Early in my career I worked as the waste officer at an ambulance service. For a long time, my specialism was clinical waste, and it taught me something that applies well beyond waste.
A policy and a process are not the same thing.
A policy sets the intention. A process says what you do, in what order, and who does it. The majority of businesses have the first. Fewer have the second, particularly smaller businesses.
Imagine somebody asks about your environmental management. It might be a client, an auditor or it might be a regulator. So, you write a policy. It goes in a folder. Nothing in how the business runs changes, because there’s no process behind it.
That’s bolted on.
Built in is different. The policy has a process behind it, and the process leaves a trail. Your waste transfer and hazardous waste consignment notes. Paperwork that records what you passed on, who took it and how it was disposed of, all created as part of the job - and a legal requirement for all businesses to retain.
That trail is your evidence. When someone asks, there’s no scramble. You show them what you do, and the records back it up.
Take sharps as an example. If you use needles in your work, you know a needlestick injury is a real risk. A well-documented process for handling and disposing of sharps protects you as a business. It shows you have thought it through. If someone who works with you doesn’t follow it and there’s an injury, you are able to demonstrate that your process wasn’t followed. It’s not a ‘get out of jail free’ card but it does show the person acted independently of the business.
The same goes for the rules around wider waste management and your duty of care for the waste you produce. Each one can be a policy in a drawer, or a process that leaves a record.
It goes wider than waste, too. How you buy, how you treat the people you work with, how you run things day to day. That’s the wider world of Environmental, Social and Governance, or ESG. Big companies write reports about it. For a small business it’s the same idea as the consignment note. Write the policy, then build the process that makes it true, and keep the proof.
A process nobody checks can drift. Put a quick review in the diary, the same as for anything else that matters.
If you work alone, you’re in a good position. One person makes the decisions, so you can change how you do something this week and it gives you the perfect opportunity to refine it ahead of taking on any employees.
You don’t need to do it all at once. Pick one thing and ask where it happens in a normal day. Who does it, and what record does it leave?