Workplace Safety Policy (Ghana)

A Workplace Safety Policy in Ghana establishes the obligations and procedures governing the conduct it regulates.

Section 9 of the Factories Offices and Shops Act 1970 (Act 328) imposes a general duty on every occupier of a factory, office, or shop registered under Act 328 to maintain the workplace in a condition that is safe and without risk to health. The Department of Factories Inspectorate, which operates under Act 328, has authority to inspect registered workplaces, issue improvement notices, and prosecute employers who fail to comply with the safety requirements of the Act. A written Workplace Safety Policy is a practical means by which an employer demonstrates compliance with the general duty under Section 9 of Act 328.

The Labour Act 2003 (Act 651) supplements Act 328 by imposing obligations on employers relating to the terms and conditions of employment and the welfare of workers. Section 118 of Act 651 obliges every employer to take all reasonably practicable steps to protect the health and safety of workers in the workplace. Section 119 of Act 651 requires employers to provide adequate protective equipment and to instruct workers on its use. A Workplace Safety Policy operationalises these statutory obligations by translating them into specific workplace procedures and responsibilities.

The mining sector in Ghana is additionally regulated by the Minerals and Mining (Health, Safety and Technical) Regulations 2012 (L.I. 2182) administered by the Inspectorate Division of the Minerals Commission. The petroleum sector is subject to safety regulations under the Petroleum (Exploration and Production) Act 2016 (Act 919) and guidelines of the Petroleum Commission. Employers in these sectors must confirm that their Workplace Safety Policy meets the sector-specific requirements of L.I. 2182 or the Petroleum Commission guidelines in addition to the general requirements of Act 328 and Act 651.

Ghana's National Pensions Act 2008 (Act 766) and the workmen's compensation framework under the Workmen's Compensation Act 1987 (PNDCL 187) establish the basis for compensation to employees who sustain injuries or contract occupational diseases arising from their employment. An employer with a documented Workplace Safety Policy that demonstrates proactive hazard identification and control is in a stronger legal position to defend against claims under PNDCL 187 and to demonstrate compliance with the Social Security and National Insurance Trust (SSNIT) requirements relating to occupational injury benefits.

The Ghana Standards Authority (GSA) has adopted international standards including ISO 45001:2018 (Occupational Health and Safety Management Systems) as a voluntary benchmark for Ghanaian organisations. Employers in the manufacturing, construction, and extractive industries that obtain ISO 45001 certification must maintain a documented Workplace Safety Policy as a core element of their occupational health and safety management system.

A Workplace Safety Policy in Ghana covers all persons at the workplace — full-time and part-time employees, casual workers, apprentices, contractors, visitors, and members of the public who may be affected by the employer's activities. The policy must be communicated to all workers in a language they understand, posted at conspicuous locations in the workplace, and reviewed whenever there is a significant change in the nature of the work, the workforce, or the applicable legal requirements.

The Environmental Protection Agency Act 1994 (Act 490) and the Environmental Assessment Regulations 1999 (L.I. 1652) impose additional occupational health and environment obligations on employers whose operations involve hazardous chemicals, waste, or emissions. The Environmental Protection Agency (EPA Ghana) requires companies undertaking prescribed undertakings to submit environmental impact assessments that include occupational health and safety management plans. A Workplace Safety Policy that addresses chemical hazard management, waste handling procedures, and emergency spill response forms an integral part of such a plan.

The Ghana Health Service (GHS) and the Food and Drugs Authority (FDA Ghana) additionally regulate occupational health matters in the healthcare and food processing sectors respectively. Employers in these sectors must align their Workplace Safety Policy with the relevant GHS guidelines on healthcare worker protection and FDA Ghana requirements on good manufacturing practices, both of which incorporate specific health and safety obligations that supplement the general framework of Act 328 and Act 651.

A Workplace Safety Policy in Ghana is required for every employer operating a factory, office, or shop registered under the Factories Offices and Shops Act 1970 (Act 328) and for any employer with five or more employees whose workplace falls within the scope of the Labour Act 2003 (Act 651).

A Workplace Safety Policy is needed when a manufacturing company registers a factory under Act 328 and receives its first inspection visit from the Department of Factories Inspectorate. The Inspectorate's checklist includes a requirement for a written safety policy and safe working procedures. An employer who cannot produce a policy on inspection risks receiving an improvement notice or being subjected to enforcement proceedings.

A Workplace Safety Policy is required when a construction company is awarded a public procurement contract under the Public Procurement Act 2003 (Act 663) or a private sector project, as contracting entities routinely require evidence of a documented safety management system before issuing a letter of award. The policy must address construction-specific hazards including work at height, excavation, scaffolding, and the use of heavy plant and equipment.

A Workplace Safety Policy is needed when a mining company operating under a mining lease granted by the Minerals Commission under the Minerals and Mining Act 2006 (Act 703) prepares its annual environmental and social impact management plan for submission to the Environmental Protection Agency (EPA Ghana) under the Environmental Assessment Regulations 1999 (L.I. 1652). The safety policy forms a key component of the occupational health and safety section of the management plan.

A Workplace Safety Policy is required when a company in the food and beverage sector applies for a Food and Drugs Authority (FDA Ghana) licence under the Food and Drugs Act 1992 (PNDCL 305B). The FDA licensing process includes an assessment of the manufacturer's hygiene and safety management arrangements, and a written policy supports this assessment.

A Workplace Safety Policy is needed when a financial institution licensed by the Bank of Ghana (BoG) or an insurance company regulated by the National Insurance Commission (NIC) implements ISO 45001:2018 as part of its enterprise risk management framework. The Ghana Standards Authority (GSA) requires a written policy statement as the foundation of an ISO 45001-compliant occupational health and safety management system.

