Health and Safety Policy vs Health and Safety Manual – What’s the Difference?

Why the Confusion?

In South Africa, the Occupational Health and Safety Act, 85 of 1993 (“OHSA”) requires employers to have measures in place to ensure a safe and healthy working environment. Two of the most important documents in achieving this are the Health and Safety Policy and the Health and Safety Manual.

Although these terms are sometimes used interchangeably, they serve different purposes and misunderstanding the difference can leave your business exposed to compliance failures, Department of Labour penalties and increased legal risk.

What is a Health and Safety Policy?

A Health and Safety Policy is a high-level statement of intent from the employer. It sets out your company’s commitment to creating and maintaining a safe workplace, and outlines broad responsibilities rather than detailed procedures.

In South Africa, a Health and Safety Policy typically includes:

• The company’s vision and commitment to workplace safety

• A statement of compliance with the OHS Act and other applicable regulations

• Broad roles and responsibilities of management and employees

• General principles for hazard prevention and employee well-being

The policy is usually signed by the CEO (or Section 16(1) appointee) and displayed prominently in the workplace.

What is a Health and Safety Manual?

A Health and Safety Manual is a detailed, practical guide for implementing your Health and Safety Policy. It contains the procedures, processes and instructions employees must follow to comply with the policy and legal requirements.

The manual is tailored to your operations and serves as the day-to-day reference for managing workplace safety.

The Relationship Between Policy and Manual

Think of your Health and Safety Policy as the “what” and the Health and Safety Manual as the “how”.

• Policy: States your company’s safety goals and commitment.

• Manual: Explains exactly how those goals will be achieved, who will do what, and the procedures to follow.

Without a policy, there’s no official commitment to safety. Without a manual, there’s no clear way to implement that commitment.

Legal Requirements in South Africa

While the OHSA does not prescribe a single template, it expects employers to have:

• A written Health and Safety Policy (particularly for businesses with more than 20 employees)

• Practical procedures that demonstrate how the policy is implemented, this is usually achieved through a Health and Safety Manual

Failing to have both can be seen as a breach of your general duty under Section 8 of the OHSA to provide a safe working environment.

Why Both Are Critical for Compliance

If a Department of Labour inspector visits your site, they will typically ask to see:

1. Your signed Health and Safety Policy; and

2. Your Health and Safety Manual with supporting procedures, risk assessments and legal appointments.

Having one without the other is incomplete compliance and can result in enforcement notices or fines.

How Barter McKellar Can Help

Our OHS legal team works with businesses across South Africa to:

• Draft customised Health and Safety Policies that meet OHS Act requirements

• Develop practical Health and Safety Manuals tailored to your industry and operational risks

• Prepare and formalise legal appointments to support implementation

• Conduct compliance audits and training for your staff

Final Takeaway

Your Health and Safety Policy and Health and Safety Manual are two sides of the same coin, one sets the vision, the other provides the roadmap. Both are essential for OHS Act compliance and for building a safe, productive workplace.