12 Signs Your Health and Safety Arrangements Have Drifted
Health and safety arrangements rarely fail loudly. They decay, one reasonable decision at a time: a person leaves, a floor is reconfigured, a threshold is crossed during a good year, a provider changes, a document is not reopened because nothing has obviously gone wrong.
The organisation feels the same. The arrangements do not describe it any more.
Twelve signs, each checkable in a few minutes, and none requiring a consultant to establish. If several are true, the issue is not any individual item but the absence of a review cycle underneath them.
1. The policy is signed by somebody who has left
Section 2 of the Health and Safety at Work etc. Act 1974 requires the policy statement to be revised as often as appropriate. A signature from a predecessor two roles ago is not a technicality: the statement is meant to represent current senior commitment, and it obviously does not.
2. Your risk assessment describes how the building used to work
Assigned desks in a hot desking office. A single floor in a two-floor demise. An assumption that everyone is present five days a week.
Regulation 3 of the Management of Health and Safety at Work Regulations 1999 requires review where the assessment is no longer valid or where there has been significant change. Reconfiguration, an attendance mandate and a change in headcount all qualify.
3. Nobody can name the competent person
Need Expert H&S Guidance?
Our qualified consultants can help you implement the right health & safety measures for your business.
Regulation 7 requires the appointment of one or more competent persons to assist in complying with statutory duties. Ask three people in your organisation who that is. If you get three answers, or none, the appointment either never existed in writing or has not survived a reorganisation.
4. Reported incidents have quietly fallen
The counterintuitive one. In an office population, fewer reports usually means less reporting rather than fewer events.
Treat an unexplained decline as a question about whether people still believe reporting produces anything, not as evidence of improvement.
5. The oldest open action is more than a year old
Take your action list, sort by date raised, and look at the top. An organisation carrying an open safety action from two years ago has told you how it treats commitments, and no policy statement offsets that.
6. Training certificates have expired without anyone noticing
First aid and fire warden qualifications lapse. Where the register records who was trained but not when it expires, the arrangement is a snapshot rather than a system, and cover disappears silently rather than visibly.
7. The last fire drill produced a time and nothing else
A duration in a spreadsheet is the least useful output a drill can generate. If the record does not say what failed, who owns it and by when, the exercise confirmed that people can walk downstairs, which was never in doubt.
8. The fire risk assessment predates your last change to the building
Article 9 of the Regulatory Reform (Fire Safety) Order 2005 requires review on significant change. A fit-out, a move, new partitions, added occupancy, charging points in the car park or a room converted to storage all qualify.
Compare two dates: the assessment and the last thing that changed. If the second is later, that is the finding.
9. Your documents cite legislation that has moved
This one has become considerably more likely in the past two years. Malta replaced its principal safety statute in 2024. Sweden renumbered its entire work environment rulebook at the start of 2025. India brought four labour codes into force in November 2025. Egypt replaced its Labour Law from September 2025.
If your entities in those countries hold documents drafted earlier, they cite instruments that no longer exist. This is the argument for a maintained legal register rather than a one-off setup exercise.
10. Your smallest entity has never been looked at
Groups examine their largest sites. The exposure sits in the smallest, because thresholds attach at low headcounts in a surprising number of jurisdictions: an occupational medicine service from the first employee in Bulgaria and Belgium, a safety technician for every employer in Greece, both preventive services from the first employee in Slovakia, a safety coordinator at five employees in Malaysia.
A twelve-person office is not a rounding error. It is frequently the entity with the most unmet obligations.
11. Adjustments exist only in a manager's memory
Where a workplace adjustment was agreed verbally with a sympathetic manager, it leaves when that manager does, and the employee has to disclose again and argue for something they already had.
The organisation's knowledge does not reset when a manager changes, which makes this a legal exposure as well as a poor experience.
12. Nobody has asked the landlord for anything in two years
In a leased building a meaningful share of your evidence belongs to somebody else: the premises fire risk assessment, alarm and emergency lighting testing, extinguisher servicing, asbestos information, and the arrangements for shared areas.
If nobody has requested current copies since the last renewal, you are relying on documents you have not seen, held by a party whose maintenance regime you have not verified.
Scoring yourself honestly
| Signs true | What it usually means |
|---|---|
| 0 to 2 | Ordinary maintenance, close them and set a review date |
| 3 to 5 | The review cycle has stopped rather than any single item failing |
| 6 or more | The arrangements describe a previous version of the organisation |
The distinction in the middle row matters. Most organisations that score badly here are not negligent and have not ignored anything deliberately. They have grown, moved, reorganised and hired, and nothing in the calendar triggered a look at whether the arrangements still fitted.
That is what a review cycle is for, and it is the cheapest thing on this page to install. HSE's framework for managing health and safety describes the plan, do, check, act cycle these items all sit inside.
For international groups
Two additional signs worth adding to the twelve.
One methodology, or several? Where each entity was set up locally by a different provider at a different time, a group cannot compare its own entities, because the outputs are not comparable. That is a structural version of drift.
Who holds the current position? If answering "how compliant is our Warsaw office" requires emailing somebody in Warsaw, the group does not have a view of itself. Holding assessments, actions and status for every entity in one register is where health and safety consultants and software are worth more together than either alone.
Periodic health and safety audits exist precisely to catch drift, because drift is invisible from the inside. The arrangements were correct when they were made, everyone remembers making them, and nobody is looking for the gap between the document and the organisation.
Where Arinite fits
Arinite is usually engaged at the point where somebody suspects several of these are true and would like to know how many. We support 1,500+ businesses across 50+ countries and protect 100,000+ employees, with 95%+ client retention over 15+ years. Our health and safety consultants work extensively with legal, finance and banking and IT and software organisations, most of which have grown or reorganised faster than their arrangements.
Where entities sit in several countries, our global health and safety consultants establish the position entity by entity against each national requirement, and our international health and safety consultants keep it current.
If you counted more than three, a free gap analysis will tell you which of them matter most and what it would take to close them.
Related Articles
Written by
Arinite Health & Safety Consultants
Health & Safety Expert at Arinite
