Health and Safety Policy Review: Employer Duties and Common Gaps

Health and safety policy review helps employers keep workplace responsibilities clear, risk assessments current and practical controls up to date.

Every business must have a policy for managing health and safety. If an employer has five or more employees, the policy must be written down. Even smaller employers should still consider keeping a written policy because it helps show how risks are managed in practice.

A health and safety policy should not be treated as a one-off document. Workplaces change, staff change, equipment changes and new risks can appear. If the policy is old or no longer reflects how the business operates, it may create avoidable legal and practical risks.

Why health and safety policy review matters

A health and safety policy explains how the employer will manage health and safety in the business. It should say who does what, when and how.

For employers, the policy is useful because it gives structure to workplace safety arrangements. It also helps managers and employees understand their responsibilities.

A review is important because a policy that looked suitable several years ago may no longer be adequate. The business may have moved premises, introduced new equipment, changed working patterns, taken on more staff or allowed employees to work from home.

If the policy is not reviewed, it may fail to deal with current workplace risks.

What should a health and safety policy include?

The Health and Safety Executive says a policy should cover three main areas: a statement of intent, responsibilities and arrangements.

The statement of intent sets out the employer’s general commitment to managing health and safety. It should usually be signed by the most senior person in the business and reviewed regularly.

The responsibilities section should explain who is responsible for health and safety tasks. This may include directors, managers, supervisors, employees, first aiders, fire marshals or external advisers.

The arrangements section should explain how health and safety will be managed in practice. This may include risk assessments, training, accident reporting, fire safety, first aid, equipment checks, workplace inspections and consultation with staff.

Common gaps in health and safety policies

Many health and safety policies look reasonable at first glance but still contain gaps. Common problems include:

• the policy has not been reviewed for several years
• responsibilities are vague or out of date
• risk assessments are missing or incomplete
• remote or hybrid working is not covered
• fire safety arrangements are unclear
• first aid arrangements are out of date
• training records are incomplete
• accident reporting procedures are unclear
• employees do not know where the policy is kept
• managers do not understand their role

These gaps can make it harder to show that health and safety is being managed properly.

Risk assessments and workplace changes

Employers are required to assess health and safety risks to employees and others who may be affected by the business. A suitable risk assessment should identify hazards, assess the risk and set out steps to eliminate or control those risks.

A health and safety policy review should check whether risk assessments still match the workplace. They should be updated when there are significant changes, such as new premises, new machinery, new working methods, new substances, changed staffing levels or different working patterns.

Risk assessments should not be filed away and forgotten. They should help the employer manage real workplace risks.

Remote and hybrid working

Health and safety duties are not limited to traditional workplaces. Employers should consider risks for employees working from home or working remotely.

A policy review should check whether remote and hybrid working arrangements are covered properly. This may include workstation setup, display screen equipment, working hours, stress, communication, accident reporting, equipment use and data security.

Employers should also check whether remote working arrangements are covered in contracts, handbooks or workplace policies. The health and safety policy should not contradict those documents.

Fire safety, first aid and accident reporting

Fire safety arrangements should be kept under review. The responsible person must carry out and regularly review a fire risk assessment for workplace premises, and a written record must be kept.

First aid arrangements should also be checked. Employers should consider whether the number of first aiders, first aid equipment and emergency procedures are still suitable for the size and nature of the business.

Accident reporting procedures should be clear. Employees should know how to report accidents, near misses and safety concerns. Managers should understand what needs to be recorded and when further action is needed.

Training and communication

A health and safety policy is only useful if employees and managers know about it. Employers should check whether staff have been told where to find the policy and whether managers understand their responsibilities.

Training may be needed when employees start work, change roles, use new equipment, move to different premises or face new workplace risks.

The policy review should also check whether training records are being kept. If a problem later arises, clear records can help show what steps the employer took.

Health and safety policy and employment documents

The health and safety policy should be consistent with other employment documents. These may include contracts of employment, the employment handbook, remote working policies, disciplinary procedures and sickness absence policies.

For example, if the handbook sets out accident reporting rules, the health and safety policy should not say something different. If the contract refers to a place of work, but employees now work from home regularly, the employer may need to review wider documentation.

Keeping these documents consistent helps avoid confusion and makes workplace rules easier to manage.

Practical review checklist for employers

When reviewing a health and safety policy, employers should ask:

• Has the policy been reviewed recently?
• Is it written down if the business has five or more employees?
• Does it clearly say who is responsible for what?
• Do risk assessments match current working arrangements?
• Are remote and hybrid workers covered?
• Are fire safety and first aid arrangements up to date?
• Are accident reporting procedures clear?
• Have employees been told where to find the policy?
• Are managers trained to follow it?
• Does it match the handbook and contracts?

Getting health and safety policies right

A health and safety policy review does not need to be complicated, but it should be thorough enough to identify outdated wording, missing responsibilities and practical gaps.

For employers, the aim is to have a clear policy that reflects the real workplace and supports safe working practices. A policy that sits on a shelf and is never reviewed is unlikely to give much protection.

EBS Law advises employers on employment policies, workplace documents, contracts and practical steps to reduce employment law risk. If your health and safety policy or related workplace documents are out of date, a review can help put the right protections in place.

For practical help with workplace policies, visit our health and safety page. For wider support, EBS Law also provides employment law advice for employers across a full range of workplace issues.