There’s still a misconception around what a policy is and what a procedure is. I like to think of a policy as a pledge. A high level company document that acknowledges your duties and outlines what you have in place to comply with any legal requirements.
A procedure however, is entirely different and the two in my mind are not too dissimilar in comparison to the way a piece of legislation is supported by an Approved code of practice.
I have not long finished helping a company to completely revamp their policies and the output was a suite of documents that properly supported the business in explaining what their policies were and procedures to follow to assist all within the company to meet the requirements of them.
Common procedures we find missing are Driving on Company Business and Control of Contractors, but I will use Driving on Company Business as my example. Your policy will most likely say that you take driving at work seriously and shall ensure you have in place risk assessments, driver checks, training and vehicle condition checks. It will likely reference the applicable legislation and be signed by the director to show compliance.
But your procedure goes one further. It explains how we do it, what the parameters are. What is good, what is not good, and what will happen if it isn’t good. This is where you get to define what your company feels is appropriate and what will happen if something falls outside of expectations as well and prevention, but it isn’t a risk assessment. Some of the headers we would expect to see in a procedure need also following with the ‘procedure’
“Driver license checks will be carried out for all that driver on company business”
- How often?
- Who (effectively) manages this and how?
- What is acceptable? Will 6 points get you a meeting with a line manager and 11 render you liable to not be permitted to drive company vehicles? Or does it, in practice depend on who the line manager is? How do you ensure everyone is treated equally?
“We shall ensure vehicles are suitably insured and breakdown cover is provided” (if this forms part of your risk assessment for safety and security it is very important)
- Who is expected to purchase the breakdown cover? Is it the company and if it is for company vehicles, how do you ensure those in their own vehicles have the same cover?
- Do you retrieve insurance details for those using their own car?
“Vehicle checks shall be completed on a regular basis”
- For company vehicles or others that drive on company business?
- Is there anything that explains what condition of vehicle is suitable?
- Who collects in the checks completed and who picks up any actions?
One of the small things I came across in a previous company is that windscreens were changed often with the amount of miles, but the ‘no smoking’ sticker was always mounted to the windscreen, so when the screen was changed, the stickers were lost. There was nothing in place to ensure these were captured and it may sound minor, but if a driver is caught smoking in a work vehicle with the sticker on display, the driver collects the fine. If the sticker is not present, the company does. Small detail but £1500 each time.
Then we move on to safety of drivers. Have you ever defined as a company how far is too far to drive? How many miles? Whilst the working time directive may cover total hours, and those that drive for a living may be very aware of the rules regarding breaks, those that work in sales or field based professional roles tend to be at risk of extremely long journeys, minimal stops and time pressures, leading to road rage, lack of attention, speeding and tiredness.
Then there’s the Monday morning hangover issue, especially prevalent in construction crews travelling to site. Do you spot check alcohol testing?
What we must do is define within our procedure what is acceptable to us as a company. It could be a maximum travel time or distance before considering staying over, sharing driving, using public transport, or some of those may not be possible. You can consider telematics systems to analyse driving styles, trends and areas of improvement.
And we must consider lone working and how often we will check in with our drivers to ensure their welfare.
One thing we can do for most instances though is give our drivers training and have a procedure in place that explains fully what our expectations are. This can help to reaffirm the basics but also gives you the opportunity to add on some company specific requirements by means of a briefing or toolbox talk.
Summary
What control measures you need will be specific to your business and risk level, but it must be clear.
This essentially is what goes into a procedure and different procedures will be differing lengths. You may decide that due to the size of the company many subjects could be combined, or only warrant a small statement. But the level of policies, procedures and length of content must suit your business. Rarely has a company of 4 people benefitted from a suite of 20 policies and as many procedures, so it need not be onerous and one size certainly doesn’t fit all, but as you grow you should be aware that your pledges and processes may also need to grow with you.
Written by: Hayley Tollervey
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