The last article explored the 10 points that needed to be covered under C&E/CoR, the next question is how do we ensure that our business can comply with those 10 items. The most common method is to develop Policies & Procedures (P&P), for our business to work under.
Compliance and Enforcement (Chain of Responsibility) Policies
When developing Policy and Procedures there are 5 areas which we need to focus on to prevent major pitfalls:
1. Compliance and Enforcement ( Chain of Responsibility ) Policy and Procedures
The Compliance and Enforcement ( Chain of Responsibility ) Policy and Procedures themselves, to what level of detail should they get to? If the Policy and Procedures fail to have enough detail, then their impact may be too loose and not cover the legislation effectively. If they are too big then they become a voluminous c that is never read let alone used.
2. Risks Compliance and Enforcement ( Chain of Responsibility ) Policy and Procedures
Risk of making the Compliance and Enforcement ( Chain of Responsibility ) Policy and Procedures to specific and restrictive which means that if a situation deviates from what we have prescribed then workers will become paralysed as they will not be able to make decisions on how to handle a situation. This may lead to the logistics function not occurring, but more likely that the function will be executed in an uncontrolled manner leaving the company exposed under Compliance and Enforcement ( Chain of Responsibility ).
Copying a Compliance and Enforcement ( Chain of Responsibility ) Policy and Procedures system from a “mate” or elsewhere in a business group, completing a “search and replace” on the business name and logos, and they have instant Policy and Procedures for their business.
Stakeholders Compliance and Enforcement ( Chain of Responsibility ) Policy and Procedures
Not taking into account all the relevant groups. Under new legislation a person engaged to complete a task on a site (including a truck) will be deemed as a “worker”, regardless of how they are engaged, be they a direct employee, a subcontractor, through a labour hire agency, via a 3rd or 4th party.
Training Compliance and Enforcement ( Chain of Responsibility ) Policy and Procedures
Compliance and Enforcement ( Chain of Responsibility ) Policy and Procedures of intent not action; this habit is common with many companies and they develop Policy and Procedures that looks great on the bookshelf and has significant version control and indexing but in reality bears no resemblance to what actually happens within the business. This means staff will continue to complete tasks in the same way they always have and pay no attention to the company Policy and Procedures.
Audits Compliance and Enforcement ( Chain of Responsibility ) Policy and Procedures
During audits we have often seen volume after volume of Policy and Procedures that are; over complicated, copied or rewritten and become a compliance hindrance to the business and often costly to prepare and repair. Basic rules – “Keep it simple – Reflect the action”
Preparing effective Compliance and Enforcement ( Chain of Responsibility ) Policy and Procedures
A few golden rules for Policy and Procedures:
- Know how your business “actually” works before you start. We are not looking for what should happen more what the business is really doing, so don’t get the manager to write this, get the front line operators to do it.
- You must be able to “map” your business processes so that they can be followed by a “trained monkey” in the event that the normal operator is unavailable at short notice
- Compare your actual processes to the Compliance and Enforcement ( Chain of Responsibility ) regulations and see where the holes are
- Fix up the holes in your business
- Write concise Policy and Procedures to cover what you actually do
- Train “workers” on the actual application of Policy and Procedures
- DO NOT get sucked in to developing a complicated Policy and Procedures system: KEEP IT SIMPLE, KEEP IT LEGAL
Bear in mind that regardless of how fantastic the bookshelf system looks, if authorities embark on an investigation due to offences they will not care about what the Policy and Procedures says, what they will be looking for is what actually happened leading up to the offence. If the Policy and Procedures you have developed are not capable of controlling the compliance issues then they will be immediately discounted.
In summary if you are NOT comfortable in getting to this level of accuracy with your Policy and Procedures get some help, it will be cheaper and quicker in the long run.
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