HSE instructions

THE SIGNIFICANCE OF OHS INSTRUCTIONS

Every employer has a duty to guarantee the safety of their employees. Where there is a risk to health or life, or when machinery is used, a specialized OHS instruction prepared by experts is essential. Additionally, employees must be familiar with it to avoid hazards associated with their profession.

WHAT DO OHS INSTRUCTIONS CONTAIN AND WHAT EXACTLY ARE THEY? 

The OHS instruction for a workplace is nothing more than a set of rules regarding safety and hygiene in the workplace. The information and guidelines contained in it aim to ensure the safety of all employees while performing their duties. It is crucial for the employer to carefully analyze the specifics of the industry and the health or life hazards that employees may face in a given facility. Most often, the danger arises from the use of chemicals, machinery or equipment, or exposure to an environment with intense noise – all employees should be aware of how to ensure their safety every day at work.

WHAT SHOULD BE INCLUDED IN A COMPREHENSIVELY DEVELOPED OHS INSTRUCTION? 

The OHS instruction contains information about the rules to be considered when performing specific tasks before starting work, during its duration, and after completion – covering all aspects related to the setup and maintenance of machinery, operation of equipment, etc. In addition, instructions may also specify requirements for specific positions (necessary qualifications, prohibited actions, procedures in emergency situations). 

What is particularly important is the clarity and simplicity of the content of the OHS instruction so that none of the employees have difficulty understanding them. Avoid using complicated terms and technical vocabulary, which not only complicates the understanding of the instructions but can also lead to misleading employees, thereby increasing the risk during work. 

TYPES OF OHS INSTRUCTIONS – POSITIONAL AND GENERAL

We most often encounter two types of OHS instructions – general and positional. General OHS instructions contain a list of rules that all employees should follow. They are somewhat universal and aim to ensure that work is carried out safely without the risk of injury or accidents – including first aid instructions. On the other hand, positional OHS instructions directly concern a specific job position.

It is also worth noting that fire safety instructions (in red) play a crucial role, containing information on the steps to take in case of a fire. However, these are just three of many OHS instructions that one may encounter. Depending on the nature of the industry, it is also advisable to consider instructions related to:

• medical procedures;
• wood or metal processing;
• installation work;
• dedicated to the hospitality sector, agriculture, construction sites, etc.

WHO DEVELOPS OHS INSTRUCTIONS FOR WORKPLACES?

Both general and positional OHS instructions should be developed by qualified individuals who have experience and knowledge in this field. In the case of general instructions, it is advisable to seek the assistance of an OHS company that will prepare the document based on applicable regulations and legal provisions. As for positional instructions, whose development requires knowledge of a specific position, the assistance of someone specializing in that area, such as a manager or engineer, can prove crucial.

WHERE SHOULD OHS INSTRUCTIONS BE STORED?

While there is no specific rule about the exact storage location of OHS instructions, it is important to ensure that they are ultimately easily accessible to all employees. The best solution may be to place them near machines and equipment, in a binder in the break room, or, for example, next to the bulletin board

MANDATORY OCCUPATIONAL HEALTH AND SAFETY INSTRUCTIONS – LEGAL BASIS

The requirements regarding the necessity of having OHS instructions are regulated by the Regulation of the Minister of Labor and Social Policy of September 26, 1997, on general occupational health and safety regulations.

Let’s start with the Labor Code. The requirement to create instructions is mentioned in several places, including:

• Art. 209(2). § 1:

“In the event of a possible threat to health or life, the employer is obliged: 2) immediately provide employees with instructions enabling, in the event of an immediate threat, the cessation of work and the removal to a safe place.”

Such threats may include fire, explosion, or the leakage of chemical substances. The likelihood of such unwanted events varies, depending on many factors. However, they cannot be treated as events that are completely improbable. Therefore, a proper approach is to prepare for the possibility of such events and implement appropriate instructions outlining the procedure.

• Art. 237(4) § 2:

“The employer is obliged to issue detailed instructions and guidelines on occupational health and safety at workplaces.”

The provision does not explicitly specify the form of developing job instructions, so it can be inferred that familiarization with the instructions can be done in written or oral form.

As for confirming familiarity with OHS regulations, employees should do so in writing, as confirmed in Art. 237(4) § 3:

“The employee is obliged to confirm in writing familiarity with the regulations and principles of occupational health and safety.”

The obligation to create occupational health and safety instructions also arises from specific regulations, including the Regulation of the Minister of Labor and Social Policy of September 26, 1997, on general occupational health and safety regulations. § 41 indicates the following: 

“1. The employer is obliged to make available to employees, for permanent use, current occupational health and safety instructions regarding:

1) the applied technological processes and the performance of work related to accident hazards or threats to the health of employees;

2) the operation of machines and other technical devices;

3) handling materials harmful to health and dangerous;

4) providing first aid.

Instructions referred to in paragraph 1 should, in a manner understandable to employees, indicate the activities to be performed before starting a given job, the principles and methods of safely performing the work, the activities to be performed after its completion, and the principles of action in emergency situations posing a threat to the life or health of employees. Instructions for work involving the use of hazardous substances and chemical preparations should take into account the information contained in the safety data sheets for these substances and preparations.”

INSTRUCTIONS FOR WORKPLACE OHS – LEGAL REGULATIONS

Depending on the type of work or business activities, the obligation to develop instructions arises from various legal regulations. For example, in the case of construction work, the obligation to prepare instructions for the safe performance of construction work results from § 2 of the Regulation of the Minister of Infrastructure of February 6, 2003, on safety and hygiene at work during construction work: “Before commencing construction work, the contractor is obliged to prepare instructions for the safe performance of such work and acquaint employees with it regarding the work they perform.”

Instructions can be developed internally in a given workplace or provided by, for example, the manufacturer of hazardous substances and preparations, machinery, tools, scaffolding, etc.

The scope of the instructions should relate to the specificity of the work. For example, in the case of the assembly of steel structures and prefabricated large-dimensional elements, the instructions should be prepared based on the assembly project and the biocidal plan, by employees familiar with the assembly organization instruction and the type of machinery and other technical equipment used (§ 214 of the above-mentioned regulation).

In many cases, instructions are often mentioned when it comes to using machinery and equipment. With many tasks to perform in a company, there may be a dilemma of whether to buy a ready-made OHS workplace instruction or entrust its development to a specialist.

EHS Consulting provides advisory services in the field of developing OHS documentation, including OHS workplace instructions.

OHS (Occupational Health and Safety) Instructions in Warsaw and the Surrounding Areas – EHS Consulting

Remember that only in the case of instructions prepared within the organization are we able to better manage safety during individual work processes.

If you have any further questions or need assistance in developing OHS instructions for your company, give us a call. We invite you to take advantage of OHS services in Warsaw and the surrounding areas – EHS Consulting.