13 Jun Reviewing your H&S Documents
Contractor Pre-Qualification and the Document Review Process
Recently, a client sent a copy of their results from their contractor pre-qualification review, and queried me on the following question from the final review report.
Question – Do you have a process/procedure to periodically review the work instructions, standard operating procedures, or specific safety instructions referred to in the last question?
To this question, they received a 0.
The client received a reasonable final score – however, they could not provide a written evidence process or procedure to verify the above question, even though the company had in place a H&S management software program that included an alerts process to undertake the document reviews.
This result then raises the question – in accordance with the Health and Safety at Work Act 2015, is a business required to undertake reviews of its health and safety plans and systems and if so, how often?
The answer is – No, it does not, but it is considered to be best practice.
To get a clear direction on this question, I searched the 2015 Act, and this is what is stated under Section 3, Purpose of the Act:
(f) ensuring appropriate scrutiny and review of actions taken by persons performing functions or exercising powers under this Act; and
(g) providing a framework for continuous improvement and progressively higher standards of work health and safety.
So, what does this mean? Like the 1992 HSIE Act, we have a situation where NZ business owners have to decipher and try to understand ambiguous and nonprescriptive legislation in order to comply with the 2015 Act. It is little wonder that so many businesses have a hatred and are turned off by this legislation, and too often get caught out.
Justifying Document Reviews
I certainly agree with section 3 (g) in regards to having a continuous improvement process, but is this being used to justify the inclusion of a document review process in the pre-qualification questionnaire?
Why is this question included in the contractor pre-qualification assessment?
This is a good question.
Apart from sections 3(f) & (g) of the Act and having worked with ISO 9001 for many years, I can see where the pre-qual companies are coming from. I agree with a document or systems review process for continuous improvement, but is there another reason?
I believe, for some health and safety professionals, the ideal H&S system would be in line with ISO 45001 Health and Safety standard, and that a document process would be in line with business best practice, but what and whose best practice?
The reality is that this will never happen when one considers that 97% of New Zealand businesses employs 20 or less people, and don’t have the time or resources to achieve this.
Undertaking a document review
To help with the continuous improvement of your business, we have created a checklist to help with this document review process.
Please contact us if you wish to discuss this further.