Although the subject (COVID-19) is new, the risk assessment process is not, but as with any risk assessment the key is getting it right for your organisation and its operational circumstances.
The three considerations for this month are therefore around COVID-19 risk assessments so you can look at what you currently have in place – or a planning to put in place - and any aspects you may want to concentrate on.
Below are three questions for you to consider areas of your management by investing 15 minutes of your time - to challenge your processes and procedures. In addition to the questions supporting information is provided for you on each of the subjects.
Please read on for some points to consider:
- What are the requirements for a COVID-19 risk assessment?
- Where are we seeing the issues with COVID-19 risk assessments?
- How should I be publishing my COVID-19 risk assessment information?
1. What are the requirements for a COVID-19 risk assessment?
“Our Plan To Rebuild” – The UK Government’s COVID-19 recovery strategy was published on the 11th May 2020 and covered six main themes:
- 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.”
In supporting this strategy there are currently 14 sector-based guidance documents, the original 8 of which were also published on the 11th May 2020. Each of the documents are broadly similar with a mixture of information, advice and “steps that will usually need to be taken”.
In conjunction with the sector guidance another document “5 steps to working safely” was published, designed to provide “practical actions for businesses to take based on 5 main steps.” The first of these steps is:
“1. Carry out a COVID-19 risk assessment
- Before restarting work, you should ensure the safety of the workplace by:
- carrying out a risk assessment in line with the HSE guidance
- consulting with your workers or trade unions
- sharing the results of the risk assessment with your workforce and on your website.”
Separately produced via the Department of Education was the sector specific guidance for “Coronavirus (COVID-19): implementing protective measures in education and childcare settings” which has overarching similar information.
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.
Section 1 of the sector guidance has an objective “That all employers carry out a COVID-19 risk assessment.”
“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 5 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 references the enforcement action that could be taken.
In the second element - Managing the risk, the objective is “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 and 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, then 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 the risk assessment to identify any further improvements you should make.
2. Where are we seeing the issues with COVID-19 risk assessments?
Both FM and health and safety are professions with a typically good understanding of risk assessments and safe systems of work. And while the sector guidance documents slightly confuse the hierarchy of controls, the process is well established.
How you consider and implement your controls following your risk assessment is critical to how successful you will be. Below are some of the insights we have seen/gained:
- One of the most common things we find in working with new customers is, while most have policies in place and control measures implemented, they often miss the bit in the middle (the why they are doing them) and so end up with a series of separate controls operating in isolation rather than a joined up management scheme.
- Your COVID-19 risk assessment needs to accurately reflect what your business plans are in the short and medium term. Occupancy levels will dictate much of the control strategies you will adopt, and these controls will vary depending on whether you are 90% or 10% occupied.
- Producing a risk assessment without knowing what your organisation’s intentions are (proposed strategy, remobilisation dates, who is returning and when, etc.), can mean initial controls - especially around movement and access - become quickly unsuitable. “Pinch points” such as those in kitchenettes, lifts and toilets can also prove additionally difficult to manage.
- Conversely for those who have identified workplace numbers and locations accurately, reviewing assessments and making changes appears to be easier.
- Allow for change – we have already seen a number of short-term changes in Government advice. Consider how the changes might affect your plans, your risk assessment and adapt them accordingly. “1m+” for example will have a major effect in some environments (hospitality to name one), but maybe little or no effect in already remobilised offices, with low occupancy who are happily accommodating 2m. Prevailing advice is still to maintain a 2m distance where you can. Employing “1m+” where practicable in pinch points such as toilets or kitchenettes, though may increase capacity/usability as you remobilise.
- As with many areas of health and safety, there are now easily available template COVID-19 risk assessment being produced. By nature, these are generic documents though, so if using one make sure you tailor it to your specific circumstances and be specific on the controls you have in place.
- Others that are doing it better seem clearer on what they need to achieve and are standing in their offices with tape measures and a roll of tape and deciding what can be done. Facilities teams sitting at home trying to plan from there seem less effective.
- Organisations with a clear communication plan and the involvement of multiple departments such as Facilities Management, Human Resources and IT are getting better response from staff to their COVID-19 risk assessment and as a result the working controls put in place. This is also an opportunity to get creative and engage. Ideas such as filming video walk throughs to allocating “COVID Champions” have been found to help engage staff and keep the right messages going out to the business.
- Make sure your risk assessment and controls are policed or enforced. How you do this will depend on your organisational culture, but you need to be consistent. COVID-19 is an emotive issue and not everyone will have the same behaviours or expectations. You should therefore set them out for the business with clear communication again being the key.
- Consultation has a high profile in the guidance, so make sure staff know how to raise any concerns or ideas.
- Home working remains a major control and should be recognised in the risk assessment and written scheme. It does get omitted or forgotten in some risk assessments. Where these people are intended to work from home for a prolonged period, they need to have their own assessment carried out too.
- Remember mental health and wellbeing as part of your risk assessment process.
3. How should I be publishing my COVID-19 risk assessment information?
The Working safely during Coronavirus (COVID-19) sector guidance documents, under “sharing your risk assessment” says, “You should share the results of your risk assessment with your employees. If possible, you should consider publishing it on your website (and we would expect all businesses with over 50 employees to do so).”
It also contains a notice you can print and display to show you have followed the relevant guidance. This is downloadable with each of the non education workplace guidance documents. And in reference to this notice the sector guidance states you “should display it in your workplace to show you have followed this guidance.”
The “Staying COVID-19 secure in 2020” (updated 23th July 2020) poster is standard format 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 safely from a COVID-19 Secure workplace or work from home.
- We have taken all reasonable steps to maintain a 2m distance in the workplace.
- Where people cannot keep 2m apart we have ensured at least a 1m distance and taken all the mitigating actions possible to manage transmission risk
The “Staying COVID-19 secure in 2020” poster is a simple, consistent and relatively easy addition to a building or floor entrance point and/or noticeboard. Once you are “COVID-19 Secure” however, publishing the risk assessment has seen different approaches including:
- Published their COVID-19 risk assessment on their websites, available for anyone to view;
- Published them on their intranet so are only available to staff;
- Providing copies of the risk assessment with return to work inductions; and
- Referencing the risk assessment results and “making it available on request” to employees.
With little enforcement information so far available and regularly changing advice and guidance, and dependent on your numbers of employees, the right solution could be any of these options. Use your COVID-19 risk assessment proactively and adapt it according to changes and new information, and communicating it is key.