Health and safety is a top priority at SSGC, both for our employees, and for all other people using our premises or engaged in company activities. This is a legal responsibility that we both recognise and accept - but more than that, it is a non-negotiable ethical duty that extends to all areas of our operations. We pride ourselves on an exhaustive and meticulous approach to safeguarding the health and the safety of our team, our community, and our role in maintaining welfare for society at large.
As such, SSGC is committed to the positive promotion of accident prevention and the elimination of incidents involving personal injury, illness or damage. This duty of care extends to the supply chain for areas such as modern slavery.
We have a number of clear objectives laid out to ensure that our intentions in this regard are fulfilled. These are set out in Section 2. Our methods and considerations in meeting these objectives are contained in this policy - and we ensure strict adherence to it at all levels of operation at our company.
Clear objectives are the key for ensuring the various complexities of health and safety are accounted for at our company. At SSGC we ensure:
i) That responsibility for the implementation of this Health and Safety Policy is clearly defined.
ii) That we both provide and maintain safe and healthy working conditions, equipment, and systems of work for all our employees.
iii) That all employees are aware of their duties under the Health and Safety at Work Act 1974, and other legislation and statutory codes of practice, as well as their responsibilities under this policy.
iv) That clear guidelines on SSGC's Health and Safety Policy exist and are made available to all people using our premises.
v) That any of our employees charged with particular responsibilities for Health and Safety receive adequate training and support to carry out these responsibilities.
vi) That the appropriate level of professional skills and competence in Health and Safety Management is in place.
vii) That adequate financial provision is made to enable this policy to be effectively implemented.
viii) That appropriate procedures are in place to monitor and audit the practice of Health and Safety.
ix) That a formal process is in place to communicate to staff the policy, and any subsequent changes to it that are deemed necessary.
Clarity is key in the execution of any business policy, and is only more crucial in the case of duties of care. To enable these objectives to be met and the policy to be effectively implemented, we are careful to ensure that detailed operating procedures are developed, implemented and kept under review.
At SSGC we know that ensuring a safe and healthy working environment requires the collective effort of all our staff. Each member of our team may have a different role to play, and as such there are different levels of responsibility for the implementation of this policy. The effective execution of this policy requires these roles to be clearly defined. We do so in the following way:
Training and support is the foundation of healthy and safe practices, and we are careful to offer this in a number of ways.
Fundamental to this Policy is SSGC's commitment to have the appropriate number of professionally competent Health and Safety Staff trained and on hand to support our objectives laid out above.
In addition, SSGC has a Corporate Health and Safety function, which is headed up by the Corporate Health and Safety Manager, and supported by a team of professional staff. This function’s role is to provide specialist advice and guidance to our management and staff on Health and Safety matters.
We recognise the complexities of addressing health and safety across different locations - it is important to us that all staff have easy access to local arrangements, to eliminate any doubt about procedure generally, and local guidance specifically.
Therefore, as a crucial part of the supporting procedures and arrangements, SSGC produces a unique manual containing the local arrangements for Health and Safety at each location in which we operate. A copy of this manual is held by each of the direct reports to the Management Executive, by each Operations Department, by the Corporate Health and Safety Department, and by local safety staff.
All employees are able to consult the appropriate manual for their location, and it is accessible via the employee’s Manager.
6.1. Key Responsibilities
The key responsibilities for the implementation of the Corporate Health and Safety Policy are set out in the main policy document, and are as follows:
6.1.1. The Board of SSGC takes overall responsibility for Health and Safety in SSGC and for the implementation of this policy. In particular, our Chief Executive is accountable for ensuring that the system is implemented effectively across SSGC as a whole.
6.1.2. Each member of the Management Executive is responsible for ensuring the effective implementation of this policy for the area(s) for which they are accountable. In particular, the Production Manager is responsible for the ongoing development and issue of this policy, for advising management on its implementation, and for monitoring its application.