A Workplace Safety Policy is required whenever a company faces a workplace accident claim under the Workmen's Compensation Act 1987 (PNDCL 187). Courts and the National Labour Commission (NLC) established under Act 651 consider whether the employer had a written safety policy and whether it was implemented as part of the assessment of the employer's duty of care.

A Workplace Safety Policy is needed when a company incorporated under the Companies Act 2019 (Act 992) applies for a licence from the Energy Commission of Ghana under the Energy Commission Act 1997 (Act 541) to operate in the electricity generation, transmission, or distribution sector. The Energy Commission's licensing conditions require applicants to demonstrate an occupational health and safety management system with a documented policy signed by senior management.

A Workplace Safety Policy is required when an employer registered with the Social Security and National Insurance Trust (SSNIT) under the National Pensions Act 2008 (Act 766) applies for a certificate of good standing. SSNIT compliance officers and external auditors increasingly request evidence of a written safety policy and accident register when conducting employer compliance assessments, particularly for employers in high-hazard sectors such as construction, manufacturing, and agriculture.

A legally compliant Workplace Safety Policy in Ghana under the Factories Offices and Shops Act 1970 (Act 328) and the Labour Act 2003 (Act 651) must contain the following essential elements.

Policy Statement and Commitment: A clear declaration signed by the chief executive officer or managing director of the organisation stating the employer's commitment to providing a safe, healthy, and secure working environment for all employees, contractors, and visitors. The statement should reference the employer's obligations under Section 9 of Act 328 and Section 118 of Act 651, and should be dated and reviewed at least annually.

Scope and Application: A definition of the workplaces, employees, contractors, and activities covered by the policy. For companies with multiple sites — for example, a manufacturing plant in Tema and a head office in Accra — the policy should specify whether it applies to all locations or whether site-specific annexes are maintained. The scope statement should also confirm that the policy covers apprentices and casual workers engaged under the Apprenticeship Act.

Roles and Responsibilities: A clear allocation of health and safety duties to specific roles: the board of directors or management committee (overall accountability); the health and safety manager or officer (day-to-day implementation, liaison with the Department of Factories Inspectorate); line managers and supervisors (hazard identification, toolbox talks, incident reporting); and individual employees (compliance with safe working procedures, reporting of hazards and near misses). The Labour Act 2003 (Act 651) requires employers to appoint a safety officer where the workforce exceeds a prescribed threshold. The named safety officer's contact details and qualifications should be stated in the policy.

Hazard Identification and Risk Assessment: The procedure for conducting workplace risk assessments, identifying significant hazards — including chemical, physical, ergonomic, biological, and psychosocial hazards — and implementing control measures in accordance with the hierarchy of controls (elimination, substitution, engineering controls, administrative controls, personal protective equipment). Risk assessments must be documented and reviewed at least annually or after any significant change in working conditions under the guidelines of the Department of Factories Inspectorate.

Safe Working Procedures: Written procedures for high-risk activities including: operation of machinery registered under Act 328; work at height; electrical work; manual handling; use and storage of hazardous substances regulated under the Environmental Protection Agency Act 1994 (Act 490); hot work (welding, cutting); and emergency plant shutdown. Each procedure should identify the responsible supervisor and the required permit-to-work authority.

Personal Protective Equipment (PPE): The PPE requirements for each job category, the employer's obligation to provide PPE free of charge under Section 119 of the Labour Act 2003 (Act 651), the procedure for PPE inspection and replacement, and the employee's duty to use and maintain PPE. The policy should specify the Ghana Standards Authority (GSA) standards that PPE must meet, for example GSA-certified safety helmets and high-visibility vests for construction sites.

Accident and Incident Reporting: The procedure for reporting workplace accidents, dangerous occurrences, and near misses to the Department of Factories Inspectorate as required under Act 328, the timeline for internal investigation, the format of the accident investigation report, and the corrective action tracking process. Serious accidents resulting in fatality or major injury must be reported to the Inspectorate within 24 hours. The employer's accident register under Act 328 must be maintained and made available to Inspectorate officers on demand.

Emergency Preparedness: The emergency response plan including fire evacuation procedures, assembly points, first aid arrangements, emergency contacts (Ghana National Fire Service — 192, Ghana Police Service — 191, National Ambulance Service — 193), and the schedule for fire drills and emergency exercises. The Ghana National Fire Service Act 1997 (Act 537) requires employers to conduct regular fire drills and maintain adequate fire suppression equipment.

Employee Training and Consultation: The health and safety training programme for new starters (induction), refresher training, and specialist training (first aid, fire warden, forklift operation). The policy must provide for worker consultation on health and safety matters, which may be through a joint health and safety committee or through workers' representatives recognised under Act 651. Minutes of health and safety committee meetings must be retained as evidence of consultation.

Occupational Health Monitoring: A programme for medical surveillance of workers exposed to recognised occupational health hazards — for example, noise-induced hearing loss in manufacturing, silica dust exposure in mining, and chemical exposure in laboratory and processing environments. Occupational health records must be kept confidential and retained for a minimum period in accordance with the Data Protection Act 2012 (Act 843).

Forms-legal.com provides this Workplace Safety Policy template as a starting point for employers in Ghana. Employers in the mining, petroleum, and construction sectors should supplement this policy with the sector-specific requirements of the Minerals and Mining (Health, Safety and Technical) Regulations 2012 (L.I. 2182), the Petroleum Commission guidelines, and the Ghana Standards Authority (GSA) standards as applicable. A solicitor enrolled with the Ghana Bar Association or an occupational health and safety consultant accredited by the Ghana Institution of Engineers (GhIE) should be engaged for complex workplaces.