A Guide to the Factories and Industrial Undertakings 
(Safety Management) Regulation

2. Duty of proprietor and contractor

2.2  Prepare, revise, etc. safety policy

A proprietor or contractor specified in Appendix I should ?

  • prepare and revise when necessary a written policy statement in relation to the safety policy of his industrial undertaking;

    There is no rule about the appropriate length of a written policy statement. One possible approach is to set out the safety policy in the written policy statement in a fairly general terms, and to refer the readers to other documents for full details, such as in-house safety rules, safety checklist, safety training programmes, and emergency instructions. The written policy statement (including its revisions), should be signed by top management (e.g. the managing director) and dated.

  • bring such statement and its revision to the notice of all workers;

    The policy statement and its revisions can be posted on notice boards or by internal circulation down to all workers.

  • keep a copy of the statement;
  • make a copy of the statement available for inspection upon request by an occupational safety officer;
  • review the safety policy -
  1. at least once in every two years;
  2. as soon as is practicable after the policy statement is altered.
To maintain an effective safety management system which has the mechanism of self-regulating and self-improving, the safety policy should be reviewed from time to time with performance measurement and safety audits.  When there is a change of particulars in the policy statement, including its core elements such as change in organisational structure, the safety policy has also to be reviewed accordingly.  A review may also be prompted by changes of particulars due to internal or external factors such as changes in technology, legislation or standards.

A written policy statement should have "the core elements" of -

  •  a statement of the proprietor's or contractor's general policy setting down in clear and unambiguous terms the management's approach and commitment to safety and health at work; 

    The safety policy should be specific and relevant to the nature of the work undertaken at the undertaking.  It should be able to convey the general intentions, approach and objectives of the undertaking as well as the criteria and principles on which its actions and responses are based. 

  • the system of allocation of responsibilities for the carrying out of the policy; and

    Whilst the overall responsibility for safety and health rests at the highest management level, that is, the proprietor or the contractor of the undertaking, many of the duties arising from that responsibility may be delegated to managers and supervisors.  In fact, all individuals at every level will have to accept certain degrees of responsibility for carrying out the policy.  Whenever possible, key individuals should be named and their responsibilities defined.

  • the arrangements as to how the responsibilities are to be executed.

    It is important that employees of all levels in the undertaking should be able to see from the statement how they fit into the system, and, for example, what their own duties and whom they should go, to report an accident or a hazard, or to obtain first aid or other help. 

1. Introduction
2. Duty of proprietor and contractor
3. Duty of registered safety auditor, safety review officer and scheme operator 
4. Penalty
5. Related occupational safety and health publications published by the Labour Department 
6. Useful information