The recurring statutory obligations
Under the Occupational Safety and Health Act 2007 and its subsidiary rules, the obligations that recur on a fixed cycle include:
- Annual safety and health audit. The occupier of a workplace must have a thorough safety and health audit carried out at least once every twelve months by a qualified safety and health advisor, with the report submitted to the Directorate of Occupational Safety and Health Services.
- Annual fire safety audit. Under the Fire Risk Reduction Rules 2007, workplaces must be audited annually by an approved fire safety auditor. This is a separate exercise from the general OSH audit and is frequently overlooked.
- Safety and health committee. A workplace regularly employing twenty or more people must establish a safety and health committee with fair representation from workers and management. The committee is required to meet quarterly — four documented meetings a year, with minutes.
- First aid provision. The Occupational Safety and Health (First Aid in the Workplace) Regulations 2024 apply to all workplaces, not only factories. Employers must conduct a first-aid needs assessment, maintain a sufficient number of trained first-aid providers, provide adequate first aid boxes stocked to the schedule set out in the regulations, and where necessary provide a dedicated first aid room. Medicines are not permitted in the first aid box.
A workable annual cycle
Dates below are indicative — anchor them to your own audit anniversary and financial year.
- January. Review the previous year's incidents and audit findings. Confirm which corrective actions are genuinely closed, with evidence.
- February. Refresh the risk assessment for any process, equipment or layout that changed during the year.
- March. Q1 safety and health committee meeting. Review the first-aid needs assessment against current headcount and shift patterns.
- April. Fire drill. Record participation, evacuation time and the problems the drill exposed — a drill with no findings is usually a drill that was not taken seriously.
- May. First aid and fire marshal certification review. Book refreshers for anyone expiring in the next six months rather than the next six weeks.
- June. Q2 committee meeting. Mid-year review of corrective action progress.
- July. Contractor and supplier safety review. Confirm competence and insurance for anyone working on your sites.
- August. Prepare for the statutory OSH audit: assemble records, close outstanding actions, check registers are current.
- September. Q3 committee meeting. Statutory OSH audit and fire safety audit conducted.
- October. Audit findings turned into a corrective action plan with named owners and deadlines. Second fire drill.
- November. Machine guarding, PPE and chemical storage inspection. Review safety data sheets.
- December. Q4 committee meeting. Set next year's training calendar and budget.
Where employers most often come unstuck
Treating the audit as the compliance programme. An annual audit is a snapshot. If nothing happens between audits, the second one finds the same issues as the first, and a pattern of repeat findings is considerably worse than a single finding.
Committees that exist on paper. A named committee that has not met, or meets without minutes, provides no defence and no benefit. Four short, minuted meetings are worth more than one long meeting that never happens.
Certificates expiring quietly. First aiders and fire marshals leave, move departments or let certification lapse. Without a tracked register, employers discover the shortfall during an incident.
The organisations with the best safety records are rarely the ones with the thickest manuals. They are the ones where a small number of things happen reliably, on a date, every year.
Put the cycle in a shared calendar with named owners, and most of the exposure disappears.