Alex is Sprintlaw’s co-founder and principal lawyer. Alex previously worked at a top-tier firm as a lawyer specialising in technology and media contracts, and founded a digital agency which he sold in 2015.
- What Is A Health And Safety Policy (And Do You Need One In NZ)?
- What NZ Law Expects From Your Business (In Plain English)
What To Include In A Health And Safety Policy (A Practical Checklist)
- 1. A Clear Statement Of Commitment
- 2. Scope: Who And What The Policy Covers
- 3. Roles And Responsibilities
- 4. Hazard Identification And Risk Management
- 5. Training, Supervision, And Safe Work Procedures
- 6. Incident Reporting, First Aid, And Emergency Management
- 7. Worker Engagement And Participation
- 8. Managing Contractors And Visitors
- 9. Alcohol, Drugs, And Fitness For Work (If Relevant)
- Key Takeaways
If you’re running a small business, it’s easy to treat paperwork as something you’ll “get to later”. But a health and safety policy is one of those documents that’s worth getting right from day one.
In New Zealand, health and safety obligations don’t just apply to construction sites or factories. They apply to every business - whether you run a café, retail store, tradie business, clinic, warehouse, gym, or an online business with a small team.
A clear health and safety policy helps you do two big things:
- Keep people safe (workers, contractors, customers, and visitors)
- Show you’re meeting your legal obligations under New Zealand health and safety law
Below, we’ll walk through what your health and safety policy in NZ should include, how it fits into your wider compliance system, and the practical steps to stay compliant as your business grows.
What Is A Health And Safety Policy (And Do You Need One In NZ)?
A health and safety policy is a written statement that sets out how your business will manage health and safety risks at work.
Think of it as the “top-level” document that explains:
- your commitment to health and safety
- who is responsible for what
- how you’ll identify hazards, manage risks, and respond to incidents
- how you’ll involve workers in health and safety
In NZ, the key law is the Health and Safety at Work Act 2015 (HSWA). Under HSWA, a business (usually referred to as a PCBU - a “person conducting a business or undertaking”) has a primary duty of care to ensure, so far as is reasonably practicable, the health and safety of workers and that other people are not put at risk by the work carried out.
While HSWA doesn’t set a one-size-fits-all rule that every business must have a written policy in every situation, having a clear, written health and safety policy is one of the simplest and most practical ways to show you are actively managing your duties - especially if you have staff, contractors, a physical workplace, or customer traffic.
If you’re already putting together a Workplace Policy suite, your health and safety policy is usually one of the core documents you’ll want included and aligned with everything else.
What NZ Law Expects From Your Business (In Plain English)
Health and safety compliance can sound intimidating, but the core expectations are practical.
As a small business, the law generally expects you to take reasonable, proactive steps to keep people safe. That means you should be able to show that you:
- identify hazards (things that could cause harm)
- assess risks (how likely harm is, and how serious it could be)
- control risks (using practical measures to eliminate or minimise risk)
- train and supervise workers so they can do their job safely
- consult and engage with workers about health and safety matters
- respond to incidents, record them, and improve your processes
It also helps to understand that health and safety is not limited to physical hazards. Depending on your workplace, risks can include things like:
- manual handling injuries (lifting, repetitive movements)
- slips, trips, and falls
- fatigue and overwork
- stress, bullying, and psychosocial risks
- vehicles and driving for work
- hazardous substances
- public-facing risks (aggressive customers, lone working)
If you employ staff, these obligations should also be reflected in your Employment Contract and your wider employment documents so expectations are consistent across the board.
And because this area is closely linked to your responsibilities as an employer, it’s worth understanding the broader concept of employer duty of care - it often overlaps with how you manage health, safety, and wellbeing at work.
What To Include In A Health And Safety Policy (A Practical Checklist)
There’s no perfect template that works for every industry. Your health and safety policy should reflect the reality of your business: your team size, the kind of work you do, the site you operate from, and the risks you actually face.
That said, a strong health and safety policy in NZ usually includes the sections below.