6.1.3. All Managers are responsible for the implementation of this policy and compliance with the related procedures and arrangements for their area of accountability.
6.1.4. All Employees are responsible for their own Health and Safety and that of others; in particular, they comply with the procedures and arrangements issued under this policy, which are applicable to their area of activity.
6.1.5. Management and staff employed on an indirect or contractual basis are charged with the same responsibilities for the implementation of the Health and Safety Policy as if they were direct employees of SSGC.
6.2.1. As noted in part 6.1.3 above, the overall responsibility for the implementation of this policy rests with management, who are careful and dutiful in exercising care and caution in business operations. Day to day responsibility is site-based.
6.2.2. Each site has an appointed Senior Member of Management - referred to as the SMOM - to take Site responsibility under the policy.
The local arrangements for each of our Sites detail the name and job title of the Senior Member of Management (SMOM), who has the designated responsibility for that site under this policy.
6.2.3. Our SMOMs take particular responsibility for:
6.3.1 SSGC is fully and willingly responsible for the Health and Safety of its employees at work. However, we expect all employees to take reasonable care of their own health and safety, and that of any other employees, contractors or visitors. We empower them with the tools and training to do so.
6.3.2 One facet of this support is the policy and procedures themselves. All our employees have read and are familiar with the SSGC Corporate Health and Safety Policy, including the detailed procedures and arrangements contained in the Health and Safety Policy and procedures manual, and in local arrangement manuals.
In particular:
6.3.3. All employees understand the personal responsibility they carry for complying with procedures and arrangements which apply to their area of activity. We take this very seriously, and neglect of, or failure to comply with, health and safety rules, is treated as a breach of disciplinary rules. The employee may be subject to action under our disciplinary procedure.
We do not take lightly any risk posed to the safety of our team. Health and safety is the concern of every employee, and constitutes an integral part of all operations. Our employees understand their duty of care when it comes to the health and safety of themselves and other persons who may be affected by their acts or omissions at work.
We understand, too, that our employees will often be best placed to notice any new amendments that have to be made. This is why SSGC expects all employees to assist in the application of the SSGC Corporate Health and Safety Policies, and to promptly report to their line management any hazard, shortfall or difficulty they may experience, or observe, that could contribute towards the overall reduction of accidents, ill-health or damage.
As part of our exhaustive commitment to upholding the highest standards of health and safety, we understand our duty of care to extend to all who fall under the umbrella of our company operations. This includes everyone, other than staff directly employed by SSGC, for example (but not limited to): Contractors, Visitors, Committee Members, Representatives of external business partners, Sales Representatives, Representatives of Utilities, and Delivery Staff and Inspecting Officers.
We ensure that all such persons are sponsored by an authorised member of SSGC staff, who is responsible for them during their entire time on SSGC premises.
8.1.2. All SSGC employees and people other than SSGC employees, who use SSGC premises, are provided with support and training to ensure they understand the emergency procedures.
8.1.2. The emergency procedures for each site are:
We recognise that practice is an important aspect of an effective emergency procedure along with procedural familiarity; this is why we are careful to set aside time to furnish our staff with such concrete experience.
8.1.3. A Senior Member of Management (SMOM) is responsible for ensuring that appropriate action is taken in an emergency.
8.1.4. We are careful to ensure that the emergency evacuation procedure for each site complies with the following requirements:
8.1.5. Local arrangements are in place to monitor incoming packages, and receptionists have a clear and rigorous procedure for dealing with bomb threats.
8.1.6. Emergency Team - Because of the nature of our business, there are certain situations that can occur within a SSGC establishment that may require a response by members of staff who have specific knowledge or training. We do not intend under these circumstances to emulate the emergency services, but it is important for SSGC to be able to offer knowledgeable support in situations that may be particular to our business.
