting error in the very first two clauses (which are almost identical).
Here is the letter I wrote to SafeContractor informing them of our decision to withdraw from their accreditation programme (copied into the HSE):
National Britannia Group Ltd
Caerphilly Business Park
Thank you for your e-mail of 1st August.
We do very much appreciate the work that you and your colleagues have put into reviewing our SafeContractor accreditation. It is a credit to your organisation that you have paid so much attention to our very detailed concerns.
Nevertheless, we cannot escape the fact that we have very different views on managing health and safety. We think that long, repetitious documents with redundant information are dangerous as they are not read properly, the really important information gets lost amongst less important information, and they give the reader the impression (whether justified or not) of being part of a bureaucratic box-ticking exercise.
In our discussions you have indicated that you agree with these principles (of keeping documents concise, readable, relevant etc.). But, in practice, you give far less weight to these principles than we do, to the extent that those principles are completely overshadowed by the competing principle of including as much information as possible, even if it is of minimal importance, or repetitive.
I think that the first two clauses of your sample H&S Policy template are very telling:
“1.1 The Company acknowledges and accepts its legal responsibilities for securing the health, safety and welfare of all its employees, of subcontractors working on its behalf and all others affected by their activities.”
“1.2 The Company recognises and accepts the general duties imposed upon the company as an employer under the Health and Safety at Work Act and subsequent health and safety regulations appertaining to it’s [sic] operation.”
Clause 1.2 says nothing substantive that clause 1.1 does not say. While you might see this redundancy as a trivial drafting error, I think that the fact that such obvious repetition has found its way into the very first section of your sample template says a lot about the (lack of) importance given to producing a concise, readable, effective document. Clearly no-one has read through this document, thinking “Can we make this shorter and clearer? Can we make the key messages more prominent?” etc. No document (whether relating to health and safety or not) would be produced by our organisation without that sort of attention to detail. To you, attention to detail seems to mean “have we covered everything?” To us, attention to detail means “is this document as effective as possible?”
I should emphasise again that we are not rejecting your approach because we want to reduce paperwork, or that we see paperwork per se as burdensome. We are rejecting it because we think it is less safe. We firmly believe that our health and safety documents help foster a safer working environment than we would have if we followed your approach. We therefore no longer wish to seek renewal of our SafeContractor accreditation.
We will continue to work independently to further improve our materials and processes, including taking into account Jim Neilson’s and Steve Pointer’s comments about more formally documenting the process we have gone through to produce the employee-facing material that we use.
Thank you again for the time and effort you have put into this.