1. A Clear Statement Of Commitment
Start with a short statement that you are committed to providing and maintaining a safe and healthy workplace, meeting your duties under HSWA, and continuously improving.
This sounds simple, but it sets the tone. It’s also useful if you ever need to show customers, landlords, or partners that you take compliance seriously.
2. Scope: Who And What The Policy Covers
Be specific about who the policy applies to, such as:
- employees (full-time, part-time, casual)
- contractors and subcontractors
- volunteers (if you have them)
- visitors and customers on site
You can also include where it applies (for example, at your premises, on client sites, in vehicles, and while working from home).
3. Roles And Responsibilities
Spell out who is responsible for health and safety tasks. For a small business, this often includes:
- Business owner/director/manager: overall responsibility for systems, resourcing, and follow-through
- Supervisors/team leads: day-to-day safety oversight and ensuring procedures are followed
- Workers: following instructions, using equipment properly, reporting hazards and incidents
- Contractors: complying with site rules and taking reasonable care
If you’re building out a more complete set of workplace documentation, these responsibilities can also sit neatly inside a Staff Handbook (alongside conduct expectations, reporting lines, and internal processes).
4. Hazard Identification And Risk Management
This is the “engine room” of most health and safety policies.
Your policy should explain how you will:
- identify hazards (regular inspections, worker feedback, incident reviews)
- assess the level of risk
- control risks using the hierarchy of controls (eliminate, substitute, isolate, engineering controls, admin controls, PPE)
- review controls regularly (especially after changes or incidents)
Tip: it’s common to refer to a separate hazard register or risk register in your policy. Your policy can set the rules, and the register can hold the detailed, site-specific hazards and controls.
5. Training, Supervision, And Safe Work Procedures
Your health and safety policy should cover how you ensure people can actually work safely in practice - not just on paper.
This might include:
- induction and onboarding (especially for new starters)
- training on equipment, machinery, chemicals, or systems
- competency checks (where relevant)
- ongoing supervision and refreshers
- clear safe operating procedures (SOPs) for higher-risk tasks
If your business uses monitoring tools (like CCTV) as part of security or safety, make sure you handle it carefully - there are privacy and employment considerations. It’s worth getting familiar with the rules around workplace cameras so your approach is fair and compliant.
6. Incident Reporting, First Aid, And Emergency Management
Your policy should clearly explain what happens if something goes wrong.
Common inclusions are:
- how to report a hazard, near miss, injury, or incident
- who to report to (and how quickly)
- first aid arrangements (who the first aider is, where kits are kept)
- evacuation procedures and emergency contacts
- how investigations are handled and improvements are implemented
If your incident reports contain personal information (which they usually do), think about how you collect, store, and access those records. Your Privacy Policy and internal privacy practices should support this, particularly if you store reports digitally or use third-party software.
7. Worker Engagement And Participation
Under HSWA, worker engagement and participation is a key part of health and safety compliance, but what this looks like in practice will depend on your business size and risk profile.
In a small business, this doesn’t need to be complicated. Your policy can explain how you’ll do this in a practical way, such as:
- regular toolbox talks or team check-ins
- a clear “raise a concern” process
- encouraging workers to suggest improvements
- communicating changes that affect health and safety (new equipment, new location, new procedure)
8. Managing Contractors And Visitors
Even if you don’t have employees, you may still engage contractors (cleaners, tradies, delivery drivers, IT technicians) or have customers and visitors on site.
Your health and safety policy should address:
- how contractors are inducted or informed about site rules
- how you ensure contractors don’t create unmanaged risks for others
- how you manage visitor safety (sign-in procedures, restricted areas, signage)
9. Alcohol, Drugs, And Fitness For Work (If Relevant)
Not every workplace needs drug and alcohol testing, and it’s not something you should introduce casually. But if you operate vehicles, heavy machinery, or other safety-sensitive work, you may need a clear approach to fitness for work.