We are acutely aware of our responsibility to cooperate with the emergency services, and where it is necessary that they be called we strive to offer the most complete information and support possible. We have local arrangements in place to ensure that information is available to the emergency services and others, and where practicable we aim to have staff available to assist in circumstances such as:
8.2.1. Familiarity with emergency procedures is a key part of ensuring that safety is both felt and maintained. We expect all SSGC employees and others who use SSGC premises to understand the fire procedures, and to that end we furnish all parties with the means and time to study them.
8.2.2. The fire procedures for each site are:
8.2.3. The fire procedures for each of our sites comply with the following requirements for action on the discovery of a fire:
8.2.4. In the event of a fire evacuation of one of our sites:
8.2.5. We recognise the importance of all equipment being kept up to code in case of emergency. As such, we carry out regular and exhaustive checks:
8.2.6. Fire Warden
Special members of our staff are appointed to assist in the orderly evacuation of SSGC controlled buildings. These Fire Wardens are responsible for ensuring that people within their area are safely evacuated or accounted for in the event of an emergency.
We also grant our Fire Wardens the authority to insist that staff and visitors comply with evacuation procedures when the need arises - and this includes our fire drills.
Local arrangements detail any extension to this primary duty, and may assign tasks such as:
8.2.7. Senior Member of Management (SMOM) responsibilities in an emergency
8.3.1. Our local arrangements at each site detail the requirements for First Aid, and all arrangements comply with the following:
8.4.1. We recognise that our commitment to running a safe business involves cooperating in various ways with external bodies. For instance, we recognise our obligations to notify and report to the relevant enforcing authorities specified injuries, diseases and dangerous occurrences which occur at work. All local arrangements on each site are careful to comply with the following requirements, and detail how they will be implemented.
8.4.2. Accident Book - All accidents resulting in injury, however slight, and accidents which may have resulted in property damage are entered in the Accident Book (B.1.510 or equivalent). We are sure to investigate them, and keep rigorous and complete records through our SSGC internal accident report forms. Our local arrangements detail the location of the Accident Book at each building or site.
8.4.3. Accident Report Forms (2508 and 2508A) - The required injuries, diseases and dangerous occurrences are reported as per RIDDOR 2013, and only by senior management or a competent health and safety person.
Regulations require the enforcing authority to be notified by the quickest practicable means, and our local arrangements specify who is responsible for doing so.
In such cases SSGC carries out a full investigation, promptly completes Form 2508 and dispatches it to the enforcing authority, and sends a copy to the local Safety Staff. All our forms and RIDDOR details are held by Head Office, and are used only for external reporting to the enforcing authorities.
8.4.4. Investigation - Initial investigation of all accidents, property damage incidents or near-miss situations is carried out by the SSGC Manager responsible for the area. Our local arrangements detail to what degree, and by whom, further investigations must be undertaken.
These accident forms are collated locally by the local Safety Staff or Property and Facilities representatives, and a summary is forwarded regularly to the Corporate Health and Safety Manager. This manager uses the forms to decide whether to initiate further investigation, and to verify local statistics.
8.5.1. All our agency staff (including all short-term contract staff) are the responsibility of the employing department, but fall under our duty of care. As such, they receive Health and Safety training relevant to the length and type of employment they are undertaking.
8.5.2. The management of maintenance contractors is also the responsibility of the employing department.
8.6.1. We ensure that all site visitors are armed with the appropriate information and safeguards to remain secure. The local arrangements we have in place on each site comply with the following requirements:
8.7.1 The person in control of the meeting ensures all those in attendance have their attention drawn to our emergency procedures. To support this end, First Aid and fire evacuation information is displayed in all meeting rooms, and the location of the visitor's assembly point is clearly explained.
All accidents and incidents, however minor, are recorded at the time and dealt with in accordance with Section 8.4 of this Policy.
8.8.1. No health and safety policy can claim to be effective if it is not underpinned by a holistic and accurate understanding of the risks it is intended to mitigate. This is why SSGC carries out regular risk assessments. Local arrangements on each of our sites detail how risk assessments are carried out, and all meet the following requirements:
8.8.2.
