The concept remains for you to consider areas of your management by investing 15 minutes of your time (possibly a little more this time around!) to challenge your processes and procedures.
We have asked three questions for you to investigate and identify whether you are meeting the level of compliance you are expecting. Some months may involve simply reviewing documents, others to go and look at items or challenge processes.
Our three questions are below, please read on for some points to consider:
What is the latest Government guidance and how does it relate to different sectors?
What are the Government requirements for a COVID-19 risk assessment?
What are your communications and activities around making your building ‘COVID Secure’?
1. What is the latest Government guidance and how does it relate to different sectors?
The foundation for our return to work is “Our Plan To Rebuild – The UK Government’s COVID-19 recovery strategy”. Published on the 11th May 2020, the plan runs to some 50 pages and covers six main areas:
- The current situation;
- Our aims (saving lives and livelihoods);
- Our approach in terms of a phased recovery;
- The roadmap to lift restrictions;
- The fourteen supporting programmes in place; and
- How we can help.
“The stated aim at the centre of this plan being to:
return to life as close to normal as possible, for as many people as possible, as fast and fairly as possible….
…in a way that avoids a new epidemic, minimises lives lost and maximises health, economic and social outcomes.”
The full document can be found at here, https://www.gov.uk/government/publications/our-plan-to-rebuild-the-uk-governments-covid-19-recovery-strategy
In supporting this strategy, 8 sector-based guidance documents were also released, all again published on the 11th May and covering:
- Construction and other outdoor work;
- Factories, plants and warehouses;
- Labs and research facilities;
- Offices and contact centres;
- Other people’s homes - people working in, visiting or delivering to other people’s homes;
- Restaurants offering takeaway or delivery;
- Shops and branches – effectively retail premises; and
- Vehicles - People who work in or from vehicles, including couriers, mobile workers, lorry drivers, etc.
Using the “office and contact centre” guidance as an example, the major areas covered in each include:
- How to use this guidance;
What do we mean by ‘offices and contact centres’?;
Thinking about risk;
Who should go to work?;
Social distancing at work;
Managing your customers, visitors and contractors;
Cleaning the workplace;
Personal protective equipment (PPE) and face coverings;
Inbound and outbound goods;
Where to obtain further guidance; and
Each of the sections are a mixture of information, advice and to quote the document “steps that will usually need to be taken”. The format and style are similar for each document and each run to approximately 30 pages in length.
The link to this guidance is - https://www.gov.uk/guidance/working-safely-during-coronavirus-covid-19
Sector specific information for education has been separately produced via the Department for Education DfE). The “Coronavirus (COVID-19): implementing protective measures in education and childcare settings” is a shorter document (the download is 12 pages) and while the overarching information is similar, the document content is in a slightly different format:
- Effective infection protection and control;
- Personal protective equipment (PPE) including face coverings and face masks;
- Shielded and clinically vulnerable children and young people;
- Shielded and clinically vulnerable adults;
- Living with a shielded or clinically vulnerable person;
- Class or group sizes;
- How to implement protective measures in an education setting before wider opening on 1st June 2020;
- When open; and
- Additional questions.
All the documents have a clear theme, with risk assessment being an implicit part of the process. None of the documents go into detail on building health issues such as air and water quality, fire and health and safety. Understanding the context of these requirements in relation to your remobilisation is going to be critical to its success.
2. What are the Government requirements for a COVID-19 risk assessment?
Section 1 of each of the sector specific guidance documents considers risk, under three headings:
- Thinking about risk;
- Managing risk; and
- Sharing the results of your risk assessment.
In “Thinking about risk” the stated objective is, “That all employers carry out a COVID-19 risk assessment.”
It continues, “Everyone needs to assess and manage the risks of COVID-19. As an employer, you also have a legal responsibility to protect workers and others from risk to their health and safety.”
It also asks:
- You consider the risks and what is reasonably practicable to minimise them, but it also recognises “you cannot completely eliminate the risk of COVID-19.”
- You must make sure that the risk assessment for your business addresses the risks of COVID-19, using of the guidance to inform your decisions and control measures.
- That the process is not about creating huge amounts of paperwork but identifying sensible measures to control the risks in your workplace, and if you have fewer than five workers, or are self-employed, you don’t have to write anything down as part of your risk assessment.
Employee consultation and involvement is strongly highlighted and in particular the need to “consult with the health and safety representative selected by a recognised trade union or, if there isn’t one, a representative chosen by workers.”
It also identifies the potential for enforcement, through the HSE or local authority, where employers “are not taking action to comply with the relevant public health legislation and guidance to control public health risks” (e.g. employers not taking appropriate action to socially distance, where possible).
The second section “Managing the risk” has an objective “To reduce risk to the lowest reasonably practicable level by taking preventative measures, in order of priority.”
This is emphasising the duty to reduce workplace risk to as low as is reasonably practicable. Also, the need for employers to work with “any other employers or contractors sharing the workplace so that everybody’s health and safety is protected.”
In the context of COVID-19 this includes examples of controls such as:
- The frequency of handwashing and surface cleaning;
- Working from home;
- Social distancing; or
- Other mitigating actions where social distancing guidelines cannot be met; and
- If people must work face-to-face for a sustained period with more than a small group of fixed partners, the need to assess whether the activity can safely go ahead and with particular regard to whether the people doing the work are especially vulnerable.
If you have not already done so, you should carry out an assessment of the risks posed by COVID-19 in your workplace as soon as possible. If you are currently operating, you are likely to have gone through a lot of this thinking already. We recommend that you use this document to identify any further improvements you should make.
3. What are your communications and activities around making your building ‘COVID Secure’?
Communicating the results of your risk assessment and displaying a “COVID-19 Secure” notice form the third and final aspect of the guidance under the sector specific guidance.
The requirement for your COVID-19 risk assessment is, “You should share the results of your risk assessment with your workforce. If possible, you should consider publishing the results on your website (and we would expect all employers with over 50 workers to do so).”
The “Staying COVID-19 Secure in 2020” notice is downloadable with each of the non education workplace guidance documents (see Question 1). Again, it is a standard format document and identifies “five steps to safer working together” These being:
- We have carried out a COVID-19 risk assessment and shared the results with the people who work here.
- We have cleaning, handwashing and hygiene procedures in line with guidance.
- We have taken all reasonable steps to help people work from home.
- We have taken all reasonable steps to maintain a 2m distance in the workplace.
- Where people cannot be 2m apart, we have done everything practical to manage transmission risk.
The expectation in the guidance is “you should display – the notice - in your workplace to show you have followed this guidance.”
These communications as well as those you are going to need to provide to staff returning to work will be instrumental in how successful you are in adapting to the changes needed, also consider:
- How you will inform employees of the changes you have made to your workplace?
- What are the expectations with access, working practices, facilities etc.?
- What mechanisms you have in place for consultation with and feedback from employees and others as relevant?
- Where emergency procedures have changed how these are reflected and notified to staff and others?
- The process for keeping your “COVID-19 Secure” status reviewed and up to date?