If testing is part of your system, you’ll generally want a properly drafted policy and process (including when testing may occur, how it’s carried out, how results are handled, and how privacy is protected) and clear consent documentation, such as a Drug Test Consent Form, to reduce the risk of disputes and privacy issues.
How To Stay Compliant Over Time (Not Just On The Day You Write The Policy)
A health and safety policy is a great start - but compliance is really about what you do day-to-day.
Here are practical ways to keep your health and safety policies working as your business grows.
Review Your Policy When Your Business Changes
Set a regular review cycle (for example, every 12 months), but also review your policy when something changes, such as:
- you move premises
- you start offering new services
- you buy new equipment
- you hire staff or start using more contractors
- an incident or near miss happens
Keep Records That Back Up Your Policy
If WorkSafe ever asks questions (or if there’s a serious incident), it helps to have records showing you actually followed your system.
Useful records include:
- training and induction records
- hazard register updates
- maintenance logs
- incident and near miss reports
- meeting notes where health and safety was discussed
Make Sure Your Team Actually Understands It
A policy that sits in a folder no one reads won’t protect your people (or your business).
Keep the language clear, train workers on what matters for their role, and make it easy for them to report hazards and incidents without fear of being blamed.
Watch For “Hidden” Health And Safety Risks
Many small businesses focus on obvious physical risks, but forget operational and people risks that can be just as serious, like:
- fatigue from understaffing
- unsafe customer interactions (especially in retail/hospitality)
- repetitive strain injuries in office-based businesses
- working alone or after-hours
If your staff work remotely (even occasionally), health and safety still matters. Your approach should cover workstation safety, communication, and incident reporting. (Many businesses also document this alongside their working arrangements - see working from home considerations.)
Common Mistakes Small Businesses Make With Health And Safety Policies
Most health and safety issues we see aren’t caused by business owners not caring - they’re caused by being time-poor, moving fast, and assuming a basic template will do the job.
Here are some common traps to avoid.
Using A Generic Template That Doesn’t Match Your Workplace
Templates can be a starting point, but if your policy doesn’t reflect your actual risks, it can create a false sense of security.
For example, a hospitality venue and a construction business shouldn’t have the same hazard controls. Even two cafés might have very different layouts, equipment, and customer traffic risks.
Not Covering Contractors Properly
Small businesses often rely heavily on contractors - but forget to document how contractors are managed, inducted, and monitored. This can be a major gap if an incident happens involving a contractor on site.
Having A Policy That Conflicts With Your Employment Documents
Your health and safety policy should match what your employment documents say about reporting lines, investigations, misconduct, privacy, and workplace behaviour.
If you’re putting documents in place, it’s usually best to make sure your health and safety policy works seamlessly with your Employment Contract terms and your wider Staff Handbook.
Forgetting Privacy When Handling Health Information
Health and safety often involves sensitive information (injury details, medical certificates, fitness for work issues).
If you collect, store, or share this information incorrectly, you can create a privacy problem alongside your health and safety problem. This is why it’s smart to make sure your internal processes align with your Privacy Policy and any privacy training you provide.
Key Takeaways
- A strong health and safety policy helps you protect your team and demonstrate compliance with New Zealand’s Health and Safety at Work Act 2015.
- Your policy should be tailored to your business and clearly cover responsibilities, hazard and risk management, training, incident reporting, and worker engagement.
- Health and safety compliance is ongoing - review your policy as your business changes, and keep records that show how you follow it in practice.
- Small businesses often get caught out by generic templates, contractor gaps, or policies that don’t match their day-to-day operations.
- Health and safety documents should work alongside your other workplace documents, like an Employment Contract and staff policies, so expectations are clear and consistent.
- If your policy involves monitoring, testing, or health information, make sure you also manage privacy and consent properly.
This article is general information only and not legal advice. If you’d like advice for your situation, get in touch with a lawyer.
If you’d like help drafting or updating a health and safety policy (or building a full set of workplace policies that fit how your business actually runs), you can reach us at 0800 002 184 or team@sprintlaw.co.nz for a free, no-obligations chat.