8.9.1. Part of SSGC’s legal duty of care is the provision of safe systems of work. More importantly, we understand such systems to both protect our workforce, and contribute to a healthier and stronger company. We are therefore proactive and forthright about putting them in place. Local arrangements are detailed in line with the following requirements.
8.9.2. We ensure that safe systems of work are established following a risk assessment process, so that they are a good and effective fit for their environment . A record is kept by the responsible Manager and a copy sent to the local Safety Staff using the SSGC form.
8.9.3. The factors we take into account include, but are not limited to, the following:
8.10.1. Client's Premises
We ensure that the stipulations of the Health and Safety at Work Act 1974 are upheld by SSGC staff on business wherever they are. When on a Client's premises, SSGC staff are careful to acquaint themselves with the Client's procedures for emergencies such as evacuation and First Aid.
8.10.2. Accidents
If an accident occurs away from SSGC premises, it is reported both to the company concerned and to SSGC.
8.10.3. Security
Staff sign both in and out when visiting other SSGC locations, and inform their Fire Warden when leaving. Local security notices and procedures are strictly followed.
8.10.4. Foreign Travel
Before travelling, our staff carefully consult the current Department of Health and Central Office of Information booklet "Health Advice for Travellers". When visiting outside the UK, our staff carry an emergency medical pack (see local procedures).
8.10.5. Insurance
All our SSGC identity card holders are insured for medical expenses while on SSGC business abroad. Details are on the reverse of the ID card, and we ensure our staff carry this at all times when on SSGC business.
8.10.6. Working alone/outside regular office hours
Our staff do not work on their own unless there is a security guard or delegated responsible person present who is aware of their presence. Our staff are alert to the fact that emergency cover is not the same out of regular working hours.
8.10.7. Company Vehicles
All accidents are reported to the relevant Manager. All defects are dealt with in accordance with the leasing company's instructions and the SSGC Business Vehicle Policy. Basic First Aid kits are made available for all SSGC owned or hired vehicles.
8.11.1. SSGC recognises the risks associated with using screen equipment - as such, we carry out workstation assessments for all staff who habitually use display screen equipment. Records of assessments are retained by the Manager responsible for carrying them out.
The safety of our employees and associated persons is of utmost importance. On occasions when hazards cannot be removed by engineering means, or if the risk cannot be reduced to an acceptable level, personal protective equipment is always provided. Our local arrangements ensure the following:
8.13.1. To comply with the Manual Handling Regulations, we undertake thorough risk assessments of all lifting operations, and our local Safety Staff or Property and Facilities representatives keep appropriate and meticulous records.
8.13.2. Our employees do not lift, move or carry a load so heavy as to be likely to cause injury. Where possible, a trolley or mechanical appliance is used.
8.13.3. We provide suitable and appropriate training to all employees who are required to lift items regularly in the course of their employment.
8.14.1. The Electricity at Work Regulations and British Standards lay down the requirements for the design, installation, inspection, testing and maintenance of all electrical equipment. We are rigorous in our approach to ensuring these requirements are met.
8.14.2. Our local procedures detail the arrangements made to ensure that these regulations are complied with, and that the following requirements are met:
8.15.1. Substances hazardous to health are controlled during their selection, receipt, distribution, use, storage, and disposal.
8.15.2. A risk assessment of all hazardous substances is carried out for the organisation, including but not limited to chemicals, gases, biological substances, and dust.
8.16.1. We understand that risks to health and safety can be posed by the most innocuous things - including poorly-stacked shelves, or overloaded office sockets. Local arrangements on each location detail requirements for maintaining the appropriate standard of housekeeping. Our managers ensure their areas are kept tidy and free from hazards to health and safety, and swiftly rectify any problems that might arise.
8.16.2. This includes general workplace factors, for example the following:
8.16.3. Regular inspections are carried out, and findings documented.
8.17.1. Each of our locations complies with the Control of Asbestos at Work Regulations.
8.17.2. SSGC has very clear and defined procedures for work with, or near, asbestos products.
All equipment used for temporary access is of sound quality, and used by trained staff who are authorised to use the equipment in the way that it was intended by the supplier. In addition, we are careful to ensure our equipment is of top and serviceable quality, so:
SSGC understands that dangerous noise levels can result in lifelong, debilitating health defects, and require careful monitoring to protect our team and the integrity of our policy. That is why we contract an external specialist to carry out full noise assessments if noise is identified as a significant risk. If it is not possible to reduce the excessive noise by engineering means, we issue our team with ear defenders (PPE) and ensure they are properly used. In high-level noise areas, we clearly display appropriate warning signs.
Where the nature of the work is particularly hazardous, we have special practices in place to ensure the correct precautions have been identified and are being taken. In these instances, a permit to work must be obtained to control the risk before, during and after the job, stating the safety measures to be taken.
This permit determines in advance which safety procedure should be in place, and serves as a clear record that all foreseeable hazards have been considered and appropriate precautions defined.
Clear and uniform communications are necessary to ensure our staff can feel safe, protected, and empowered in their upholding of this policy at all times. All the safety signs we use on SSGC sites conform to the Safety Signs Regulations 1980 and British Standards.
On some occasions it is necessary for SSGC staff to work alone or out of sight of other staff. Where this is the case, we ensure that our local arrangements include:
Mechanical handling equipment has the potential to pose serious health and safety risks: if misused by unauthorised or untrained staff, it could cause significant damage or injury. SSGC are diligent in ensuring that any mechanical handling equipment is operated with the utmost care, and the highest required levels of attention and training.
8.23.1. Manually powered handling equipment is only operated by trained and competent staff authorised by SSGC.
8.23.2. No mechanical handling equipment is used in excess of its maximum safe working load, or in a manner other than for which it was intended to be used.
8.23.3. All mechanical handling equipment is used and maintained to ensure its continued function.
SSGC understands that, in addition to being operated correctly, the machinery we use must also operate correctly itself. All existing and new machinery within our control is therefore capable of being used in a way that:
Our patrolling Security Officers are empowered to observe and make notes on these and any other matters of importance; any comments are promptly brought to the attention of the clients' representative. In doing so, our Security Officers help the Client to meet their legal obligations, and help employees uphold and work within the highest standards of safety.
Safety at work is not just a legislative commitment. It is the backbone of fostering an effective, trustworthy, and ethical business practice. It is the pillar of any robust organisation. And it is a humane imperative. That is why SSGC is rigorous about providing the necessary training, instruction and information to empower our employees to work safely.
Health and safety training at SSGC starts the second our new hires walk through our door. It is covered during induction training for all our employees, including those working temporarily and part-time, particularly relating to:
Health and safety training is not a one-off event. Knowledge requirements will change depending on the areas and levels in which an employee operates, and we are careful to provide additional training where necessary to ensure our policies can be effectively implemented by our team.
All our Managers who are responsible for staff are given additional health and safety training commensurate to their position. Some managers will have role-specific responsibilities, and in these cases further appropriate training will be given.
In general, all Managers with staff responsibilities are trained in the following areas:
Armed with the knowledge this course offers, our Managers are then able to brief their own staff on the relevant details. In this way, all our employees receive specific, actionable information as to how they can best keep themselves and their colleagues safe in line with SSGC policy.
Our employees and managers may find themselves exposed to new or increased risks in their line of work. Where this is the case, SSGC offers additional specialised training in advance. Situations that warrant further training include:
We adapt any such training to take account of any new or changed risks to the health and safety of the employees concerned.
In order for continued training to be effective, it must be correctly deployed. We do not want to miss an opportunity to enrich and arm our employees with further knowledge, particularly if they need it to remain safe. That is why we have a careful chain of responsibility for identifying training needs.
The identification of training needs falls to our line managers/supervisors, in partnership with the Corporate Health and Safety Manager, and local Safety Staff who are responsible for advising training departments on what training is required to comply with statutory requirements and SSGC procedures.
Our Operations Department is responsible for arranging appropriate training, in conjunction with the Corporate Health and Safety Manager and local Safety Staff.
The maintenance of training records in all subjects is essential, but it is particularly so with respect to health and safety. SSGC records in this area are maintained by the Operations Department.
10.1.1. We recognise that maintaining the highest levels of health and safety requires financial, as well as policy, commitments. There is no excuse for failing to budget for employee safety. That is why our Corporate Finance function provides each business unit with detailed planning and budgeting instructions annually for Health and Safety, setting out the timetable and exact requirements of the financial planning process.
10.1.2. Each of our business units prepares an annual budget. Within each business, the Senior Managers with responsibility for each operational area participate in setting the budget and ensuring that it makes provisions for all activity and expenses, including capital expenditure, which is necessary to ensure the effective implementation of SSGC’s Corporate Policy on Health and Safety.
10.1.3. The proposed annual budget is agreed with the Management Executive Director in whose area of responsibility the business unit is located, and is submitted to Corporate Finance for inclusion in the financial planning process.
10.1.4. The proposed annual budgets of each business unit are agreed with the Chief Executive, and are consolidated for review and approval by the company board.
10.2.1. Each of our business units monitors its performance against the agreed budget at each financial period. Forecasts for the out-turn of the financial year are prepared at the end of each quarter.
Within each business unit, the Senior Managers with responsibility for each operational area ensure that in the forecasting process provision is made for all contingent activity and expense, including capital expenditure, which is necessary to ensure the effective implementation of our Corporate Policy on Health and Safety, and for which provision was not made at the time of the annual budgeting process.
A robust and exhaustive policy is only as good as the effects it can be shown to have. Moreover, in the case of health and safety, risks and vulnerabilities can crop up unexpectedly. This is why regular auditing and review of our health and safety policy is a crucial aspect of its implementation.
Safety audits are undertaken by the management team in order to monitor the effectiveness both of our policy implementation, and of the risk assessment process. The results of such audits and reviews are made available to the appropriate director or other relevant parties upon request.
Local Safety Staff, Property and Facilities Staff and line management will carry out periodic health and safety inspections of SSGC premises to verify compliance with the operational aspects of the policy and other health and safety arrangements and operating procedures, whether contained in the Health and Safety Policy and Procedures Manual, or in local arrangements.
The monitoring systems we use will follow one of two principles:
SSGC employs reactive systems for the purposes stated. We intend, however, to use the health and safety management system to improve health and safety performance and not merely to record and rectify shortfalls. To this end, our auditing process primarily uses active methods to measure and monitor SSGC health and safety performance in practice.
An audit by the Corporate Health and Safety Department will take place at least once every 12 months.
We expect our employees to take an active role in monitoring health and safety. We encourage employees to report any hazard within their area of operation that could be improved upon to better deliver a safe and healthy workplace - our local arrangements make provisions for our employees to do so.
12.1.1. We communicate any changes to the Health and Safety Policy and the key operating procedures through our Cascade Communication Process, and supplement this through issuing notices. Where appropriate, training will be provided as per Section 6 of the Health and Safety Policy and Procedures Manual.
12.1.2. In addition to the formal communication of changes to the Corporate Policy and Procedures Manual, the Corporate Health and Safety Department publishes a short leaflet at least one per year. This leaflet advises our employees on critical developments in health and Safety, including raising questions for employees to reflect upon so that their feedback might be incorporated into further policy or procedure amendments.
Approval For this Statement
This statement was approved by the Board of Directors on 27/10/2022 signed by Frano Lubura, Quality Manager/General Manager.
